Audit 296136

FY End
2023-06-30
Total Expended
$41.93M
Findings
2
Programs
8
Year: 2023 Accepted: 2024-03-20

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
382478 2023-002 Significant Deficiency Yes P
958920 2023-002 Significant Deficiency Yes P

Contacts

Name Title Type
ZCPNEJ3THRH3 Lisa Rogers Auditee
5088244028 Grady Connor Auditor
No contacts on file

Notes to SEFA

Title: 1. 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 County submits to federal awarding or pass-through entities. De Minimis Rate Used: N Rate Explanation: The County did not use the de minis cost rate. The County of Bristol, Massachusetts (the County) is a governmental entity established by the laws of the Commonwealth of Massachusetts. All operations related to the County’s federal grant programs are included in the scope of the OMB Uniform Guidance. The U.S. Department of Treasury has been designated as the County’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 County of Bristol, Massachusetts for the year ended June 30, 2023. 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 County it is not intended to and does not present the financial position, or changes in the financial position of the County.
Title: 2. 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 County submits to federal awarding or pass-through entities. De Minimis Rate Used: N Rate Explanation: The County did not use the de minis cost rate. 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 County submits to federal awarding or pass-through entities.
Title: 3. Indirect cost rate 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 County submits to federal awarding or pass-through entities. De Minimis Rate Used: N Rate Explanation: The County did not use the de minis cost rate. The County has not elected to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance.
Title: 4. Cash and Non-cash assistance 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 County submits to federal awarding or pass-through entities. De Minimis Rate Used: N Rate Explanation: The County did not use the de minis cost rate. The County received non-cash assistance related to the Child Nutrition cluster (National School Lunch- Assistance listing #10.555), for the year ended June 30, 2023.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: 5. COVID-19 pandemic related funding 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 County submits to federal awarding or pass-through entities. De Minimis Rate Used: N Rate Explanation: The County did not use the de minis cost rate. Programs identified in the accompanying Schedule of Expenditures of Federal Awards which have been funded pursuant to federal legislation as a result of the coronavirus pandemic have been specifically indicated with the prefix- COVID-19.
Title: 6. 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 County submits to federal awarding or pass-through entities. De Minimis Rate Used: N Rate Explanation: The County did not use the de minis cost rate. The County’s subrecipients for the year ended June 30, 2023, are associated with amounts paid for eligible program costs of the County’s Coronavirus State and Local Fiscal Recovery Funds – Assistance listing #21.027. This is accounted for in the County’s American Rescue Plan Program. The County's payments to subrecipients during the fiscal year ending June 30, 2023, are as follows:Subrecipient Amount City of Fall River $ 10,031,967 City of Taunton 6,652,250 City of Attleboro 5,538,000 Town of North Attleborough 5,200,000 Town of Swansea 2,278,665 City of New Bedford 1,867,153 Town of Fairhaven 1,230,540 Town of Raynham 950,000 Town of Dartmouth 875,425 Town of Westport 802,000 Town of Berkley 755,072 Town of Freetown 608,658 Town of Easton 399,181 Town of Mansfield 290,000 Town of Norton 278,000 Town of Rehoboth 106,435 Total $ 37,863,346

