Chapter PI 49

PI 49.07(3)(c) (c) Complete a fraud risk assessment.

PI 49.07(3)(d) (d) If the school uses a student information system, complete testing of the enrollment software using one of the following:

PI 49.07(3)(d)1. 1. The department’s pupil enrollment software test plan.

PI 49.07(3)(d)2. 2. A pupil enrollment software test plan developed by the auditor. The auditor shall annually submit the plan to the department for approval. The auditor shall not use the test plan until it is approved by the department.

PI 49.07(3)(f) (f) Verify that the total number of pupils attending the school on the official attendance records match the total number of pupils based on the pupil count report under s. PI 49.06 (5) (b) for each grade category.

PI 49.07(3)(g) (g) Verify the enrollment for all special needs scholarship program pupils reported on the pupil count report under s. PI 49.06 (5) (b) using the school’s official attendance records.

PI 49.07(3)(i) (i) Verify that the special needs scholarship program pupils meet the requirements of s. PI 49.06 (6).

PI 49.07(3)(j) (j) Verify that the school did not receive a payment under s. 115.7915 (4m), Stats., for any of the following:

PI 49.07(3)(j)1. 1. Pupils for whom the school is receiving a childcare payment for all day care.

PI 49.07(3)(j)2. 2. Pupils who are enrolled in a public school district.

PI 49.07(3)(j)3. 3. Pupils participating in a program under s. 118.60 or 119.23, Stats.

PI 49.07(3)(k) (k) Select a sample of at least 60 pupils not participating in the special needs scholarship program from original classroom records and verify the school included the selected pupils in the official attendance records. The sample shall include pupils from each classroom. If the pupils are in different classrooms during the day, the auditor may select one period and select pupils from each classroom for that period. If the auditor identifies an auditing exception, the auditor shall increase the sample size in increments of 60 pupils until the auditor finds no additional exceptions or until the auditor verifies that all pupils have been properly included in reported enrollments. If the school has an enrollment of fewer than 60 pupils who did not participate in the special needs scholarship program, the auditor shall examine records for all pupils who did not participate in the special needs scholarship program.

PI 49.07(3)(L) (L) Reconcile the enrollment the school reported to the department under s. 115.30 (3), Stats., with the official attendance records of the school.

PI 49.07(3)(m) (m) Verify that any application that has not been counted on a previous count date under s. PI 49.06 (5) (b) meets the requirements of s. PI 49.05 and s. 115.7915 (2), Stats. If the auditor identifies that an application is missing the information required under s. PI 49.05 (4) (a) 2., the school may correct the application if the applicant provides the missing documentation. The missing documentation shall be provided by the due date of the enrollment audit specified under sub. (1) in which the application is required to be reviewed under this subsection. If the missing documentation is not provided by the required date, the application shall be determined ineligible.

PI 49.07(3)(n) (n) If a pupil participated in the special needs scholarship program in the previous year, the auditor shall verify that the residency documentation obtained pursuant to s. PI 49.06 (5) (c) meets the requirements of that paragraph.

PI 49.07(3)(o) (o) Verify that any pupils in 4-year-old kindergarten, 5-year-old kindergarten, or first grade meet the age requirements in s. 118.14 (1), Stats.

PI 49.07(3)(p) (p) Verify that the school complied with the requirements under s. PI 49.03 (4).

PI 49.07(3)(q) (q) Perform other auditing procedures as agreed upon by the auditor and the department.

PI 49.07(3)(r) (r) Verify that any reevaluations required under s. 115.7915 (2) (h), Stats., have been completed and that the school properly identified partial scholarship pupils on the pupil count report under s. PI 49.06 (5) (b) 3.

PI 49.07(3)(s) (s) Verify that the school has a written agreement with each parent specifying the services that will be provided to each special needs scholarship program pupil. The auditor shall ensure the school and the parent entered into the agreement by the count date.

PI 49.07(3)(t) (t) Verify that any transfer request that has not been counted on a previous count date under s. PI 49.06 (5) (b), meets the requirements of s. PI 49.05. If the auditor identifies that a transfer request is missing the information required under s. PI 49.05 (5) (b) 2. or 3., the school may correct the transfer request if the applicant provides the missing documentation. The missing documentation shall be provided by the due date of the enrollment audit specified under sub. (1) in which the transfer request is required to be reviewed under this subsection. If the missing documentation is not provided by the required date, the transfer request shall be determined ineligible.

