Audit 295550

FY End
2022-06-30
Total Expended
$2.64M
Findings
6
Programs
9
Year: 2022 Accepted: 2024-03-18

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
380867 2022-001 Material Weakness - P
380868 2022-002 Material Weakness - P
380869 2022-003 Significant Deficiency Yes P
957309 2022-001 Material Weakness - P
957310 2022-002 Material Weakness - P
957311 2022-003 Significant Deficiency Yes P

Contacts

Name Title Type
G4X6GJF8HCE5 Sarah Hickey Auditee
7815852994 Grady Connor Auditor
No contacts on file

Notes to SEFA

Title: Basis of Presentation Accounting Policies: Accounting policies and financial reporting practices permitted for municipalities in Massachusetts are prescribed by the Uniform Municipal Accounting System (UMAS) promulgated by the Commonwealth of Massachusetts Department of Revenue. Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The information included in the Schedule may not fully agree with other federal award reports the District submits to federal awarding or pass-through entities. De Minimis Rate Used: N Rate Explanation: The District has not elected to use the 10% de minimus indirect cost rate allowed under the Uniform Guidance The Silver Lake Regional School District (the District) is a governmental agency established by the laws of the Commonwealth of Massachusetts, for the purposes of providing public education for middle school through high school. It is comprised of its member towns of the Town of Halifax, Town of Kingston, and Town of Plympton. The District’s administrative structure (superintendent and business office) also serve the member town’s elementary schools through a formalized arrangement. All operations related to the District's federal grant programs are included in the scope of the OMB Uniform Guidance. The U.S. Department of Education has been designated as the District’s oversight agency for purposes of the audit. The accompanying schedule of expenditures of federal awards (the "Schedule") includes the federal award activity of the Silver Lake Regional School District for the year ended June 30, 2022. The information in the Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations (CFR), Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the Silver Lake Regional School District it is not intended to and does not present the financial position, or changes in the financial position of the District.
Title: Summary of Significant Accounting Policies Accounting Policies: Accounting policies and financial reporting practices permitted for municipalities in Massachusetts are prescribed by the Uniform Municipal Accounting System (UMAS) promulgated by the Commonwealth of Massachusetts Department of Revenue. Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The information included in the Schedule may not fully agree with other federal award reports the District submits to federal awarding or pass-through entities. De Minimis Rate Used: N Rate Explanation: The District has not elected to use the 10% de minimus indirect cost rate allowed under the Uniform Guidance Accounting policies and financial reporting practices permitted for municipalities in Massachusetts are prescribed by the Uniform Municipal Accounting System (UMAS) promulgated by the Commonwealth of Massachusetts Department of Revenue. Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The information included in the Schedule may not fully agree with other federal award reports the District submits to federal awarding or pass-through entities.
Title: Cash and Non-cash Assistance - Child Nutrition Cluster Accounting Policies: Accounting policies and financial reporting practices permitted for municipalities in Massachusetts are prescribed by the Uniform Municipal Accounting System (UMAS) promulgated by the Commonwealth of Massachusetts Department of Revenue. Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The information included in the Schedule may not fully agree with other federal award reports the District submits to federal awarding or pass-through entities. De Minimis Rate Used: N Rate Explanation: The District has not elected to use the 10% de minimus indirect cost rate allowed under the Uniform Guidance The following define the cash and non-cash assistance provided by the U.S. Department of Agriculture's Child Nutrition cluster - National School Lunch Program (CFDA#10.555). Cash assistance - expenditures represent federal reimbursement for meals during the year. Non-cash assistance - represent food commodities received under a state distribution formula and are valued at federally published wholesale prices for purposes of this schedule. Such commodities are not recorded in the financial records, although memorandum records are maintained.
Title: Subrecipient pass-through awards Accounting Policies: Accounting policies and financial reporting practices permitted for municipalities in Massachusetts are prescribed by the Uniform Municipal Accounting System (UMAS) promulgated by the Commonwealth of Massachusetts Department of Revenue. Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The information included in the Schedule may not fully agree with other federal award reports the District submits to federal awarding or pass-through entities. De Minimis Rate Used: N Rate Explanation: The District has not elected to use the 10% de minimus indirect cost rate allowed under the Uniform Guidance The Silver Lake Regional School District is awarded and administers certain award programs, which are also provide certain services to the member town’s elementary schools through the approved awards. Oversight monitoring and administration of these amounts are performed directly by District administration. The amounts reimbursed to the member towns for services provided under these awards have been reported in the federal expenses of each program in the accompanying schedule of expenditures of federal awards. Amounts passed through to the member towns have been aggregated in the accompanying schedule. The amounts to each member town have been detailed in the table below. See Notes to the Schedule.

