Chapter PI 49

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.

PI 49.09(3)(d)3. 3. Subtract the amount determined under par. (c).

PI 49.09(3)(e) (e) The school’s cash and investment balance that must be maintained under sub. (4) as follows:

PI 49.09(3)(e)1. 1. Determine the sum of any remaining depreciation on fixed assets used by the school and any land purchases that have not yet been included in eligible cost under sub. (1) (b) that meet the requirements to be included as an eligible education expense. The depreciation under this subdivision shall not include depreciation for leased right of use assets.

PI 49.09(3)(e)2. 2. Subtract the amount under subd. 1. from the amount under par. (d).

PI 49.09(3m) (3m) Paycheck Protection Program loans. Notwithstanding sub. (3) (a) 2., (b) 2., and (c) 4., the forgiven portion of Paycheck Protection Program loans administered by the U.S. small business administration under 15 USC 636 may not be included as offsetting government assistance revenue in the supplemental schedule.

PI 49.09(4) (4) Maintain reserve balance. The school shall maintain the reserve balance, if positive, for future eligible education expenses for special needs scholarship program pupils. The school’s cash and investment balance shall be at least as much as the amount calculated under sub. (3) (e), if positive. If the school is participating in a program under s. 118.60 or 119.23, Stats., the cash and investment balance shall be at least as much as the reserve calculated under this chapter and chs. PI 35 and 48 less the sum of any remaining depreciation on fixed assets used by the school and any land purchases that have not yet been included in eligible cost under sub. (1) (b) that meet the requirements to be included as an eligible education expense. The depreciation under this subsection shall not include depreciation for leased right of use assets.

PI 49.09(5) (5) Financial audit submission.

PI 49.09(5)(a) (a) If a school ceases to participate or is barred from participation in the special needs scholarship program under s. 115.7915, Stats., it shall submit to the department the financial audit for the final school year in which it participated. The net eligible education expenses under sub. (3) (c) shall be multiplied by the percent of the school year the school participated in the special needs scholarship program if the school was not eligible for all of the payments under s. PI 49.13. This percentage shall be calculated as follows:

PI 49.09(5)(a)1. 1. The net eligible education expenses shall be multiplied by 25 percent if the school was only eligible for the September payment.

PI 49.09(5)(a)2. 2. The net eligible education expenses shall be multiplied by 50 percent if the school was only eligible for the September and November payments.

PI 49.09(5)(a)3. 3. The net eligible education expenses shall be multiplied by 75 percent if the school was only eligible for the September, November, and February payments.

PI 49.09(5)(b) (b) If a school fails to submit the financial audit, the school’s net eligible education expenses for the year shall be determined to be zero for purposes of determining the school’s reserve balance.

PI 49.09(6) (6) Refund of the reserve. If a school ceases to participate or is barred from participating in the special needs scholarship program under s. 115.7915, Stats., and the school’s reserve is positive, the school shall refund the reserve balance to the department as specified under s. PI 49.13 (6).

PI 49.09 History History: EmR1619: emerg. cr., eff. 6-2-16; CR 16-005: cr., Register October 2016 No. 730, eff. 11-1-16; correction in (4) made under s. 35.17, Stats., Register October 2016 No. 730; EmR1630: emerg. renum. (3) (a) 3. to (3) (a) 3. (intro.) and am., cr. (3) (a) 3. a., b., renum. (3) (b) 3. to (3) (b) 3. (intro.) and am., cr. (3) (b) 3. a., b., am. (5) (title), renum. (5) to (5) (a), (b), eff. 11-1-16; CR 16-066: renum. (3) (a) 3. to (3) (a) 3. (intro.) and am., cr. (3) (a) 3. a., b., renum. (3) (b) 3. to (3) (b) 3. (intro.) and am., cr. (3) (b) 3. a., b., am. (5) (title), renum. (5) to (5) (a), (b) Register April 2017 No. 736, eff. 5-1-17; EmR1815: emerg. am. (1) (e) 1., (3) (d) 1., (e) 1., (4), eff 7-1-18; EmR1911: emerg. renum. (1) (b) to (1) (b) (intro.) and am., cr. (1) (b) 2., am. (1) (e) 1., (2), (3) (a) (intro.), 1., 2., 3. b., 4., (b) 1., 2., 3. b., (c) 1., 3., cr. (3) (c) 4., am. (3) (d) 1., (e) 1., (4), renum. (5) (a) to (5) (a) (intro.) and am., cr. (5) (a) 1. to 3., am. (6), eff. 7-1-19; CR 19-095: renum. (1) (b) to (1) (b) (intro.) and am., cr. (1) (b) 2., am. (1) (e) 1., (2), (3) (a) (intro.), 1., 2., 3. b., 4., (b) 1., 2., 3. b., (c) 1., 3., cr. (3) (c) 4., am. (3) (d) 1., (e) 1., (4), renum. (5) (a) to (5) (a) (intro.) and am., cr. (5) (a) 1. to 3., am. (6) Register March 2020 No. 771, eff. 4-1-20; EmR2117: emerg. cr. (3m), eff. 6-12-21; CR 21-046: cr. (3m) Register February 2022 No. 794, eff. 3-1-22.