PI 49.07(3)(u) (u) If the school operated a summer school program, review all school documentation to support the summer school report the school filed with the department under s. PI 49.16 (5). The review shall be part of the third Friday in September enrollment audit.

PI 49.07(4) (4) Certifications.

PI 49.07(4)(a) (a) Upon review of the enrollment audits, the department shall certify an amount due from a school or an amount due to the school. The certifications shall include any adjustments identified in the financial audits submitted under ss. PI 49.08 and 49.09 to the costs for a pupil or government assistance revenue received for educational programming for a pupil in the reports submitted under s. PI 49.13 (7). If, based on the financial audit, the payment amount calculated under s. 115.7915 (4m) (cm), Stats., for a pupil in a report submitted under s. PI 49.13 (7) is less than the payment amount calculated under s. 115.7915 (4m) (a) 2. b., Stats., the payment for the pupil shall be calculated as specified under s. 115.7915 (4m) (a) 2. b., Stats. If a school fails to file an enrollment audit with the department, the department may determine that all special needs scholarship program pupils are ineligible.

PI 49.07(4)(b) (b) A school shall refund to the department the amount certified as due to the department as specified under s. PI 49.13 (6).

PI 49.07(4)(c) (c) The department shall pay any additional amount due to a school for eligible pupils within 60 days of the date of the certification letter.

PI 49.07 Note Note: The enrollment audit form and department’s pupil enrollment software test plan may be obtained at no charge from the Wisconsin department of public instruction’s webpage at http://dpi.wi.gov/sms/special-needs-scholarship.

PI 49.07 History History: EmR1619: emerg. cr., eff. 6-2-16; CR 16-005: cr., Register October 2016 No. 730, eff. 11-1-16; correction in (3) (p) made under s. 35.17, Stats., Register October 2016 No. 730; EmR1630: emerg. cr. (3) (r) to (t), am. (4) (b) 1., eff. 11-1-16; CR 16-066: cr. (3) (r) to (t), am. (4) (b) 1. Register April 2017 No. 736, eff. 5-1-17; EmR1815: emerg. am. (1) (intro.), (a), (2), (3) (a), r. (3) (e), am. (3) (f), r. (3) (h), am. (3) (k), (m), (p), (t), cr. (3) (u), renum. (4) (b) (intro.) to (4) (b) and am., r. (4) (b) 1., 2., eff 7-1-18; EmR1911: emerg. am. (1) (intro.), (a), (b), (2), (3) (a), r. (3) (e), am. (3) (f), r. (3) (h), am. (3) (j) 3., (k), (m), (p), (t), cr. (3) (u), am. (4) (a), renum. (4) (b) (intro.) to (4) (b) and am., r. (4) (b) 1., 2., eff. 7-1-19; CR 19-095: am. (1) (intro.), (a), (b), (2), (3) (a), r. (3) (e), am. (3) (f), r. (3) (h), am. (3) (j) 3., (k), (m), (p), (t), cr. (3) (u), am. (4) (a), renum. (4) (b) (intro.) to (4) (b) and am., r. (4) (b) 1., 2. Register March 2020 No. 771, eff. 4-1-20; EmR2117: emerg. am. (4) (a), eff. 6-12-21; CR 21-046: am. (4) (a) Register February 2022 No. 794, eff. 3-1-22.

PI 49.08 PI 49.08 Financial audit.

PI 49.08(1) (1) Financial audit requirements. Annually by October 15, a school shall submit a financial audit and financial audit supplemental schedule to the department. The financial audit shall comply with all of the following:

PI 49.08(1)(a) (a) The financial audit shall either include the school-only balances and activity or shall be prepared at the consolidated level as permitted by generally accepted accounting principles.

PI 49.08(1)(b) (b) A school may submit a financial audit that includes a modified audit opinion due to fixed assets purchased in previous years not being included in the financial audit.

PI 49.08(1)(c) (c) The school shall have support for the original purchase price for the fixed assets and evidence that the school paid for the fixed asset purchases in order for the depreciation expense to be an eligible education expense. If any fixed assets are included in the statement of financial position that do not meet these requirements, the financial audit shall include a footnote disclosure that includes the fixed asset amount, accumulated depreciation, and current year depreciation expense for the fixed assets that do not meet the requirements to be included as an eligible education expense.

PI 49.08(1)(d) (d) Except as provided under par. (b) and sub. (4) (b), a financial audit that includes a modified audit opinion does not meet the requirements under s. 115.7915 (6) (e), Stats., and this chapter unless the modification is approved by the department.