Finding Details

Material Weakness:2022-001 - Establishment of procedures to provide for timely reconciliation, close-out, and reporting of financial activity Criteria: The District should have internal control policies and procedures surrounding the administration and monitoring of financial activity of the District on a routine, timely basis. Properly designed and implemented internal controls should ensure that account balances (cash, withholdings, other) and activity associated with revolving accounts are formally reconciled and monitored on a routine basis. Condition:The District did not perform timely reconciliation and close-out of fiscal activity throughout fiscal year 2022. It should be noted the District did not close-out financial records for the fiscal year end June 30, 2022, until May 2023. During the fiscal year certain financial aid was also withheld from the Commonwealth pending additional reporting submissions. Additionally, as we have recommended in prior years, procedures surrounding the reconciliation of withholding accounts and disposition of identified variances has not yet been fully implemented. Potential Effect: Lack of timely reconciliations, reporting and monitoring of financial activity presents the reasonable possibility that material misstatements of the District’s financial activity (error or otherwise) will not be prevented or detected and corrected in a timely manner. Cause: Based upon our discussion with District personnel, due in part to the pandemic, turnover in certain key positions (District accountant) and other personnel changes, the District has fallen behind in the overall close-out and timely reconciliation of financial activity. Additionally, it was indicated additional complexities associated with ever changing operating and regulatory environment of the District combined with staffing turnover increased delays in overall completion of work. Auditor’s recommendation: It is important for management and those charged with governance to design and implement internal controls surrounding financial reporting which ensure timely reconciliation, reporting, monitoring of financial activity. An effectively designed, implemented, and maintained internal control system (no matter the size of the organization) addresses certain key areas such as (a) reliability of the organization’s financial reporting, (b) the effectiveness and efficiency of its operations, and (c) its compliance with applicable laws and regulations. Considerations in evaluating the design and operations of internal control should be evaluated within the basic five components summarized as follows: control environment (tone of the organization/structure); risk assessment (identification, analysis and management of risks affecting financial reporting); information systems (procedures and records established to initiate, authorize, record and process transactions; resolve incorrect processing; account for overrides of systems or bypassing controls; ensure information is accumulated, recorded, processed, summarized, reported and maintained); control activities ( policies and procedures that assist in ensuring management directives are carried out); and monitoring (accessing the quality of internal control over time). In addition to adequacy of staffing levels. Additionally, cross-training of personnel can provide additional benefits in times of staffing turnovers. It is important that all risk assessments include formal documentation of evaluations and decisions made. Moreover, expected timelines, and reporting methodologies should be established which provide reasonable monitoring activities, which allow for prevention, detection and correction of errors and misstatements in a timely manner. It is important to note that current accounting and auditing standards continue to emphasis and require additional and more comprehensive and in-depth participation by the governing body in regard to the overall risk assessment and monitoring of financial activities of the organization.
Other Matters:2022-002 Completion and filing of the Single Audit in accordance with OMB guidelines. Criteria: OMB guidelines generally requires the District’s Single Audit to be completed and filed by March 31 of the following year (March 31, 2023). Condition:The District was unable to meet the filing deadline in the current year. Cause: The District was not closed out and timely with the audit. Effect: The District’s filing is considered late by OMB. Auditor’s Recommendation: We recommend the District work to meet the required filing deadline.
