Audit 299007

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Special Education Cluster Special Education Grants to States Federal Assistance Listing No. 84.027 Special Education Preschool Grants Federal Assistance Listing No. 84.173 2023-002: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $1,794,406, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $156,211 for 65 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $156,211 could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-001. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the special education grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Special Education Cluster Special Education Grants to States Federal Assistance Listing No. 84.027 Special Education Preschool Grants Federal Assistance Listing No. 84.173 2023-002: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $1,794,406, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $156,211 for 65 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $156,211 could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-001. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the special education grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Special Education Cluster Special Education Grants to States Federal Assistance Listing No. 84.027 Special Education Preschool Grants Federal Assistance Listing No. 84.173 2023-002: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $1,794,406, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $156,211 for 65 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $156,211 could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-001. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the special education grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Special Education Cluster Special Education Grants to States Federal Assistance Listing No. 84.027 Special Education Preschool Grants Federal Assistance Listing No. 84.173 2023-002: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $1,794,406, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $156,211 for 65 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $156,211 could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-001. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the special education grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Special Education Cluster Special Education Grants to States Federal Assistance Listing No. 84.027 Special Education Preschool Grants Federal Assistance Listing No. 84.173 2023-002: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $1,794,406, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $156,211 for 65 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $156,211 could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-001. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the special education grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Special Education Cluster Special Education Grants to States Federal Assistance Listing No. 84.027 Special Education Preschool Grants Federal Assistance Listing No. 84.173 2023-002: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $1,794,406, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $156,211 for 65 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $156,211 could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-001. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the special education grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 2023-003: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Title I grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $919,109, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $110,714 for 28 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $110,714 could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-002. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines, and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the Title I grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 2023-003: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Title I grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $919,109, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $110,714 for 28 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $110,714 could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-002. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines, and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the Title I grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 2023-003: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Title I grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $919,109, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $110,714 for 28 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $110,714 could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-002. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines, and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the Title I grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 2023-003: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Title I grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $919,109, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $110,714 for 28 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $110,714 could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-002. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines, and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the Title I grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 2023-004: Eligibility of Schools and Allocations to Schools Compliance Requirement: Eligibility Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must determine which schools or school attendance areas are eligible to participate in the program. When determining eligibility, grantees must select a poverty measure from among one of the allowable data sources. Grantees must serve eligible schools or attendance areas in rank order according to their percentage of poverty. Grantees must also provide equitable services to eligible private school students and homeless students prior to allocating funds to eligible public schools using similar allowable data sources. Condition: The City was required to determine which schools or school attendance areas, including private school students and homeless students, were eligible to participate in the grant program. The City was also required to ensure that eligible schools or school attendance areas were served in rank order in accordance with their percentage of poverty. The supporting documentation was not available upon request and was not provided in a timely manner. The information required to perform this testing was requested in May 2023, and was not provided until January 2024, after several repeated requests were made throughout that time. Context: The City did not provide sufficient documentation to demonstrate the compliance of its eligibility determinations or allocations to schools in a timely manner. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that documentation regarding eligibility determinations and allocations is retained and filed in an organized manner that is made readily available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all documentation regarding eligibility determinations and allocations to schools. The documentation should be filed in an organized manner and should be readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required documentation is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 2023-004: Eligibility of Schools and Allocations to Schools Compliance Requirement: Eligibility Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must determine which schools or school attendance areas are eligible to participate in the program. When determining eligibility, grantees must select a poverty measure from among one of the allowable data sources. Grantees must serve eligible schools or attendance areas in rank order according to their percentage of poverty. Grantees must also provide equitable services to eligible private school students and homeless students prior to allocating funds to eligible public schools using similar allowable data sources. Condition: The City was required to determine which schools or school attendance areas, including private school students and homeless students, were eligible to participate in the grant program. The City was also required to ensure that eligible schools or school attendance areas were served in rank order in accordance with their percentage of poverty. The supporting documentation was not available upon request and was not provided in a timely manner. The information required to perform this testing was requested in May 2023, and was not provided until January 2024, after several repeated requests were made throughout that time. Context: The City did not provide sufficient documentation to demonstrate the compliance of its eligibility determinations or allocations to schools in a timely manner. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that documentation regarding eligibility determinations and allocations is retained and filed in an organized manner that is made readily available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all documentation regarding eligibility determinations and allocations to schools. The documentation should be filed in an organized manner and should be readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required documentation is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 2023-004: Eligibility of Schools and Allocations to Schools Compliance Requirement: Eligibility Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must determine which schools or school attendance areas are eligible to participate in the program. When determining eligibility, grantees must select a poverty measure from among one of the allowable data sources. Grantees must serve eligible schools or attendance areas in rank order according to their percentage of poverty. Grantees must also provide equitable services to eligible private school students and homeless students prior to allocating funds to eligible public schools using similar allowable data sources. Condition: The City was required to determine which schools or school attendance areas, including private school students and homeless students, were eligible to participate in the grant program. The City was also required to ensure that eligible schools or school attendance areas were served in rank order in accordance with their percentage of poverty. The supporting documentation was not available upon request and was not provided in a timely manner. The information required to perform this testing was requested in May 2023, and was not provided until January 2024, after several repeated requests were made throughout that time. Context: The City did not provide sufficient documentation to demonstrate the compliance of its eligibility determinations or allocations to schools in a timely manner. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that documentation regarding eligibility determinations and allocations is retained and filed in an organized manner that is made readily available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all documentation regarding eligibility determinations and allocations to schools. The documentation should be filed in an organized manner and should be readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required documentation is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 2023-004: Eligibility of Schools and Allocations to Schools Compliance Requirement: Eligibility Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must determine which schools or school attendance areas are eligible to participate in the program. When determining eligibility, grantees must select a poverty measure from among one of the allowable data sources. Grantees must serve eligible schools or attendance areas in rank order according to their percentage of poverty. Grantees must also provide equitable services to eligible private school students and homeless students prior to allocating funds to eligible public schools using similar allowable data sources. Condition: The City was required to determine which schools or school attendance areas, including private school students and homeless students, were eligible to participate in the grant program. The City was also required to ensure that eligible schools or school attendance areas were served in rank order in accordance with their percentage of poverty. The supporting documentation was not available upon request and was not provided in a timely manner. The information required to perform this testing was requested in May 2023, and was not provided until January 2024, after several repeated requests were made throughout that time. Context: The City did not provide sufficient documentation to demonstrate the compliance of its eligibility determinations or allocations to schools in a timely manner. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that documentation regarding eligibility determinations and allocations is retained and filed in an organized manner that is made readily available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all documentation regarding eligibility determinations and allocations to schools. The documentation should be filed in an organized manner and should be readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required documentation is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 2023-005: Affirmation of Consultation Forms to Private Schools Compliance Requirement: Special Tests and Provisions Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide equitable services to eligible private school children, their teachers, and their families. Grantees must conduct timely and meaningful consultation with private school officials to determine the kind of educational services to provide to eligible private school children. Grantees must also ensure that planned services are provided and that the required amount was used for private school children. Condition: The City was required to ensure that a portion of this grant was available for the equitable participation of students, families, and educators in non-profit, non-public (private) schools. Public school officials were required to initiate contact and make good faith efforts to have timely and meaningful consultation with private school officials regarding participation in programs and services. The City was also required to document these consultations via signed Affirmation of Consultation forms. The supporting documentation was not available upon request and was not provided in a timely manner. The information required to perform this testing was requested in May 2023, and was not provided until January 2024, after several repeated requests were made throughout that time. Context: The City did not provide sufficient documentation to demonstrate compliance with its requirement to conduct timely and meaningful consultations with officials from eligible private schools in a timely manner. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that the required consultations with private schools take place and that the consultations performed are adequately documented, retained and filed in an organized manner that is made readily available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all required forms. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that timely consultations with private schools occur, and that the required documentation is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 2023-005: Affirmation of Consultation Forms to Private Schools Compliance Requirement: Special Tests and Provisions Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide equitable services to eligible private school children, their teachers, and their families. Grantees must conduct timely and meaningful consultation with private school officials to determine the kind of educational services to provide to eligible private school children. Grantees must also ensure that planned services are provided and that the required amount was used for private school children. Condition: The City was required to ensure that a portion of this grant was available for the equitable participation of students, families, and educators in non-profit, non-public (private) schools. Public school officials were required to initiate contact and make good faith efforts to have timely and meaningful consultation with private school officials regarding participation in programs and services. The City was also required to document these consultations via signed Affirmation of Consultation forms. The supporting documentation was not available upon request and was not provided in a timely manner. The information required to perform this testing was requested in May 2023, and was not provided until January 2024, after several repeated requests were made throughout that time. Context: The City did not provide sufficient documentation to demonstrate compliance with its requirement to conduct timely and meaningful consultations with officials from eligible private schools in a timely manner. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that the required consultations with private schools take place and that the consultations performed are adequately documented, retained and filed in an organized manner that is made readily available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all required forms. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that timely consultations with private schools occur, and that the required documentation is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 2023-005: Affirmation of Consultation Forms to Private Schools Compliance Requirement: Special Tests and Provisions Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide equitable services to eligible private school children, their teachers, and their families. Grantees must conduct timely and meaningful consultation with private school officials to determine the kind of educational services to provide to eligible private school children. Grantees must also ensure that planned services are provided and that the required amount was used for private school children. Condition: The City was required to ensure that a portion of this grant was available for the equitable participation of students, families, and educators in non-profit, non-public (private) schools. Public school officials were required to initiate contact and make good faith efforts to have timely and meaningful consultation with private school officials regarding participation in programs and services. The City was also required to document these consultations via signed Affirmation of Consultation forms. The supporting documentation was not available upon request and was not provided in a timely manner. The information required to perform this testing was requested in May 2023, and was not provided until January 2024, after several repeated requests were made throughout that time. Context: The City did not provide sufficient documentation to demonstrate compliance with its requirement to conduct timely and meaningful consultations with officials from eligible private schools in a timely manner. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that the required consultations with private schools take place and that the consultations performed are adequately documented, retained and filed in an organized manner that is made readily available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all required forms. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that timely consultations with private schools occur, and that the required documentation is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 2023-005: Affirmation of Consultation Forms to Private Schools Compliance Requirement: Special Tests and Provisions Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide equitable services to eligible private school children, their teachers, and their families. Grantees must conduct timely and meaningful consultation with private school officials to determine the kind of educational services to provide to eligible private school children. Grantees must also ensure that planned services are provided and that the required amount was used for private school children. Condition: The City was required to ensure that a portion of this grant was available for the equitable participation of students, families, and educators in non-profit, non-public (private) schools. Public school officials were required to initiate contact and make good faith efforts to have timely and meaningful consultation with private school officials regarding participation in programs and services. The City was also required to document these consultations via signed Affirmation of Consultation forms. The supporting documentation was not available upon request and was not provided in a timely manner. The information required to perform this testing was requested in May 2023, and was not provided until January 2024, after several repeated requests were made throughout that time. Context: The City did not provide sufficient documentation to demonstrate compliance with its requirement to conduct timely and meaningful consultations with officials from eligible private schools in a timely manner. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that the required consultations with private schools take place and that the consultations performed are adequately documented, retained and filed in an organized manner that is made readily available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all required forms. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that timely consultations with private schools occur, and that the required documentation is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-006: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Education Stabilization Fund grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $3,487,658, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $440,173 for 83 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $440,173 of could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-003. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the education stabilization grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-006: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Education Stabilization Fund grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $3,487,658, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $440,173 for 83 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $440,173 of could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-003. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the education stabilization grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-006: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Education Stabilization Fund grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $3,487,658, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $440,173 for 83 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $440,173 of could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-003. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the education stabilization grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-006: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Education Stabilization Fund grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $3,487,658, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $440,173 for 83 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $440,173 of could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-003. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the education stabilization grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-006: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Education Stabilization Fund grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $3,487,658, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $440,173 for 83 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $440,173 of could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-003. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the education stabilization grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-006: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Education Stabilization Fund grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $3,487,658, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $440,173 for 83 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $440,173 of could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-003. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the education stabilization grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-006: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Education Stabilization Fund grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $3,487,658, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $440,173 for 83 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $440,173 of could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-003. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the education stabilization grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-006: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Education Stabilization Fund grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $3,487,658, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $440,173 for 83 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $440,173 of could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-003. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the education stabilization grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-007: Controls for the Purchase of Capital Equipment Compliance Requirement: Equipment/Real Property Management Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must obtain prior approval from the pass-through entity for capital expenditures related to general and special purpose equipment purchases. Condition: The City was required to obtain prior approval from the pass-through entity for capital expenditures related to general or special purpose equipment. The City purchased security camera equipment and was unable to provide evidence that prior approval was obtained. Context: The City did not maintain sufficient documentation to demonstrate that approval was obtained prior to the purchase of capital equipment. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that approval is obtained prior to the purchase of capital equipment and that documentation of the approval is retained. Questioned Costs: The City expended a total of $4,564,014 in Education Stabilization Funds in 2023, of which $619,967 was charged to a contract services account. Of the total charged to the contract services account, $302,687 was selected for testing and $73,629 was spent on the purchase of security camera equipment without prior approval from the pass-through entity. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the need to obtain prior approval from the pass-through entity for capital expenditures paid from the Education Stabilization Funds grants. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required approvals are obtained and the documentation is maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-007: Controls for the Purchase of Capital Equipment Compliance Requirement: Equipment/Real Property Management Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must obtain prior approval from the pass-through entity for capital expenditures related to general and special purpose equipment purchases. Condition: The City was required to obtain prior approval from the pass-through entity for capital expenditures related to general or special purpose equipment. The City purchased security camera equipment and was unable to provide evidence that prior approval was obtained. Context: The City did not maintain sufficient documentation to demonstrate that approval was obtained prior to the purchase of capital equipment. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that approval is obtained prior to the purchase of capital equipment and that documentation of the approval is retained. Questioned Costs: The City expended a total of $4,564,014 in Education Stabilization Funds in 2023, of which $619,967 was charged to a contract services account. Of the total charged to the contract services account, $302,687 was selected for testing and $73,629 was spent on the purchase of security camera equipment without prior approval from the pass-through entity. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the need to obtain prior approval from the pass-through entity for capital expenditures paid from the Education Stabilization Funds grants. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required approvals are obtained and the documentation is maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-007: Controls for the Purchase of Capital Equipment Compliance Requirement: Equipment/Real Property Management Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must obtain prior approval from the pass-through entity for capital expenditures related to general and special purpose equipment purchases. Condition: The City was required to obtain prior approval from the pass-through entity for capital expenditures related to general or special purpose equipment. The City purchased security camera equipment and was unable to provide evidence that prior approval was obtained. Context: The City did not maintain sufficient documentation to demonstrate that approval was obtained prior to the purchase of capital equipment. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that approval is obtained prior to the purchase of capital equipment and that documentation of the approval is retained. Questioned Costs: The City expended a total of $4,564,014 in Education Stabilization Funds in 2023, of which $619,967 was charged to a contract services account. Of the total charged to the contract services account, $302,687 was selected for testing and $73,629 was spent on the purchase of security camera equipment without prior approval from the pass-through entity. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the need to obtain prior approval from the pass-through entity for capital expenditures paid from the Education Stabilization Funds grants. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required approvals are obtained and the documentation is maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-007: Controls for the Purchase of Capital Equipment Compliance Requirement: Equipment/Real Property Management Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must obtain prior approval from the pass-through entity for capital expenditures related to general and special purpose equipment purchases. Condition: The City was required to obtain prior approval from the pass-through entity for capital expenditures related to general or special purpose equipment. The City purchased security camera equipment and was unable to provide evidence that prior approval was obtained. Context: The City did not maintain sufficient documentation to demonstrate that approval was obtained prior to the purchase of capital equipment. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that approval is obtained prior to the purchase of capital equipment and that documentation of the approval is retained. Questioned Costs: The City expended a total of $4,564,014 in Education Stabilization Funds in 2023, of which $619,967 was charged to a contract services account. Of the total charged to the contract services account, $302,687 was selected for testing and $73,629 was spent on the purchase of security camera equipment without prior approval from the pass-through entity. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the need to obtain prior approval from the pass-through entity for capital expenditures paid from the Education Stabilization Funds grants. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required approvals are obtained and the documentation is maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-007: Controls for the Purchase of Capital Equipment Compliance Requirement: Equipment/Real Property Management Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must obtain prior approval from the pass-through entity for capital expenditures related to general and special purpose equipment purchases. Condition: The City was required to obtain prior approval from the pass-through entity for capital expenditures related to general or special purpose equipment. The City purchased security camera equipment and was unable to provide evidence that prior approval was obtained. Context: The City did not maintain sufficient documentation to demonstrate that approval was obtained prior to the purchase of capital equipment. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that approval is obtained prior to the purchase of capital equipment and that documentation of the approval is retained. Questioned Costs: The City expended a total of $4,564,014 in Education Stabilization Funds in 2023, of which $619,967 was charged to a contract services account. Of the total charged to the contract services account, $302,687 was selected for testing and $73,629 was spent on the purchase of security camera equipment without prior approval from the pass-through entity. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the need to obtain prior approval from the pass-through entity for capital expenditures paid from the Education Stabilization Funds grants. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required approvals are obtained and the documentation is maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-007: Controls for the Purchase of Capital Equipment Compliance Requirement: Equipment/Real Property Management Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must obtain prior approval from the pass-through entity for capital expenditures related to general and special purpose equipment purchases. Condition: The City was required to obtain prior approval from the pass-through entity for capital expenditures related to general or special purpose equipment. The City purchased security camera equipment and was unable to provide evidence that prior approval was obtained. Context: The City did not maintain sufficient documentation to demonstrate that approval was obtained prior to the purchase of capital equipment. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that approval is obtained prior to the purchase of capital equipment and that documentation of the approval is retained. Questioned Costs: The City expended a total of $4,564,014 in Education Stabilization Funds in 2023, of which $619,967 was charged to a contract services account. Of the total charged to the contract services account, $302,687 was selected for testing and $73,629 was spent on the purchase of security camera equipment without prior approval from the pass-through entity. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the need to obtain prior approval from the pass-through entity for capital expenditures paid from the Education Stabilization Funds grants. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required approvals are obtained and the documentation is maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-007: Controls for the Purchase of Capital Equipment Compliance Requirement: Equipment/Real Property Management Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must obtain prior approval from the pass-through entity for capital expenditures related to general and special purpose equipment purchases. Condition: The City was required to obtain prior approval from the pass-through entity for capital expenditures related to general or special purpose equipment. The City purchased security camera equipment and was unable to provide evidence that prior approval was obtained. Context: The City did not maintain sufficient documentation to demonstrate that approval was obtained prior to the purchase of capital equipment. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that approval is obtained prior to the purchase of capital equipment and that documentation of the approval is retained. Questioned Costs: The City expended a total of $4,564,014 in Education Stabilization Funds in 2023, of which $619,967 was charged to a contract services account. Of the total charged to the contract services account, $302,687 was selected for testing and $73,629 was spent on the purchase of security camera equipment without prior approval from the pass-through entity. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the need to obtain prior approval from the pass-through entity for capital expenditures paid from the Education Stabilization Funds grants. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required approvals are obtained and the documentation is maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-007: Controls for the Purchase of Capital Equipment Compliance Requirement: Equipment/Real Property Management Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must obtain prior approval from the pass-through entity for capital expenditures related to general and special purpose equipment purchases. Condition: The City was required to obtain prior approval from the pass-through entity for capital expenditures related to general or special purpose equipment. The City purchased security camera equipment and was unable to provide evidence that prior approval was obtained. Context: The City did not maintain sufficient documentation to demonstrate that approval was obtained prior to the purchase of capital equipment. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that approval is obtained prior to the purchase of capital equipment and that documentation of the approval is retained. Questioned Costs: The City expended a total of $4,564,014 in Education Stabilization Funds in 2023, of which $619,967 was charged to a contract services account. Of the total charged to the contract services account, $302,687 was selected for testing and $73,629 was spent on the purchase of security camera equipment without prior approval from the pass-through entity. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the need to obtain prior approval from the pass-through entity for capital expenditures paid from the Education Stabilization Funds grants. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required approvals are obtained and the documentation is maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-008: Reporting to the State Compliance Requirement: Reporting Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must comply with reporting requirements established by the Massachusetts Department of Elementary and Secondary Education, the City’s Pass-Through Grantor (State). In order for the State to comply with federal reporting requirements, the City is required to submit complete and accurate “Recipient Data Collection Forms” to the State. Condition: The City was unable to provide copies of the Recipient Data Collection Forms submitted to the State. Context: The City did not maintain sufficient documentation to demonstrate compliance with grant reporting requirements. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure and demonstrate that required reporting is completed, retained, and available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all required reports. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required reporting is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.   D. Summary Schedule of Prior Audit Findings and Questioned Costs 2022-001: Controls for Monitoring Payroll Charged to the Grant Condition and Criteria: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City did not maintain sufficient supporting documentation to demonstrate compliance with federal and state time and effort reporting requirements. Recommendation: The City should implement procedures to ensure compliance with all grant requirements. Current Status: It was anticipated that the recommendation would be implemented in 2023, however this did not occur. This matter has been reported in finding 2023-002.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-008: Reporting to the State Compliance Requirement: Reporting Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must comply with reporting requirements established by the Massachusetts Department of Elementary and Secondary Education, the City’s Pass-Through Grantor (State). In order for the State to comply with federal reporting requirements, the City is required to submit complete and accurate “Recipient Data Collection Forms” to the State. Condition: The City was unable to provide copies of the Recipient Data Collection Forms submitted to the State. Context: The City did not maintain sufficient documentation to demonstrate compliance with grant reporting requirements. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure and demonstrate that required reporting is completed, retained, and available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all required reports. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required reporting is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.   D. Summary Schedule of Prior Audit Findings and Questioned Costs 2022-001: Controls for Monitoring Payroll Charged to the Grant Condition and Criteria: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City did not maintain sufficient supporting documentation to demonstrate compliance with federal and state time and effort reporting requirements. Recommendation: The City should implement procedures to ensure compliance with all grant requirements. Current Status: It was anticipated that the recommendation would be implemented in 2023, however this did not occur. This matter has been reported in finding 2023-002.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-008: Reporting to the State Compliance Requirement: Reporting Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must comply with reporting requirements established by the Massachusetts Department of Elementary and Secondary Education, the City’s Pass-Through Grantor (State). In order for the State to comply with federal reporting requirements, the City is required to submit complete and accurate “Recipient Data Collection Forms” to the State. Condition: The City was unable to provide copies of the Recipient Data Collection Forms submitted to the State. Context: The City did not maintain sufficient documentation to demonstrate compliance with grant reporting requirements. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure and demonstrate that required reporting is completed, retained, and available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all required reports. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required reporting is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.   D. Summary Schedule of Prior Audit Findings and Questioned Costs 2022-001: Controls for Monitoring Payroll Charged to the Grant Condition and Criteria: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City did not maintain sufficient supporting documentation to demonstrate compliance with federal and state time and effort reporting requirements. Recommendation: The City should implement procedures to ensure compliance with all grant requirements. Current Status: It was anticipated that the recommendation would be implemented in 2023, however this did not occur. This matter has been reported in finding 2023-002.