Gibraltar Area School DistrictLocal Government

2024-004 Procurement Federal Agency: U.S. Department of Education Federal Program Names: Special Education Cluster (IDEA) Assistance Listing Numbers: 84.027, 84.173 Federal Award Year: 2023-2024 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-152114-DPI-FLOW-341, 2024-152114-DPI-PRESCH-347 Type of Finding Material weakness in internal control over compliance, Other Matters Criteria or Specific Requirement 2 CFR 200.320 Methods of Procurement state that if noncompetitive procurement method is used, single source documentation must be maintained. Condition During our testing of procurement transactions of the program we noted that 2 of 2 vendors selected were not supported by single source noncompetitive procurement documentation to support that the District is prudent with the monies used towards the program. Questioned Costs None. Context The District's procurement documentation did not conform to Uniform Guidance for 2 of 2 vendors tested in our sample. Cause The District did not properly document the method being used. Effect The District is not in compliance with procurement documentation requirements. Vendors may be paid with federal funds with no supporting documentation maintained for the procurement method used. Repeat Finding - No Recommendation We recommend the District review procurement policies and establish a procurement documentation process in order to ensure this policy is being followed. Views of Responsible Officials There is no disagreement with this finding.

2024-005 Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Names: Special Education Cluster (IDEA) Assistance Listing Numbers: 84.027, 84.173 Federal Award Year: 2023-2024 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-152114-DPI-FLOW-341, 2024-152114-DPI-PRESCH-347 Type of Finding Significant Deficiency in internal control over compliance Criteria or Specific Requirement 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 could not provide proof of verification of the suspension and debarment status of vendors before entering into services with them. Questioned Costs None. Context The District did not document their review 1 of 1 vendors tested in our sample to document they were not suspended or debarred when initiating covered transactions in the current year. Cause The District does not have a policy or procedure in place to document if a vendor is debarred or suspended. Effect The District could contract with a vendor that has been suspended or debarred from receiving federal funds. Repeat Finding – No Section III – Federal Award Findings and Questioned Costs (Continued) 2024-005 (Continued) Recommendation We recommend the District establish procedures that are in accordance with Uniform Guidance to document their verification that the vendor is not suspended or debarred at the beginning of the year or before entering into a contract. Views of Responsible Officials There is no disagreement with this finding.