Significant Deficiency:2022-003 Recommend continued enhancement/monitoring of established policies and procedures surrounding grant compliance Criteria: Current Uniform Guidance highlights the importance and requirement for grantees to maintain internal control policies and procedures Surrounding the administration of federal grants, focusing clearly on internal controls over compliance with federal requirements for each major program. Condition: As noted in the prior year audit, the District has yet to fully update and review established policies and procedures surrounding risk assessments and grants management associated with the direct administration of federal grants (and others), focusing on clearly defining the key components (i.e., control environment, risk assessment, control activities, information and communication, monitoring). During the current year, we noted the following: Semi-annual time and effort certifications were all completed at the end of the fiscal year same as prior year). We noted a drawdown request associated with the ESSER III funds was performed in January of 2022; however, no expenditures were charged to the funds until August of the subsequent year (fiscal year 2023). We noted the documentation related to quotes obtained under District and state procurement guidelines were unclear/incomplete. See also the Financial Statement Finding 2022-001 reported in accordance with Government Auditing Standards. In our opinion this deficiency could have an impact upon the District’s major federal programs. Repeat Finding: This is a repeat finding from the prior year. Cause: Based upon our discussion with District personnel, due in part to the pandemic, turnover in certain key positions (District accountant) and other personnel changes, the District has fallen behind in the overall close-out and timely reconciliation of financial activity. Additionally, it was indicated additional complexities associated with ever changing operating and regulatory environment of the District combined with staffing turnover increased delays in overall completion of work. A review of the current grant manual, policies and procedures has not been updated. Potential Effect: Specific grant compliance requirements may not be complied with. Moreover, errors or fraud may occur which may not be prevented or detected in a timely manner. Auditor’s recommendation: In our profession opinion, as recommend in the previous year, it is important the District evaluate enhancements to address timely updating of established procedures to ensure the District’s compliance with grant and financial reporting requirements. This is additionally important with changes in District personnel. Management and those charged with governance to design and implement internal controls surrounding financial reporting which ensure timely reconciliation, reporting, monitoring of financial activity and grant compliance. Such policies and procedures should include centralized reporting and monitoring of grant requirements and compliance related thereto should be incorporated into established organizational internal control policies and procedures (inclusive of risk assessment). A routine assessment (annually) should be performed in accordance with updated grant and OMB guidance, to ensure the appropriate design and implementation related thereto. See also our recommendation above (2022-001).
Material Weakness:2022-001 - Establishment of procedures to provide for timely reconciliation, close-out, and reporting of financial activity Criteria: The District should have internal control policies and procedures surrounding the administration and monitoring of financial activity of the District on a routine, timely basis. Properly designed and implemented internal controls should ensure that account balances (cash, withholdings, other) and activity associated with revolving accounts are formally reconciled and monitored on a routine basis. Condition:The District did not perform timely reconciliation and close-out of fiscal activity throughout fiscal year 2022. It should be noted the District did not close-out financial records for the fiscal year end June 30, 2022, until May 2023. During the fiscal year certain financial aid was also withheld from the Commonwealth pending additional reporting submissions. Additionally, as we have recommended in prior years, procedures surrounding the reconciliation of withholding accounts and disposition of identified variances has not yet been fully implemented. Potential Effect: Lack of timely reconciliations, reporting and monitoring of financial activity presents the reasonable possibility that material misstatements of the District’s financial activity (error or otherwise) will not be prevented or detected and corrected in a timely manner. Cause: Based upon our discussion with District personnel, due in part to the pandemic, turnover in certain key positions (District accountant) and other personnel changes, the District has fallen behind in the overall close-out and timely reconciliation of financial activity. Additionally, it was indicated additional complexities associated with ever changing operating and regulatory environment of the District combined with staffing turnover increased delays in overall completion of work. Auditor’s recommendation: It is important for management and those charged with governance to design and implement internal controls surrounding financial reporting which ensure timely reconciliation, reporting, monitoring of financial activity. An effectively designed, implemented, and maintained internal control system (no matter the size of the organization) addresses certain key areas such as (a) reliability of the organization’s financial reporting, (b) the effectiveness and efficiency of its operations, and (c) its compliance with applicable laws and regulations. Considerations in evaluating the design and operations of internal control should be evaluated within the basic five components summarized as follows: control environment (tone of