School District of Cudahy

Condition: The District did not have appropriate M-5's on file for several students. Criteria: Districts are required to maintain a signed and dated M-5 form (Consent to Bill Wisconsin Medicaid) for each student who has services billed through Medicaid. Cause: District staff did not maintain proper documentation to bill Medicaid for students. Effect: Failing to obtain a signed and dated M-5 form could affect the reimbursements received by the District under the SBS Medicaid program. Recommendation: We recommend the District review its procedures for obtaining and maintaining appropriate documentation for each student whose services are billed through Medicaid. Corrective Action Plan: The District will strengthen its procedures for obtaining, verifying, and maintaining required documentation. This will include implementing a standardized process to ensure M- 5 forms are completed, collected, and securely retained prior to submitting any claims for reimbursement. Additionally, the District will conduct periodic internal reviews to confirm that all required documentation is on file and up to date.

Condition: The District could not provide documentation to attest the construction contracts met Davis- Bacon prevailing wage requirements. Criteria: As required by the Davis Bacon Act, auditees are required for any minor remodeling, renovation or construction contracts that are over $2,000 and use laborers and mechanics must meet prevailing wage requirements. Cause: The District does not have a process in place to track which contracts meet the Davis-Bacon prevailing wage requirements and ensure proper documentation is obtained. Effect: The District is at risk of jeopardizing the continued funding provided by the federal agencies. Recommendation: It is recommended that the District implement procedures to ensure documentation related to the use of federal funds are properly obtained, stored centrally and can be located timely. Corrective Action Plan: The District will strengthen its procedures when attestation of prevailing wages is required. The District will also develop a checklist to verify that all Davis-Bacon requirements are met prior to contract execution and throughout the life of each project. The District is committed to strengthening its controls and ensuring full compliance with Davis-Bacon prevailing wage requirements going forward.

Finding 2024 – 1: Audit Journal Entries Comment: During audit fieldwork, our testing resulted in audit adjustments in order to present materially accurate financial statements. Recommendation: A vital process of effective internal controls is the review and subsequent adjustment of general ledger balances. This review and adjustment will aid in the appropriate budgeting and management of the District’s financial activities and resources.

Finding 2024 – 2: Bank Reconciliation Comment: During audit fieldwork, we discovered material weakness over the internal control related to the bank reconciliation process, which has resulted in significant discrepancies in the reconciliation for cash. Recommendation: We recommend the District implement effective internal controls in order to provide an accurate assessment of reporting requirements on bank reconciliation.