PI 49.08(2) (2) Compliance with American Institute of Certified Public Accountants requirements. An auditor engaged by a school to provide the audit opinion in this section shall comply with the auditing standards established by the American Institute of Certified Public Accountants, including all of the following:

PI 49.08(2)(a) (a) The auditor shall develop written audit programs identifying the steps and procedures to be followed in conducting the audit, including establishing the planning materiality that the auditor will use for the audit.

PI 49.08(2)(b) (b) The auditor shall trace all entries on the financial audit and financial audit supplemental schedule to the trial balance provided by the school.

PI 49.08(2)(c) (c) The auditor shall obtain sufficient appropriate audit evidence to conclude that the financial statements do not contain misstatements the effect of which, when aggregated with misstatements in other accounts and transactions, exceeds the planning materiality and results in a material misstatement in the financial statements or in the school’s net eligible education expenses. The auditor shall determine sufficient appropriate audit evidence based on the requirements of the American Institute of Certified Public Accountants.

PI 49.08(3) (3) Standard financial audit.

PI 49.08(3)(a) (a) The standard financial audit shall be prepared in accordance with generally accepted accounting principles.

PI 49.08(3)(b) (b) Except as provided under par. (c), the standard financial audit shall include 2-year comparative financial statements containing all of the statements required by generally accepted accounting principles, including a statement of financial position, a statement of activities, and a statement of cash flows. Both years of the financial statements shall be audited.

PI 49.08(3)(c) (c) The first year a school completes a standard financial audit for the special needs scholarship program, the statement of activities and statement of cash flows may only include the current school year.

PI 49.08(4) (4) Modified financial audit.

PI 49.08(4)(a) (a) The modified financial audit shall include an audited one-year statement of financial position prepared as required by generally accepted accounting principles.

PI 49.08(4)(b) (b) A school may submit a modified financial audit that includes a modified audit opinion due to post-retirement benefits being excluded from the statement of financial position.

PI 49.08(5) (5) Management letter. The management letter required under s. 115.7915 (6) (e), Stats., shall include all of the following if issued by the auditor:

PI 49.08(5)(a) (a) Any letter issued under the American Institute of Certified Public Accountants Statement on Auditing Standards 114.

PI 49.08(5)(b) (b) Any letter issued under the American Institute of Certified Public Accountants Statement on Auditing Standards 115.

PI 49.08(5)(c) (c) Any other letter to management communicating significant deficiencies or material weaknesses in the internal controls.

PI 49.08 History History: EmR1619: emerg. cr., eff. 6-2-16; CR 16-005: cr., Register October 2016 No. 730, eff. 11-1-16; EmR1815: emerg. r. and recr. (1), cr. (3) to (5), eff 7-1-18; EmR1911: emerg. r. and recr. (1), cr. (3) to (5), eff. 7-1-19; CR 19-095: r. and recr. (1), cr. (3) to (5) Register March 2020 No. 771, eff. 4-1-20.

PI 49.09 PI 49.09 Financial audit supplemental schedule.

PI 49.09(1) (1) Eligible education expenses. The eligible education expenses included in the financial audit supplemental schedule shall comply with all of the following:

PI 49.09(1)(a) (a) Eligible education expenses may only include those expenses that already have or will result in a cash disbursement.

PI 49.09(1)(b) (b) Eligible education expenses may only include the following:

PI 49.09(1)(b)1. 1. In a standard financial audit, expenses that are in the statement of activities, except for the cost of land. The amount that the school paid for land shall be included in the first year the land is used for educational programming using an allocation method under par. (d), if applicable.

PI 49.09(1)(b)2. 2. In a modified financial audit, expenses that would be included in the statement of activities for the school year based on generally accepted accounting principles except for the following:

PI 49.09(1)(b)2.a. a. The amount that the school paid for land shall be included in the first year the land is used for educational programming using an allocation method under par. (d), if applicable.

PI 49.09(1)(b)2.b. b. Post-retirement benefits may be included as an eligible education expense based on the amount expended for the post-retirement benefits in the school year.

PI 49.09(1)(c) (c) An expense may only be included as an eligible education expense one time.

PI 49.09(1)(d) (d) If an expense or government assistance revenue is partially related to educational programming, the school shall use an allocation method to determine the portion that is related to educational programming.