the organization/structure); risk assessment (identification, analysis and management of risks affecting financial reporting); information systems (procedures and records established to initiate, authorize, record and process transactions; resolve incorrect processing; account for overrides of systems or bypassing controls; ensure information is accumulated, recorded, processed, summarized, reported and maintained); control activities ( policies and procedures that assist in ensuring management directives are carried out); and monitoring (accessing the quality of internal control over time). In addition to adequacy of staffing levels. Additionally, cross-training of personnel can provide additional benefits in times of staffing turnovers. It is important that all risk assessments include formal documentation of evaluations and decisions made. Moreover, expected timelines, and reporting methodologies should be established which provide reasonable monitoring activities, which allow for prevention, detection and correction of errors and misstatements in a timely manner. It is important to note that current accounting and auditing standards continue to emphasis and require additional and more comprehensive and in-depth participation by the governing body in regard to the overall risk assessment and monitoring of financial activities of the organization.
Other Matters:2022-002 Completion and filing of the Single Audit in accordance with OMB guidelines. Criteria: OMB guidelines generally requires the District’s Single Audit to be completed and filed by March 31 of the following year (March 31, 2023). Condition:The District was unable to meet the filing deadline in the current year. Cause: The District was not closed out and timely with the audit. Effect: The District’s filing is considered late by OMB. Auditor’s Recommendation: We recommend the District work to meet the required filing deadline.
Significant Deficiency:2022-003 Recommend continued enhancement/monitoring of established policies and procedures surrounding grant compliance Criteria: Current Uniform Guidance highlights the importance and requirement for grantees to maintain internal control policies and procedures Surrounding the administration of federal grants, focusing clearly on internal controls over compliance with federal requirements for each major program. Condition: As noted in the prior year audit, the District has yet to fully update and review established policies and procedures surrounding risk assessments and grants management associated with the direct administration of federal grants (and others), focusing on clearly defining the key components (i.e., control environment, risk assessment, control activities, information and communication, monitoring). During the current year, we noted the following: Semi-annual time and effort certifications were all completed at the end of the fiscal year same as prior year). We noted a drawdown request associated with the ESSER III funds was performed in January of 2022; however, no expenditures were charged to the funds until August of the subsequent year (fiscal year 2023). We noted the documentation related to quotes obtained under District and state procurement guidelines were unclear/incomplete. See also the Financial Statement Finding 2022-001 reported in accordance with Government Auditing Standards. In our opinion this deficiency could have an impact upon the District’s major federal programs. Repeat Finding: This is a repeat finding from the prior year. Cause: Based upon our discussion with District personnel, due in part to the pandemic, turnover in certain key positions (District accountant) and other personnel changes, the District has fallen behind in the overall close-out and timely reconciliation of financial activity. Additionally, it was indicated additional complexities associated with ever changing operating and regulatory environment of the District combined with staffing turnover increased delays in overall completion of work. A review of the current grant manual, policies and procedures has not been updated. Potential Effect: Specific grant compliance requirements may not be complied with. Moreover, errors or fraud may occur which may not be prevented or detected in a timely manner. Auditor’s recommendation: In our profession opinion, as recommend in the previous year, it is important the District evaluate enhancements to address timely updating of established procedures to ensure the District’s compliance with grant and financial reporting requirements. This is additionally important with changes in District personnel. Management and those charged with governance to design and implement internal controls surrounding financial reporting which ensure timely reconciliation, reporting, monitoring of financial activity and grant compliance. Such policies and procedures should include centralized reporting and monitoring of grant requirements and compliance related thereto should be incorporated into established organizational internal control policies and procedures (inclusive of risk assessment). A routine assessment (annually) should be performed in accordance with updated grant and OMB guidance, to ensure the appropriate design and implementation related thereto. See also our recommendation above (2022-001).