Pittsville School DistrictLocal Government

Federal Agency: US Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: Unknown Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2023-714368-DPI-SB-SEVERE-546, 2023-715368-DPI-NSL-547, 2023-714368-SPI-SK_NSL-561, Unknown, 2023-714368-DPI-SFSP-586 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria or Specific Requirement: 2 CFR Section 320.318(i) requires the District to 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. 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal 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: The District policy requires that they receive multiple price quotes for transactions over $10,000. The District policy also requires that for contracts, they include a suspension and debarment verification within said contract as well as look up the vendor’s status on sam.gov. The district did not retain documentation for multiple price quotes for 4 out of 5 small purchase transactions in our sample. The District also did not retain documentation related to suspension and debarment status for 2 out of 4 vendors in our sample. Questioned Costs: None Context: While the department heads are responsible for ensuring they maintain documentation over price quotes to comply with the districts small purchase policy, the District did not retain documentation over price quotes obtained nor documentation of how the vendor was ultimately selected for 4 out of 5 small purchase transactions in our sample. The District did not retain documentation over verification that the vendors status of suspension and debarment from sam.gov for 2 out of 4 vendors in our sample. Cause: The District employees did not retain the supporting documentation for information obtained from vendors. Also, due to turnover at the district with the superintendent, they are unable to locate the documentation for verification of suspension and debarment status. Effect: Procurement transactions may not be in compliance with the Uniform Guidance. District could contract with a vendor that has been suspended or debarred from receiving federal funds. Repeat Finding: No. Recommendation: We recommend that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to help ensure compliance. We also recommend the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status prior to entering into the transaction. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: US Department of Education Federal Program Name: Elementary and Secondary School Emergency Relief Assistance Listing Number: 84.425D, 84.425U Federal Award Identification Number and Year: S425U210044 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2022-714368-DPI-ESSERFII-163, 2022-714368-DPI-ESSERFIII-165 Award Period: 3/13/2020-9/30/2024 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or Specific Requirement: Segregation of duties is an internal control intended to prevent or detect the occurrence of errors or intentional fraud. Segregation of duties ensures that no single employee has control over all phases of a transaction. Condition: The director of business services has the capability of doing all functions of the general disbursement and payroll processes. There is a bookkeeper that helps with some of the steps in these processes, but the bookkeeper is part-time and the director of business services will complete these tasks in her absence. The director of business services prepared the annual report and there was no review of the report by someone other than the preparer prior to submission to Wisconsin Department of Public instruction. Accordingly, this does not allow for a proper segregation of duties for internal control purposes. Questioned Costs: None Context: When identifying internal controls over compliance related to reporting (annual report) and allowable costs and allowable activities (general disbursements and payroll), it was noted that the director of business services position handled all the responsibilities of those functions and there were no formal, documented internal controls over compliance in place to review that procedures were performed as required and no review of the work completed by someone other than the preparer. 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 segregation of duties. District could incorrectly report amounts and other data on the annual report. Repeat Finding: No. Recommendation: We recommend the District review its processes related to general disbursements for grants and implement a control where someone other than the director of business services is reviewing disbursements coded to grant project codes to help ensure compliance with grant requirements. For payroll transactions, we recommend implementing a control where someone other than the director of business services is reviewing who is coded to the grant on a routine basis and that the payroll allocation to the grant is appropriate and supported by time and effort documentation. We also recommend that the District implement a formal review process over the reporting requirement relating to ESSER annual reports. View of Responsible Officials: There is no disagreement with the audit finding.