PI 49.09(1)(e) (e) The following may not be included in kindergarten through grade 12 eligible education expenses:

PI 49.09(1)(e)1. 1. Contributed services, fixed assets or goods.

PI 49.09(1)(e)2. 2. Scholarship awards and financial support for pupils to attend the private school, including payments to parents or others on behalf of pupils.

PI 49.09(1)(e)3. 3. Daycare expenses except expenses for before or after school care for kindergarten through grade 12 pupils that are enrolled in educational programming at the school.

PI 49.09(1)(e)4. 4. Expenses for pupils who are enrolled in the public school district and attending the private school.

PI 49.09(2) (2) Auditor review of eligible education expenses. An auditor shall ensure the eligible education expenses a school included in the supplemental schedule comply with the requirements under sub. (1) and s. PI 49.08 (1) (c).

PI 49.09(3) (3) Supplemental schedule calculations. The supplemental schedule shall calculate all of the following:

PI 49.09(3)(a) (a) Net eligible education expenses incurred primarily for special needs scholarship program pupils as follows:

PI 49.09(3)(a)1. 1. Determine the amount of primarily special needs scholarship program expenses. The amount included as an eligible education expense shall be determined using an allocation method specifically related to the expense being allocated. This amount may not include costs included as eligible in any statements provided under s. PI 49.13 (7).

PI 49.09(3)(a)2. 2. Subtract all government assistance revenues received for primarily special needs scholarship program expenses.

PI 49.09(3)(a)3. 3. Subtract the lesser of the following:

PI 49.09(3)(a)3.a. a. Fundraising revenue.

PI 49.09(3)(a)3.b. b. The non-administrative fundraising expenses included in the expenses in subd. 1. In this subdivision, administrative expenses include expenses for school personnel, copying, mailing, or fixed assets used for other school purposes.

PI 49.09(3)(a)4. 4. Subtract all insurance proceeds received for primarily special needs scholarship program expenses.

PI 49.09(3)(b) (b) Net eligible education expenses for all pupils as follows:

PI 49.09(3)(b)1. 1. Determine the amount of eligible education expenses, excluding eligible education expenses in par. (a) and costs included as eligible in any statements provided under s. PI 49.13 (7) incurred in that school year. If an expense is included under par. (a) that is not 100 percent related to special needs scholarship program pupils, the total expense prior to applying the allocation percentage shall be excluded under this subdivision.

PI 49.09(3)(b)2. 2. Subtract all government assistance revenues received for eligible education expenses. This amount shall not include government assistance revenues subtracted in par. (a) 2. or in the statements provided under s. PI 49.13 (7).

PI 49.09(3)(b)3. 3. Subtract the lesser of the following:

PI 49.09(3)(b)3.a. a. Fundraising revenue.

PI 49.09(3)(b)3.b. b. The non-administrative fundraising expenses included in the expenses in subd. 1. In this subdivision, administrative expenses include expenses for school personnel, copying, mailing, or fixed assets used for other school purposes.

PI 49.09(3)(b)4. 4. Subtract all insurance proceeds received for eligible education expenses, excluding eligible education expenses in par. (a).

PI 49.09(3)(c) (c) The net eligible education expenses for special needs scholarship program pupils as follows:

PI 49.09(3)(c)1. 1. Calculate the percentage of pupils at the school participating in the special needs scholarship program as the full-time equivalent for the special needs scholarship program pupils compared to the all pupil full-time equivalent. The full-time equivalents shall be based on the average of the full-time equivalents determined in the enrollment audits under s. PI 49.07. The full-time equivalent for the special needs scholarship program pupils shall exclude pupils that received a payment under s. PI 49.13 (7) in that school year.

PI 49.09(3)(c)2. 2. Multiply the amount calculated under par. (b) by the percentage under subd. 1.

PI 49.09(3)(c)3. 3. Add the net eligible education expenses under par. (a) and costs included as eligible in any statements provided under s. PI 49.13 (7) incurred in that school year.

PI 49.09(3)(c)4. 4. Subtract government assistance revenue related to that school year that is subtracted in the statements provided under s. PI 49.13 (7).

PI 49.09(3)(d) (d) The reserve balance as follows:

PI 49.09(3)(d)1. 1. Determine the total scholarships received for the school year being audited and any adjustments for the school year under s. PI 49.07 (4). This amount shall include summer school revenue received under s. 115.7915 (4p), Stats., for the immediately preceding summer.

PI 49.09(3)(d)2. 2. Add the prior year reserve balance, if any.