Federal Agency: U.S. Department of Education Federal Program Name: Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund Assistance Listing Number: 84.425D & 84.425C Federal Award Identification Number and Year: 2021 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2021-401253-DPI-GEERF-162, 2022-401253-DPI-ESSERFII-163 & 2022-401253-DPI-ESSERFIII-165 Award Period: July 1, 2020 through September 30, 2022, March 13, 2020 through September 30, 2029 and July 1, 2020 through September 30 ,2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria or specific requirement: 2 CFR section 200.313(d)(1) requires property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. Condition: The District’s capital asset records do not include all of the required aspects of property records as required by Uniform Guidance. The detail capital asset records do not identify the source of the funding for the property or the percentage of federal participation in the project costs for the federal award under which the property was acquired. Questioned costs: None Context: The Districts capital asset records are not currently designed to track the source and percentage of federal participation in a project as the District does not commonly utilize federal funding for capital purchases. Cause: The District has not designed and implemented controls to ensure capital asset records included all necessary information for assets purchased with federal awards. Effect: Capital asset records for assets purchased, wholly or partially, with federal awards do not include all necessary details as required by Uniform Guidance. Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend the District design and implement capital asset record procedures and controls that ensure all necessary information is track in capital asset records for assets purchased with federal awards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund Assistance Listing Number: 84.425D & 84.425C Federal Award Identification Number and Year: 2021 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2021-401253-DPI-GEERF-162, 2022-401253-DPI-ESSERFII-163 & 2022-401253-DPI-ESSERFIII-165 Award Period: July 1, 2020 through September 30, 2022, March 13, 2020 through September 30, 2029 and July 1, 2020 through September 30 ,2024 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria or specific requirement: 29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction requires that all nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. Condition: During testing of both of the qualifying contracts for selected for testing for compliance with requirements of the Davis-Bacon Act. Neither contract contained requirement clauses communicating required compliance with Davis-Bacon Act provisions. Questioned costs: None Context: The agreements entered into during the fiscal year under audit were for project that were below the scope the contractor and District require full contracts for. As such simplified agreements were entered, which did not include written Davis-Bacon Act clauses. Cause: The District did not design and implement controls to ensure contract qualifying for Davis-Bacon Act compliance included all required clauses. Effect: Projects subject to compliance with provisions of the Davis-Bacon Act may not have been conducted in compliance with such requirements. Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend the District design and implement internal controls that ensure all necessary clauses, provisions and languages in included in contracts subject to compliance with Davis-Bacon Act. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund Assistance Listing Number: 84.425D & 84.425C Federal Award Identification Number and Year: 2021 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2022-401253-DPI-ESSERFII-163 & 2022-401253-DPI-ESSERFIII-165 Award Period: March 13, 2020 through September 30, 2029 & July 1, 2020 through September 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria or specific requirement: For contracts between federal award recipients and contracts that are subject to David-Bacon Act requirements, 29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(I)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions) and 2 CFR Part 176, Subpart C; and 2 CFR section 200.326 require the contractor or subcontractor submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Condition: Both of the qualifying projects selected for testing for compliance with requirements of the Davis-Bacon Act for the submission of weekly certified payrolls by the contractor. The District did not obtain or review weekly payrolls for either contract subject to Davis-Bacon Act provisions. For both contracts certified payrolls were subsequently obtained supporting related weekly payroll. Questioned costs: None Context: The District entered into agreements during the fiscal year under audit for project that were below the scope the contractor and District require full contracts, which included establishing submission and monitoring requirements for weekly certified payrolls. As the District does not commonly entered into contracts subject to these requirements, policies and process in place did not address these requirements. Cause: The District did not design and implement controls to ensure weekly certified payrolls were completed by the contractor and submitted to the District contracts qualifying for Davis-Bacon Act provisions. Effect: Projects subject to compliance with provisions of the Davis-Bacon Act may not be in compliance with required provision for required weekly pay.. Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend the District design and implement internal controls that ensure required documentation of weekly certified payrolls are obtained and reviewed for all contracts subject to compliance with Davis-Bacon Act. Views of responsible officials: There is no disagreement with the audit finding. Federal Program Name: Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund Assistance Listing Number: 84.425D & 84.425C Federal Award Identification Number and Year: 2021 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2022-401253-DPI-ESSERFII-163 & 2022-401253-DPI-ESSERFIII-165 Award Period: March 13, 2020 through September 30, 2029 & July 1, 2020 through September 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria or specific requirement: For contracts between federal award recipients and contracts that are subject to David-Bacon Act requirements, 29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(I)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions) and 2 CFR Part 176, Subpart C; and 2 CFR section 200.326 require the contractor or subcontractor submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Condition: Both of the qualifying projects selected for testing for compliance with requirements of the Davis-Bacon Act for the submission of weekly certified payrolls by the contractor. The District did not obtain or review weekly payrolls for either contract subject to Davis-Bacon Act provisions. For both contracts certified payrolls were subsequently obtained supporting related weekly payroll. Questioned costs: None Context: The District entered into agreements during the fiscal year under audit for project that were below the scope the contractor and District require full contracts, which included establishing submission and monitoring requirements for weekly certified payrolls. As the District does not commonly entered into contracts subject to these requirements, policies and process in place did not address these requirements. Cause: The District did not design and implement controls to ensure weekly certified payrolls were completed by the contractor and submitted to the District contracts qualifying for Davis-Bacon Act provisions. Effect: Projects subject to compliance with provisions of the Davis-Bacon Act may not be in compliance with required provision for required weekly pay.. Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend the District design and implement internal controls that ensure required documentation of weekly certified payrolls are obtained and reviewed for all contracts subject to compliance with Davis-Bacon Act. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Title I Grant to Local Educational Agencies Assistance Listing Number: 84.010 Federal Award Identification Number and Year: S010A220049; 2022 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2023-401253-DPI-TI-A-141 Award Period: July 1, 2022 through June 30 ,2023 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria or specific requirement: ESEA sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25) (20 USC 6311(h)(1)(C)(iii)(II) and 7801(23),(25)) required to remove a student from the cohort, a school or Local Education Authorities (LEA) must confirm, in writing, that the student transferred out, emigrated to another country, transferred to a prison or juvenile facility, or is deceased. Condition: The District did not retain document to support the removal of students from the adjusted cohort. Questioned costs: None Context: The District was not able to provide to the auditor documentation of the process to track and monitor the documentation of students removed from the adjust cohort. In addition, no documentation was available to review for any students removed from the adjusted cohort. Cause: The District did not design and implement internal controls to ensure the documentation was retained for any students removed from the adjusted cohort. Effect: The adjusted cohort may not include all student required for the calculation. Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend the District design and implement procedures and internal controls to ensure proper documentation is obtained and retained for any students removed from the adjusted cohort.