Finding Details

riteria:The Uniform Guidance requires grantees to design and implement formalized internal control policies and procedures which address the compliance requirements associated with all federal programs administered by the grantee. Condition and context: The County has worked with other counties and third parties in the establishment of procedures, and electronic portals to streamline the administration of the program. The County enters into a written agreement with each community identifying the community as a subrecipient of the County. Additionally, the County has contracted with two third-party consultants to assist in the initial examination of eligibility of submitted applications in accordance with US Treasury’s program guidelines and additional compliance requirement monitoring. Final approval is performed by the County. Moreover, as reported in the prior year (fiscal year 2022), policies and procedures which more clearly detail and document the processes (subrecipient monitoring) were not yet fully designed and implemented for fiscal year 2023. Per our current year audit, and discussions with personnel, we noted the County implemented additional subrecipient monitoring during fiscal year 2024 for the quarter ending June 30, 2023. A subrecipient monitoring report and associated follow-up procedures was issued by the consultant December 28, 2023. The County indicates it is working to ensure subrecipient monitoring is performed timely. During the current year audit, we also noted the certain activity reported in the County’s required Annual Performance Report surrounding the program for the fiscal year ending June 30, 2023, could not be reconciled with the initial underlying tracking spreadsheets and information provided. We recommend personnel maintain documentation at the time of reporting to ensure accuracy and reconciliation to underlying documentation. During our testing of certain applications submitted during the fiscal year, we noted one instance in which a subrecipient grant agreement which was not signed by the County. We noted all payments made during fiscal year 2023 associated with the program were approved by the County Commissioners. In our professional opinion personnel should ensure all approvals are documented through established procedures. Moreover, steps should be taken to ensure annual reporting is supported by underlying documentation at the time of the reporting. Cause:Due to the nature of the award, initial incomplete and changing guidance related thereto, the County worked to provide the fiscal relief to communities in a timely manner. Accordingly, all aspects of the program administration required continued review and implementation. Effect or potential effect: Noncompliance could occur. Questioned costs: None. Auditor’s recommendation: In our professional judgement, we recommend the County continue to evaluate (and more formally document) internal control policies and procedures (inclusive of responsibilities, duties, documentation related thereto) associated with overall administration (and subrecipient monitoring) of the program. In our opinion this should more clearly define parameters of the results of the risk assessment process and the depth of subrecipient monitoring, and County decisions related thereto. We recommend the County review and update current policies and procedures manuals to ensure all of the County’s federal programs’ internal control over compliance and central monitoring and reporting thereof is being met. Views of responsible officials: The County has developed a formalized internal control policy and procedures, including a robust subrecipient monitoring program. The procedures include control environment, risk assessment, control activities, and information and communication monitoring. As part of the procedure, the County ensures that all documentation associated with subrecipient grants are maintained by the County. As indicated, the County has implemented current subrecipient policies and procedures.
riteria:The Uniform Guidance requires grantees to design and implement formalized internal control policies and procedures which address the compliance requirements associated with all federal programs administered by the grantee. Condition and context: The County has worked with other counties and third parties in the establishment of procedures, and electronic portals to streamline the administration of the program. The County enters into a written agreement with each community identifying the community as a subrecipient of the County. Additionally, the County has contracted with two third-party consultants to assist in the initial examination of eligibility of submitted applications in accordance with US Treasury’s program guidelines and additional compliance requirement monitoring. Final approval is performed by the County. Moreover, as reported in the prior year (fiscal year 2022), policies and procedures which more clearly detail and document the processes (subrecipient monitoring) were not yet fully designed and implemented for fiscal year 2023. Per our current year audit, and discussions with personnel, we noted the County implemented additional subrecipient monitoring during fiscal year 2024 for the quarter ending June 30, 2023. A subrecipient monitoring report and associated follow-up procedures was issued by the consultant December 28, 2023. The County indicates it is working to ensure subrecipient monitoring is performed timely. During the current year audit, we also noted the certain activity reported in the County’s required Annual Performance Report surrounding the program for the fiscal year ending June 30, 2023, could not be reconciled with the initial underlying tracking spreadsheets and information provided. We recommend personnel maintain documentation at the time of reporting to ensure accuracy and reconciliation to underlying documentation. During our testing of certain applications submitted during the fiscal year, we noted one instance in which a subrecipient grant agreement which was not signed by the County. We noted all payments made during fiscal year 2023 associated with the program were approved by the County Commissioners. In our professional opinion personnel should ensure all approvals are documented through established procedures. Moreover, steps should be taken to ensure annual reporting is supported by underlying documentation at the time of the reporting. Cause:Due to the nature of the award, initial incomplete and changing guidance related thereto, the County worked to provide the fiscal relief to communities in a timely manner. Accordingly, all aspects of the program administration required continued review and implementation. Effect or potential effect: Noncompliance could occur. Questioned costs: None. Auditor’s recommendation: In our professional judgement, we recommend the County continue to evaluate (and more formally document) internal control policies and procedures (inclusive of responsibilities, duties, documentation related thereto) associated with overall administration (and subrecipient monitoring) of the program. In our opinion this should more clearly define parameters of the results of the risk assessment process and the depth of subrecipient monitoring, and County decisions related thereto. We recommend the County review and update current policies and procedures manuals to ensure all of the County’s federal programs’ internal control over compliance and central monitoring and reporting thereof is being met. Views of responsible officials: The County has developed a formalized internal control policy and procedures, including a robust subrecipient monitoring program. The procedures include control environment, risk assessment, control activities, and information and communication monitoring. As part of the procedure, the County ensures that all documentation associated with subrecipient grants are maintained by the County. As indicated, the County has implemented current subrecipient policies and procedures.