Port Washington-Saukville School DistrictLocal Government

2023 – 002 Federal Agency: U.S Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555 Federal Award Identification Number and Year: 212WI063N1199, 222WI063N1199; 2022 and 2023 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2021-454515-NSL-547 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria or specific requirement: Uniform Guidance requires grant recipients implement and apply procurement policies that align with the requirements outlined in 2 CFR part 200.318-320, including the selection of vendors based on the identified informal and formal procurement methods, referred to as micro-purchases, small purchases, sealed bids, proposals and when noncompetitive procurement methods may be applied. The grant recipients are also required to design and implement an internal control structure to ensure compliance with procurement standards identified in 2 CFR Part 200.318-320 are complied with and necessary documentation retained. Condition: During our evaluation of the District's procurement policies in effect for the year under audit, it was noted that the policy in force for part of the year did not identify the correct thresholds for the selection of vendors in informal procurement methods, micro-purchases and small purchase. The policy was update during the year to comply with such requirements. Questioned costs: None. Context: The District's purchasing policy updated during the year to comply the thresholds in Uniform Guidance and to required retention of documentation of these evaluations. Prior to this update, the District's purchasing policy was had not been updated for several years and did not include all necessary aspects to comply with Uniform Guidance. Cause: The District did not complete its review and updating of the procurement prior to the beginning of year and the initiation of current contracts. Effect: The District's purchasing policy in effect during part of the year under audit did not fully comply with the requirements of the Uniform Guidance related to the use of informal procurement methods, micro-purchase and small purchase transactions. Repeat finding: This is a repeat of finding 2022-002. Recommendation: We recommend the District should review and update, as necessary, policies to ensure they fully comply with Uniform Guidance and any other applicable requirements. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 003 Federal Agency: U.S Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555 Federal Award Identification Number and Year: 212WI063N1199, 222WI063N1199; 2022 and 2023 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2021-454515-NSL-547 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR Part 200 Section 200.214 - Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Grant recipients are required to design and implement control process to ensure grant requirements are complied with, including requires related to non-procurement debarment and suspension regulations. Condition: During our testing, we noted the District was not able to provide documentation of compliance with their control process and evidence that three vendors were not suspended or debarred prior to the purchase. Questioned costs: None. Context: For the 2 vendors with purchases exceeding the threshold, the District did not retain documentation that they had verified that the vendor was not suspended or debarred by the Federal Government prior to purchase. The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of compliance with their internal controls over these compliance requirements provides an opportunity for noncompliance. Cause: The District did not retain documentation of their verification and documentation of the vendor’s status as not suspended or debarred with the Federal Government. Effect: The lack of documentation over these compliance requirements provides an opportunity for noncompliance. Repeat finding: This is a repeat of finding 2022-003. Recommendation: We recommend the District design controls to ensure an adequate documentation of control and review of potential contractors to determine they are not suspended or debarred is retained for all applicable vendor relationships. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Uniform Guidance requires grant recipients implement and apply procurement policies that align with the requirements outlined in 2 CFR part 200.318-320, including the selection of vendors based on the identified informal and formal procurement methods, referred to as micro-purchases, small purchases, sealed bids, proposals and when noncompetitive procurement methods may be applied. The grant recipients are also required to design and implement an internal control structure to ensure compliance with procurement standards identified in 2 CFR Part 200.318-320 are complied with and necessary documentation retained. Condition: During our evaluation of the District's procurement policy in effect for the year under audit, it was noted that policy did not identify the correct thresholds for the selection of vendors in informal procurement methods, micro-purchases and small purchase. In addition, the District did not maintain documentation of the selection of vendors in compliance with Uniform Guidance for the five (5) small purchase transaction selected for testing, as part of a statistically valid sample. Questioned costs: N/A Context: The District's purchasing policy was adopted several years ago and the formal policy has not be updated for the thresholds in Uniform Guidance and to required retention of documentation of these evaluations. For the 5 vendors selected for testing in a non-statistically valid sample, the District was not able to provide documentation of their compliance with the required vendor selection criteria. Cause: The District did not review and update the procurement policy in effect to comply with Uniform Guidance and update threshold identified in the most current updates to the Uniform Guidance. Effect: The District's purchasing policy in effect during the year under audit did not fully comply with the requirements of the Uniform Guidance related to the use of informal procumbent methods, micro purchase and small purchase transactions. In addition, the District may not apply proper procurement requirements to transactions. Repeat Finding: Not a repeat finding. Recommendation: We recommend the District should review and update as necessary the procurement policies to ensure they fully comply with Uniform Guidance and any other applicable requirements. The District should design and implement control process to ensure grant transactions comply with Uniform Guidance requirements and proper documentation is maintained. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Per 2 CFR Part 200 Section 200.214 - Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Grant recipients are required to design and implement control process to ensure grant requirements are complied with, including requires related to non-procurement debarment and suspension regulations. Condition: During our testing, we noted the District was not able to provide documentation of compliance with their control process and evidence that three vendors were not suspended or debarred prior to the purchase. Questioned costs: N/A Context: For the 3 vendors with purchases exceeding the threshold, the District did not retain documentation that they had verified that the vendor was not suspended or debarred by the Federal Government prior to purchase. The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of compliance with their internal controls over these compliance requirements provides an opportunity for noncompliance. Cause: The District did not retain documentation of their verification and documentation of the vendor?s status as not suspended or debarred with the Federal Government. Effect: The lack of documentation over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: Not a repeat finding. Recommendation: We recommend the District design controls to ensure an adequate documentation of control and review of potential contractors to determine they are not suspended or debarred is retained for all applicable vendor relationships. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: The Wisconsin Department of Health Services guidelines indicates that Wisconsin Department of Public Instruction Form M-5 must be accessible to the auditor within the agency?s documentation for each student for whom services were billed under the School Based Services program. Condition: In our statistically valid sample of 40 students tested we identified 10 students for whom Form M5?s were not able to be reviewed during the audit procedures. Questioned costs: N/A Context: The District was not able to produce the signed Form M-5 for 10 of the students sampled due to availability of historical records for students who were no longer receiving services or whom were no longer served by the District. Cause: The District?s document retention policy did not consistently require the retention of Form M5 in the student?s file for students that transferred out of the District or for student who no longer received services that would be billed under the School Based Services program. Effect: The District identified and claimed expenses for school-based services for students that did not have Form M-5, Consent to Bill Wisconsin Medicaid, retained in accordance with State Requirements. Repeat Finding: Not a repeat finding. Recommendation: We recommend the District design and implement controls and procedures to ensure that students Form M5 is retained and available for review in accordance with Sate Requirements. Views of responsible officials: There is no disagreement with the audit finding.