Federal Agency: U.S. Department of Education Federal Program Name: Title I grant to Local Educational Agencies Assistance Listing Number: 84.010 Federal Award Identification Number and Year: S010A220049; 2022 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2023-401253-DPI-TI-A-141 Award Period: July 1, 2022 through June 30 ,2023 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria or specific requirement: Title I, Section 1111(b)(2)(B)(iii) required that the Local Education Authorities (LEA) design and implement policies and procedures for ensuring that the LEA and its schools implement test security measures. Condition: The District did not design, document or implement test security measures in compliance with Title I requirements. Questioned costs: None Context: The District was not able to provide to the auditor documentation of the design or implementation of test security policy that comply with the requirements of Title I. Cause: The District did not monitor or document compliance with the requirement to design, document or implement test security. Effect: The District may not be in compliance with requirements to ensure test security in compliance with their State Education Authority requirements and Title I requirements. Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend the District design and implement test security measures and internal controls to ensure these policies comply with requirements of Title I.

2021 ? 002 Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.555 & 10.559 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): Not available Award Period: July 1, 2020 ? June 30, 2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: UG ?200.318 General procurement standards require that: (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: The District was not able to provide documentation to support the purchase rational, selection procedures and basis for the price for all procurement transactions selected for testing.. Questioned costs: None. Context: For the 1 procurement selected for testing, the District did not retain full records support compliance with procurement policies and controls established by the District and in accordance with Uniform Guidance. The entire eligible population was selected for testing. Cause: The District did not retain documentation of procurement purchase for the entire duration of the contract in a manner that allowed for the review of records during the audit. Effect: The District is not in compliance with document retention requirements for procurement transaction as required by Uniform Guidance. Repeat Finding: The finding is not a repeat of a finding. Recommendation: The District should design and implement controls to ensure that all aspects of Uniform Guidance procurement requirements, including document retention requirements, are complied with. Views of responsible off

Federal agency: Department of Education Federal program title: ESEA Title 1 ? Basic Grants (LEA) State ID Number: 84.010 Award Period: July 1, 2018 through June 30, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria or specific requirement: 2 CFR Section 200.430 (i)(1), Uniform Guidance, requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect work performed. These records must include support for the distribution of salary and wages among specific activities or cost objects. Budget estimates alone do not qualify as support for charges to Federal Awards but maybe used for interim accounting provided, among other things, an after the fact review is performed and necessary adjustments are made. Condition: CLA reviewed 22 payroll transactions for individuals whose time was charged based on the budgeted allocation and reviewed all 2 financial reports filed by the District including salary and wages claims. Noted the budgeted allocation rate was properly applied, but the after-the-fact review was not formally documented or approved. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Questioned costs: N/A. Context: The District uses multiple funding sources to pay for employees. At the beginning of the year, the District determines a budgeted percentage of an employee?s wage will be funded by Title 1 based on employees anticipated work with Title I eligible programs and available funding sources. The District uses this budget percentage throughout the year to charge eligible costs to the grant. As financial reports are reviewed by the Title IA coordinator she reviews the employees charged based on job duties actually performed. However, this review is not formally documented or approved. Cause: The District does not formally document or approve its after-the-fact review of budgetary percentages used for charging through-out the year. This review is conducted as part of the financial report preparation process. Effect: Errors in the after-the-fact review could occur and would not be identified and corrected, potentially resulting in ineligible salary or wages being charged to the grant. Repeat Finding: Not a repeat finding. Recommendation: We recommend that the District design and implement controls to document and approve this after-the-fact review. Views of responsible officials: There is no disagreement with the audit finding.

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