PI 49.10 PI 49.10 School financial requirements.

PI 49.10(1) (1) Engagement letter. A school shall have a written engagement letter with each auditor providing services required by this chapter. The school or auditor shall provide a copy of the engagement letter to the department upon request. The written engagement letter shall contain all of the following:

PI 49.10(1)(a) (a) A statement that the auditor shall comply with generally accepted auditing standards and the requirements of this chapter.

PI 49.10(1)(b) (b) A statement that the auditor shall comply with generally accepted governmental auditing standards if other governmental agencies providing funds to the school so require.

PI 49.10(1)(c) (c) The responsibilities of the school and the auditor in meeting the requirements of this chapter.

PI 49.10(1)(d) (d) The services the auditor provides to the school that are in addition to those audit and attestation services required under this chapter.

PI 49.10(1)(e) (e) The auditor’s acknowledgement that the department will rely on the auditor’s work to fulfill the department’s responsibilities under s. 115.7915, Stats., and this chapter.

PI 49.10(1)(f) (f) The auditor’s compensation for the services the auditor provides to the school.

PI 49.10(2) (2) Financial accounting system. A school shall use a double entry financial accounting system organized in a manner that enables preparation of the financial audit and financial audit supplemental schedule. A school shall balance the financial accounting system and provide the auditor with a trial balance of the account balances.

PI 49.10(3) (3) Adjusting entries. Adjustments to the school’s trial balance recommended by a school’s auditor shall be approved by the school before the entries are recorded in the school’s financial accounting system.

PI 49.10(4) (4) Records retention. A school shall retain all financial and pupil records relating to the enrollment audits under s. PI 49.07 and the audit required under ss. PI 49.08 and PI 49.09 for at least 5 years from the due date of the financial audit for each school year, unless the department or a law enforcement agency requests that the school retain the records for more than 5 years.

PI 49.10(5) (5) Records availability. A school shall furnish all financial and pupil records the auditor considers necessary to provide the audit opinion or agreed upon procedure reports. Upon request by the department, a school shall provide the department access and copies to the records referenced in the auditor’s working papers.

PI 49.10(6) (6) School responsibility. An auditor’s failure to completely or properly perform the responsibilities set forth in s. 115.7915, Stats., or this chapter is not a defense to any determination the department makes under this chapter or s. 115.7915, Stats.

PI 49.10(7) (7) Auditor bar. A school participating in the special needs scholarship program may not engage an auditor who the department bars under s. PI 35.12 (7), PI 48.12 (7), or PI 49.11 (7) until such time as the auditor provides evidence acceptable to the department that the auditor has made procedural changes and has successfully completed professional development training that enables the auditor to comply with the requirements of this chapter, chs. PI 35 and 48, and ss. 115.7915, 118.60, and 119.23, Stats.

PI 49.10 History History: EmR1619: emerg. cr., eff. 6-2-16; CR 16-005: cr., Register October 2016 No. 730, eff. 11-1-16; correction in (7) made under s. 35.17, Stats., Register October 2016 No. 730; EmR1815: emerg. am. (6), eff 7-1-18; EmR1911: emerg. am. (6), eff. 7-1-19; CR 19-095: am. (6) Register March 2020 No. 771, eff. 4-1-20.

PI 49.11 PI 49.11 Auditor requirements.

PI 49.11(1) (1) Independence requirements. An auditor engaged by a school to meet the requirements under this chapter and s. 115.7915, Stats., shall comply with the standards of the American Institute of Certified Public Accountants, including all of following:

PI 49.11(1)(a) (a) An auditor shall comply with the requirements of s. Accy 1.101.

PI 49.11(1)(b) (b) An auditor shall obtain the school’s trial balance if completing compilation or review services.

PI 49.11(1)(c) (c) Except as provided in par. (d), an auditor may not post or prepare for posting typical reoccurring financial transactions to the school’s general ledger, including cash receipts and disbursements, invoices or billings for services, billings from vendors and suppliers, and payroll activity.

PI 49.11(1)(d) (d) An auditor shall obtain written approval of the school’s management prior to posting adjusting, correcting, and closing journal entries to the school’s general ledger. An auditor’s working papers shall document evidence of management approval for all such entries resulting from a financial statement compilation, review, or audit.