GREENWOOD SCHOOL DISTRICT

Child Nutrition Segregation of Duties Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 and 10.582 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-SB-SEVERE-546, 2022-102394-DPI-NSL-547, 2022-102394-DPI-SK_NSLAE-561, 2022-102394-DPI-FFVP-Oct-376, 2022-102394-DPI-SFSP-561, 2022-102394-DPI-FFVP-July-594 Award period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: 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 transaction. Condition: The Business Service Director is responsible for preparing and submitting claims related to the Child Nutrition Cluster and the District administrative assistant is responsible for updating student eligibility records based on verification of income eligibility. There is no formal, documented review or verification by someone other than the preparer that the appropriate steps are being followed or completed. Accordingly, this does not document proper segregation of duties for internal control purposes. Questioned Costs: None. Context: When identifying internal controls over compliance related to reporting (reimbursement requests) and verification of eligibility (special tests and provisions), it was noted that there were no formal, documented controls in place to review that procedures were performed as required and that there was a review over the work to prevent error or fraud. Cause: With the limited staffing at the District, there is one person that was dedicated for each area and the review has not been documented properly. 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. The District could over- or under-claim monthly reimbursements resulting in payment back or unearned reimbursement from the granting agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-006. Recommendation: We recommend that the District implement a formal review process over the reporting and verification requirements related to the Child Nutrition Cluster during the fiscal year and properly retain the documentation. Views of Responsible Officials: There is no disagreement with the audit finding.

Child Nutrition Cluster Segregation of Duties Child Nutrition Cluster ? Assistance Listing No. 10.553, 10.555, 10.559 and 10.582 Recommendation: CLA recommends that the District implement a formal review process over the reporting and verification requirements related to the Child Nutrition Cluster during the fiscal year and properly retain the documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This process was completed in the fall of 2022. The person handling this for 2021-22 didn?t complete this process because lunches and breakfasts were all free.. Name(s) of the contact person(s) responsible for corrective action: Lisa Hinker Planned completion date for corrective action plan: Fall of 2022

2021-006

Education Stabilization Fund Equipment/Real Property Management Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund - Elementary and Secondary School Emergency Relief Fund and Governor's Emergency Education Relief Fund Assistance Listing Number: 84.425C and 84.425D Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-ESSERFII-163, 2021-102394-DPIGEERF-162, 2021-102394-DPIESSERF-160 Award period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: 2 CFR Section 200.131(d) states (1) 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 FAIN), who holds title, the acquisition date, and 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 sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. (5) If the non-federal entity is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return. Condition: The District's controls identified and tracked assets that were paid for by grant dollars, however there needs to be improvements in the documentation of those controls. Questioned Costs: None. Context: While performing audit procedures, it was noted that the District did not have policies in place to ensure documentation of the District?s controls classifying and retaining information about capital asset purchases with federal funds for both assets in our sample. Cause: The District was not aware of the compliance requirements related to equipment and real property purchased with federal funding by the District. Effect: Equipment or real property purchased with federal funds may not have properly maintained property records and upon disposition of the asset the District may have failed to provide information and funds back to the federal government. Repeat Finding: No Recommendation: We recommended that the District implement proper documentation of controls over maintaining property records for equipment and real property purchased with federal funds and ensure documentation of a physical inventory of capital assets is completed at least every two years. Views of Responsible Officials: There is no disagreement with the audit finding.

Elementary and Secondary School Emergency Relief Equipment/Real Property Management Elementary and Secondary School Emergency Relief ? Assistance Listing No. 84.425C and 84.425D Recommendation: CLA recommends that the District implement proper documentation of controls over maintaining property records for equipment and real property purchased with federal funds and ensure documentation of a physical inventory of capital assets is completed at least every two years. Explanation of disagreement with audit finding: Capital Fixed Asset reports are maintained by the District with designated grant project information attached to the items. Linda Schmitt is using Asset Tiger to track inventory items. Action taken in response to finding: Capital fixed assets will be reviewed every 2 years for retention of items that have been purchased with federal grant funds. Name(s) of the contact person(s) responsible for corrective action

