Southeastern Wisconsin Regional Planning Commission

Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Planning and Construction Assistance Listing Number: 20.205 Federal Award Identification Number and Year: 395-0096-25-21 & 395-0096-25-22 – Year Ended December 31, 2025 Award Period: January 1, 2025 – December 31, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: § 200.318 “General procurement standards” states that recipients or subrecipients must maintain and use documented procedures for procurement transactions under a federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in §§ 200.317 through 200.327. The recipient or subrecipient must also maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award, and administration of contracts. Condition: The Commission had not established written procurement or conflict of interest policies. Questioned costs: None Context: Although the Commission followed procurement, suspension and debarment processes to verify vendors met compliance requirements, no documented process or policies were maintained by the Commission. Cause: The lack of written policy and internal control structure does not include a process for ensuring procurement, suspension and debarment requirements are met for all required vendors. Effect: The Commission may contract with or make subawards under covered transactions that do not follow proper procurement processes or to parties that are suspended or debarred. Repeat Finding: No Recommendation: We recommend that the Commission update their current procurement and conflict of interest policies and implement a system of internal controls over procurement, suspension and debarment that will ensure compliance. Views of responsible officials: Management agrees with the finding.

Action taken in response to finding: The Commission is in the process of adopting an updated procurement and conflict of interest policy to comply with compliance requirements.

Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Planning and Construction Cluster Assistance Listing Number: 20.205 Federal Award Identification Number and Year: 395-0096-22-21 / 395-0096-22-22 -Year Ended December 31, 2023 Award Period: January 1, 2023 – December 31, 2023 - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or specific requirement: Section 200.303, Internal Controls, states that the Commission shall “establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: The Commission had not established a policy or an effective internal control system related to the grant agreement and the Procurement, Suspension, and Debarment compliance requirement. The Commission’s current procurement policy does not include a documented process to ensure vendors meet suspension and debarment requirements. In addition, there was no documentation that the Commission had timely verified that the Commission’s vendors were not suspended or debarred. Questioned costs: None Context: Procurement policies were followed, but no documented process to ensure suspension and debarment compliance was noted. Cause: The current policy and internal control structure does not include a process for ensuring suspension and debarment requirements are met for all required vendors. Effect: The Commission may contract with or make subawards under covered transactions to parties that are suspended or debarred. Repeat Finding: No Recommendation: We recommend that the Commission update their current procurement policy and implement a system of internal controls over suspension and debarment that will ensure compliance. Views of responsible officials: Management agrees with the finding.

Highway Planning and Construction Cluster: Assistance Listing No. 20.205 Recommendation: We recommend that the Commission update their current procurement policy and implement a system of internal controls over suspension and debarment that will ensure compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Commission has taken corrective action to ensure review of suspension and debarment is documented in accordance with updated procurement policies. Name of the contact person responsible for corrective action: Elizabeth Larsen, SHRM-SCP, SPHR, Director of Administration Planned completion date for corrective action plan: December 31, 2024