School District of West De PereLocal Government

Control Deficiencies Suspension and Debarment – Child Nutrition Cluster Type of Finding: Significant deficiency in internal control compliance Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Pass-Through Agency: Wisconsin Department of Instruction Pass-Through Number(s): 2024-056328-DPI-SB-546, 2024-056328-DPI-NSL-547, 2024-056328-DPI-SFSP-586 Award Period: 7/1/23 – 6/30/24 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The organization should have procedures for verifying that an entity with which it plans to enter a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: The District has a policy in place that meets the requirements of Uniform Guidance, however, the policy was not followed in 2023-2024. Questioned Costs: None noted. Context: For 5 out of 5 vendors tested, the District did not have documentation of checking for suspension and debarment. Cause: Due to turnover in the Food Service Director Position and related support staff, new Food Service Director was not able to produce documentation that suspension and debarment was checked for the vendors tested. Effect: The district could potentially be using Federal Grant dollars for suspended or debarred vendors Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District implement a process to check for suspension and debarment for all vendors exceeding the threshold for purchases. Views of responsible officials: There is no disagreement with the finding

2020-004 Control Deficiencies Federal Grants Management Procurement Policy CFDA 84.027 and 84.173 Type of Finding Significant deficiency in internal control over compliance. Condition During our testing of procurement transactions of the program we noted that the selection of a vendor for cabinetry work 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. Additionally, our testing of internal controls over compliance identified the following weakness in internal control: there is not proper identification of what purchases require the District to obtain quotes or bids in compliance with the procurement policy. 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). Context In our statistically valid sample of 6 transactions tested, there was an error in 1, or about 16.7%. Cause The District did not follow their Federal Funds Procedural Manual, effective July 1, 2015, section 3 of the purchasing chapter related to appropriate methods of procurement. Effect Obtaining price quotes from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of price quotes may cause the District to over pay for supplies or services. Recommendation We recommend the District follow their purchasing policy related to small purchases which includes obtaining price quotes from an adequate number of vendors (at least two) and maintaining this documentation. Views of Reasonable Officials Refer to the management response per the corrective action plan.

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