Education Stabilization Fund Wage Rate Requirements Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund - Elementary and Secondary School Emergency Relief Fund Assistance Listing Number: 84.425D Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-ESSERFII-163 Award period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other Matter Criteria or Specific Requirement: 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. Internal controls should be designed and implemented to prevent or detect noncompliance with this requirement. Condition: The District had 2 construction projects funded by ESSER during 2021-22. The District is responsible for ensuring the contractor provides the appropriate certified payrolls and reviewing them to ensure the prevailing wage rates are being met or exceeded. The documented review of the certified payrolls did not occur. When the District had a construction manager for one of the projects, the District did not implement controls to monitor the construction management company to ensure this compliance requirement was met. Questioned Costs: $14,420. Context: For one of the projects, the District did not have a signed contract that included all required prevailing wage components. The District did not obtain the appropriate certified payrolls and did not document any review of the certified payrolls ensuring appropriate wage rates were being charged for the project. It was noted that the District's construction manager for the other project did obtain and review the appropriate certified payrolls; however, the District did not implement controls to monitor the construction manager to ensure this compliance requirement was met. Cause: The District was not aware of the Davis Bacon Act and the compliance requirements surrounding it. Effect: The District could pay vendors that are not in compliance with the wage rate requirements (Davis Bacon Act). Repeat Finding: No Recommendation: We recommended that the District implement controls to ensure construction contracts include the proper wording and implement controls to ensure certified payrolls are received and reviewed. We also recommend the district implement controls for monitoring third-party contractors when the contractors are responsible for compliance requirements. Views of Responsible Officials: There is no disagreement with the audit finding.

Elementary and Secondary School Emergency Relief Wage Rate Requirements Elementary and Secondary School Emergency Relief ? Assistance Listing No. 84.425D Recommendation: CLA recommends that the District implement controls to ensure construction contracts include the proper wording and implement controls to ensure certified payrolls are received and reviewed. We also recommend the district implement controls for monitoring third party contractors when the contractors are responsible for compliance requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The district was contracting with CESA #10 facilities management to oversee the project. The prevailing wage requirement was designated in the bidding process and the district was assured that the prevailing wage rule would be met. Wage reports were requested and maintained by the CESA #10 office. From now on the district will be requesting that these documents be sent on to the district in a timely manner for review and take pictures of the postings at the job site. Name(s) of the contact person(s) responsible for corrective action: Joe Green Planned completion date for corrective action plan: Next capital project

2021-004 Segregation of Duties ? Grant Management Repeat of Finding 2020-004 All Federal Programs All State Programs All Pass-Through Agencies Award period: July 1, 2020 ? June 30, 2021 Type of Finding: Material Weakness in Internal Control over Compliance. Condition: Please see the condition described in Finding 2021-001 for information on the lack of segregation of duties specifically related to the activities allowed or unallowed, and allowable costs/cost principles. Additionally, our testing of internal controls over federal and state grants identified the following weaknesses in internal controls due to the lack of segregation of duties in relation to the Uniform Guidance and State Single Audit Guidelines compliance requirements: ? There is no separate review of the payroll transactions processed by the Director of Business Services and subsequently included on the grant claims. ? There is no separate review of the grant claims which are the basis for the schedule of expenditures of federal awards and schedule of expenditures of state awards. Criteria or Specific Requirement: 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 transaction. Context: While performing audit procedures, it was noted that the District does not have adequate segregation of duties for internal control purposes. Questioned Costs: None. Cause: The lack of segregation of duties is due to the limited number of employees and the size of District?s operations. The District has not recently completed a full risk assessment and review of internal controls to identify additional mitigating and compensating controls to implement to reduce the risk of errors or intentional fraud. 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.

2021-004 Segregation of Duties ? Grant Management All federal and state programs. Recommendation: CLA recommends the District perform a risk assessment of its operations and current procedures to identify and implement mitigating controls to reduce the risk of errors and intentional fraud. The District should review its disbursement process to ensure that there is adequate segregation of duties in regards to initiating, authorizing and approving purchases, along with adding controls to ensure that the item purchasesensure that there is adequate segregation of duties in regards to preparing and approving grant claims prior to submission for reimbursement to the granting agency. The District should review its payroll process and identify payroll tasks that could be reassigned to other District personnel. The District should also review its receipting process and identify tasks that could be reassigned to other District personnel. We also recommend the District Board continue to monitor the transactions and the financial records of the District. Explanation of disagreement with audit finding: District does not have any disagreement with the audit finding. Action planned/taken in response to finding: Grant project payroll transactions will be reviewed by administration and with the CESA officials for the respective projects. The detail reports will have a sheet that is signed off on by the reviewers. Federal and State Single Audit Guidelines will be reviewed. Payroll detail is being given to the district administrator and principal for the budgeting and CESA grant project meetings with WUFA account detail. The Accounting Procedures document is being reviewed each year with board, administration and staff that are involved in preparation for a possible Single Audit. Name(s) of the contact person(s) responsible for corrective action: Todd Felhofer, 715-267-6101. Planned completion date for corrective action plan: Ongoing.

2021-005 Financial Reporting for Federal and State Awards Repeat of Finding 2020-005 All Federal Programs All State Programs All Pass-Through Agencies Award period: July 1, 2020 ? June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance. Condition: Section 200.510 of the Uniform Guidance and Section 2.1.6 of the main document of the SSAG requires the District to prepare appropriate financial statements, including the schedule of expenditures of federal awards and the schedule of expenditures of state awards. While the current staff of the District maintains financial records supporting amounts reported in the schedule of expenditures of federal awards and schedule of expenditures of state awards, the District contracts with CLA to compile the data from these records and prepare the schedule of expenditures of federal awards and schedule of expenditures of state awards for the District. However, as independent auditors, CLA cannot be considered part of the District?s internal control system. As part of its internal control over preparation of its schedule of expenditures of federal awards and schedule of expenditures of state awards, including disclosures, the District had implemented a comprehensive review procedure to ensure the schedule of expenditures of federal awards and schedule of expenditures of state awards, including note disclosures, are complete and accurate. Criteria or Specific Requirement: Having staff with expertise in federal and state financial reporting prepare the District?s single audit schedules is an internal control intended to prevent, detect and correct a potential misstatement in the schedules of expenditures of federal and state awards, or accompanying notes to the schedule. Context: While performing audit procedures, it was noted that management does not have internal controls in place to provide reasonable assurance that the schedule of expenditures of federal awards and schedule of expenditures of state awards are prepared in accordance with U.S. GAAP. Questioned Costs: None Cause: The additional costs associated with hiring staff sufficiently experienced to prepare the District?s single audit schedules, including the additional training time, outweigh the derived benefits. Effect: The District could receive federal or state grant awards which are not included in the accompanying schedules of expenditures of federal and state awards.

2021-005 Financial Reporting for Federal and State Awards All federal and state programs. Recommendation: CLA recommends District personnel continue reviewing the District?s single audit schedules. Such review procedures should be performed by an individual possessing a thorough understanding of Uniform Guidance and State Single Audit Guidelines requirements and knowledge of the District?s activities and operations. While it may not be cost beneficial to hire additional staff to prepare these items, a thorough review of this information by appropriate staff of the District is necessary to ensure all federal and state award programs are properly reported in the District?s single audit schedules. Explanation of disagreement with audit finding: District does not have any disagreement with the audit finding. Action planned/taken in response to finding: Grant project payroll transactions will be reviewed by administration and with the CESA officials for the respective projects. The detail reports will have a sheet that is signed off on by the reviewers. Federal and State Single Audit Guidelines will be reviewed. Payroll detail is being given to the districtadministrator and principal for the budgeting and CESA grant project meetings with WUFAR account detail. Name(s) of the contact person(s) responsible for corrective action: Todd Felhofer 715-267-6101. Planned completion date for corrective action plan: Ongoing.

2021-006 Child Nutrition Segregation of Duties Federal Agency: U.S. Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listing Number: 10.555 and 10.559 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2021-102394-DPI-NSLAE-566, 2021-102394-DPI-SFSP-566, Unknown Award period: July 1, 2020 ? June 30, 2021 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: 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 transaction. Compliance Requirements: Cash Management, Special Tests and Provisions. Condition: The Business Service Director is responsible for preparing and submitting claims related to the Child Nutrition Cluster and the District administrative assistant is responsible for updating student eligibility records based on verification of income eligibility. There is no review or verification by someone other than the preparer that the appropriate steps are being followed or completed. 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 cash management (reimbursement requests) and verification of eligibility (special tests and provisions), it was noted that there were no controls in place to review that procedures were performed as required and that there was a review over the work to prevent error or fraud. Cause: With the limited staffing at the District, there is one person that was dedicated for each area and the review has not been put in place. 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.

2021-006 Child Nutrition Segregation of Duties Assistance Listing No. 10.555 and 10.559 Recommendation: CLA recommends that the District implement a review process over the cash management and verification requirements related to the Child Nutrition Cluster during the fiscal year. Explanation of disagreement with audit finding: District does not have any disagreement with the audit finding. Action planned/taken in response to finding: This was an issue because everyone was considered free through the SFSP for the 2020-21 school year. Our verification party didn?t realize this still needed to be processed. We have followed up to make sure it is completed now during 2021-2022. Name(s) of the contact person(s) responsible for corrective action: Todd Felhofer 715-267-6101. Planned completion date for corrective action plan: Ongoing.