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-008: Reporting to the State Compliance Requirement: Reporting Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must comply with reporting requirements established by the Massachusetts Department of Elementary and Secondary Education, the City’s Pass-Through Grantor (State). In order for the State to comply with federal reporting requirements, the City is required to submit complete and accurate “Recipient Data Collection Forms” to the State. Condition: The City was unable to provide copies of the Recipient Data Collection Forms submitted to the State. Context: The City did not maintain sufficient documentation to demonstrate compliance with grant reporting requirements. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure and demonstrate that required reporting is completed, retained, and available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all required reports. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required reporting is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.   D. Summary Schedule of Prior Audit Findings and Questioned Costs 2022-001: Controls for Monitoring Payroll Charged to the Grant Condition and Criteria: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City did not maintain sufficient supporting documentation to demonstrate compliance with federal and state time and effort reporting requirements. Recommendation: The City should implement procedures to ensure compliance with all grant requirements. Current Status: It was anticipated that the recommendation would be implemented in 2023, however this did not occur. This matter has been reported in finding 2023-002.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-008: Reporting to the State Compliance Requirement: Reporting Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must comply with reporting requirements established by the Massachusetts Department of Elementary and Secondary Education, the City’s Pass-Through Grantor (State). In order for the State to comply with federal reporting requirements, the City is required to submit complete and accurate “Recipient Data Collection Forms” to the State. Condition: The City was unable to provide copies of the Recipient Data Collection Forms submitted to the State. Context: The City did not maintain sufficient documentation to demonstrate compliance with grant reporting requirements. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure and demonstrate that required reporting is completed, retained, and available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all required reports. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required reporting is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.   D. Summary Schedule of Prior Audit Findings and Questioned Costs 2022-001: Controls for Monitoring Payroll Charged to the Grant Condition and Criteria: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City did not maintain sufficient supporting documentation to demonstrate compliance with federal and state time and effort reporting requirements. Recommendation: The City should implement procedures to ensure compliance with all grant requirements. Current Status: It was anticipated that the recommendation would be implemented in 2023, however this did not occur. This matter has been reported in finding 2023-002.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-008: Reporting to the State Compliance Requirement: Reporting Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must comply with reporting requirements established by the Massachusetts Department of Elementary and Secondary Education, the City’s Pass-Through Grantor (State). In order for the State to comply with federal reporting requirements, the City is required to submit complete and accurate “Recipient Data Collection Forms” to the State. Condition: The City was unable to provide copies of the Recipient Data Collection Forms submitted to the State. Context: The City did not maintain sufficient documentation to demonstrate compliance with grant reporting requirements. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure and demonstrate that required reporting is completed, retained, and available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all required reports. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required reporting is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.   D. Summary Schedule of Prior Audit Findings and Questioned Costs 2022-001: Controls for Monitoring Payroll Charged to the Grant Condition and Criteria: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City did not maintain sufficient supporting documentation to demonstrate compliance with federal and state time and effort reporting requirements. Recommendation: The City should implement procedures to ensure compliance with all grant requirements. Current Status: It was anticipated that the recommendation would be implemented in 2023, however this did not occur. This matter has been reported in finding 2023-002.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-008: Reporting to the State Compliance Requirement: Reporting Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must comply with reporting requirements established by the Massachusetts Department of Elementary and Secondary Education, the City’s Pass-Through Grantor (State). In order for the State to comply with federal reporting requirements, the City is required to submit complete and accurate “Recipient Data Collection Forms” to the State. Condition: The City was unable to provide copies of the Recipient Data Collection Forms submitted to the State. Context: The City did not maintain sufficient documentation to demonstrate compliance with grant reporting requirements. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure and demonstrate that required reporting is completed, retained, and available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all required reports. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required reporting is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.   D. Summary Schedule of Prior Audit Findings and Questioned Costs 2022-001: Controls for Monitoring Payroll Charged to the Grant Condition and Criteria: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City did not maintain sufficient supporting documentation to demonstrate compliance with federal and state time and effort reporting requirements. Recommendation: The City should implement procedures to ensure compliance with all grant requirements. Current Status: It was anticipated that the recommendation would be implemented in 2023, however this did not occur. This matter has been reported in finding 2023-002.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-008: Reporting to the State Compliance Requirement: Reporting Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must comply with reporting requirements established by the Massachusetts Department of Elementary and Secondary Education, the City’s Pass-Through Grantor (State). In order for the State to comply with federal reporting requirements, the City is required to submit complete and accurate “Recipient Data Collection Forms” to the State. Condition: The City was unable to provide copies of the Recipient Data Collection Forms submitted to the State. Context: The City did not maintain sufficient documentation to demonstrate compliance with grant reporting requirements. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure and demonstrate that required reporting is completed, retained, and available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all required reports. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required reporting is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.   D. Summary Schedule of Prior Audit Findings and Questioned Costs 2022-001: Controls for Monitoring Payroll Charged to the Grant Condition and Criteria: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City did not maintain sufficient supporting documentation to demonstrate compliance with federal and state time and effort reporting requirements. Recommendation: The City should implement procedures to ensure compliance with all grant requirements. Current Status: It was anticipated that the recommendation would be implemented in 2023, however this did not occur. This matter has been reported in finding 2023-002.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Special Education Cluster Special Education Grants to States Federal Assistance Listing No. 84.027 Special Education Preschool Grants Federal Assistance Listing No. 84.173 2023-002: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $1,794,406, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $156,211 for 65 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $156,211 could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-001. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the special education grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Special Education Cluster Special Education Grants to States Federal Assistance Listing No. 84.027 Special Education Preschool Grants Federal Assistance Listing No. 84.173 2023-002: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $1,794,406, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $156,211 for 65 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $156,211 could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-001. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the special education grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Special Education Cluster Special Education Grants to States Federal Assistance Listing No. 84.027 Special Education Preschool Grants Federal Assistance Listing No. 84.173 2023-002: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $1,794,406, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $156,211 for 65 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $156,211 could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-001. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the special education grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Special Education Cluster Special Education Grants to States Federal Assistance Listing No. 84.027 Special Education Preschool Grants Federal Assistance Listing No. 84.173 2023-002: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $1,794,406, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $156,211 for 65 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $156,211 could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-001. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the special education grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Special Education Cluster Special Education Grants to States Federal Assistance Listing No. 84.027 Special Education Preschool Grants Federal Assistance Listing No. 84.173 2023-002: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $1,794,406, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $156,211 for 65 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $156,211 could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-001. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the special education grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Special Education Cluster Special Education Grants to States Federal Assistance Listing No. 84.027 Special Education Preschool Grants Federal Assistance Listing No. 84.173 2023-002: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $1,794,406, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $156,211 for 65 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $156,211 could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-001. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the special education grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 2023-003: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Title I grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $919,109, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $110,714 for 28 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $110,714 could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-002. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines, and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the Title I grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 2023-003: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Title I grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $919,109, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $110,714 for 28 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $110,714 could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-002. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines, and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the Title I grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 2023-003: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Title I grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $919,109, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $110,714 for 28 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $110,714 could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-002. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines, and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the Title I grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 2023-003: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Title I grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $919,109, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $110,714 for 28 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $110,714 could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-002. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines, and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the Title I grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 2023-004: Eligibility of Schools and Allocations to Schools Compliance Requirement: Eligibility Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must determine which schools or school attendance areas are eligible to participate in the program. When determining eligibility, grantees must select a poverty measure from among one of the allowable data sources. Grantees must serve eligible schools or attendance areas in rank order according to their percentage of poverty. Grantees must also provide equitable services to eligible private school students and homeless students prior to allocating funds to eligible public schools using similar allowable data sources. Condition: The City was required to determine which schools or school attendance areas, including private school students and homeless students, were eligible to participate in the grant program. The City was also required to ensure that eligible schools or school attendance areas were served in rank order in accordance with their percentage of poverty. The supporting documentation was not available upon request and was not provided in a timely manner. The information required to perform this testing was requested in May 2023, and was not provided until January 2024, after several repeated requests were made throughout that time. Context: The City did not provide sufficient documentation to demonstrate the compliance of its eligibility determinations or allocations to schools in a timely manner. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that documentation regarding eligibility determinations and allocations is retained and filed in an organized manner that is made readily available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all documentation regarding eligibility determinations and allocations to schools. The documentation should be filed in an organized manner and should be readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required documentation is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 2023-004: Eligibility of Schools and Allocations to Schools Compliance Requirement: Eligibility Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must determine which schools or school attendance areas are eligible to participate in the program. When determining eligibility, grantees must select a poverty measure from among one of the allowable data sources. Grantees must serve eligible schools or attendance areas in rank order according to their percentage of poverty. Grantees must also provide equitable services to eligible private school students and homeless students prior to allocating funds to eligible public schools using similar allowable data sources. Condition: The City was required to determine which schools or school attendance areas, including private school students and homeless students, were eligible to participate in the grant program. The City was also required to ensure that eligible schools or school attendance areas were served in rank order in accordance with their percentage of poverty. The supporting documentation was not available upon request and was not provided in a timely manner. The information required to perform this testing was requested in May 2023, and was not provided until January 2024, after several repeated requests were made throughout that time. Context: The City did not provide sufficient documentation to demonstrate the compliance of its eligibility determinations or allocations to schools in a timely manner. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that documentation regarding eligibility determinations and allocations is retained and filed in an organized manner that is made readily available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all documentation regarding eligibility determinations and allocations to schools. The documentation should be filed in an organized manner and should be readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required documentation is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 2023-004: Eligibility of Schools and Allocations to Schools Compliance Requirement: Eligibility Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must determine which schools or school attendance areas are eligible to participate in the program. When determining eligibility, grantees must select a poverty measure from among one of the allowable data sources. Grantees must serve eligible schools or attendance areas in rank order according to their percentage of poverty. Grantees must also provide equitable services to eligible private school students and homeless students prior to allocating funds to eligible public schools using similar allowable data sources. Condition: The City was required to determine which schools or school attendance areas, including private school students and homeless students, were eligible to participate in the grant program. The City was also required to ensure that eligible schools or school attendance areas were served in rank order in accordance with their percentage of poverty. The supporting documentation was not available upon request and was not provided in a timely manner. The information required to perform this testing was requested in May 2023, and was not provided until January 2024, after several repeated requests were made throughout that time. Context: The City did not provide sufficient documentation to demonstrate the compliance of its eligibility determinations or allocations to schools in a timely manner. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that documentation regarding eligibility determinations and allocations is retained and filed in an organized manner that is made readily available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all documentation regarding eligibility determinations and allocations to schools. The documentation should be filed in an organized manner and should be readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required documentation is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 2023-004: Eligibility of Schools and Allocations to Schools Compliance Requirement: Eligibility Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must determine which schools or school attendance areas are eligible to participate in the program. When determining eligibility, grantees must select a poverty measure from among one of the allowable data sources. Grantees must serve eligible schools or attendance areas in rank order according to their percentage of poverty. Grantees must also provide equitable services to eligible private school students and homeless students prior to allocating funds to eligible public schools using similar allowable data sources. Condition: The City was required to determine which schools or school attendance areas, including private school students and homeless students, were eligible to participate in the grant program. The City was also required to ensure that eligible schools or school attendance areas were served in rank order in accordance with their percentage of poverty. The supporting documentation was not available upon request and was not provided in a timely manner. The information required to perform this testing was requested in May 2023, and was not provided until January 2024, after several repeated requests were made throughout that time. Context: The City did not provide sufficient documentation to demonstrate the compliance of its eligibility determinations or allocations to schools in a timely manner. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that documentation regarding eligibility determinations and allocations is retained and filed in an organized manner that is made readily available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all documentation regarding eligibility determinations and allocations to schools. The documentation should be filed in an organized manner and should be readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required documentation is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 2023-005: Affirmation of Consultation Forms to Private Schools Compliance Requirement: Special Tests and Provisions Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide equitable services to eligible private school children, their teachers, and their families. Grantees must conduct timely and meaningful consultation with private school officials to determine the kind of educational services to provide to eligible private school children. Grantees must also ensure that planned services are provided and that the required amount was used for private school children. Condition: The City was required to ensure that a portion of this grant was available for the equitable participation of students, families, and educators in non-profit, non-public (private) schools. Public school officials were required to initiate contact and make good faith efforts to have timely and meaningful consultation with private school officials regarding participation in programs and services. The City was also required to document these consultations via signed Affirmation of Consultation forms. The supporting documentation was not available upon request and was not provided in a timely manner. The information required to perform this testing was requested in May 2023, and was not provided until January 2024, after several repeated requests were made throughout that time. Context: The City did not provide sufficient documentation to demonstrate compliance with its requirement to conduct timely and meaningful consultations with officials from eligible private schools in a timely manner. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that the required consultations with private schools take place and that the consultations performed are adequately documented, retained and filed in an organized manner that is made readily available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all required forms. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that timely consultations with private schools occur, and that the required documentation is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 2023-005: Affirmation of Consultation Forms to Private Schools Compliance Requirement: Special Tests and Provisions Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide equitable services to eligible private school children, their teachers, and their families. Grantees must conduct timely and meaningful consultation with private school officials to determine the kind of educational services to provide to eligible private school children. Grantees must also ensure that planned services are provided and that the required amount was used for private school children. Condition: The City was required to ensure that a portion of this grant was available for the equitable participation of students, families, and educators in non-profit, non-public (private) schools. Public school officials were required to initiate contact and make good faith efforts to have timely and meaningful consultation with private school officials regarding participation in programs and services. The City was also required to document these consultations via signed Affirmation of Consultation forms. The supporting documentation was not available upon request and was not provided in a timely manner. The information required to perform this testing was requested in May 2023, and was not provided until January 2024, after several repeated requests were made throughout that time. Context: The City did not provide sufficient documentation to demonstrate compliance with its requirement to conduct timely and meaningful consultations with officials from eligible private schools in a timely manner. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that the required consultations with private schools take place and that the consultations performed are adequately documented, retained and filed in an organized manner that is made readily available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all required forms. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that timely consultations with private schools occur, and that the required documentation is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 2023-005: Affirmation of Consultation Forms to Private Schools Compliance Requirement: Special Tests and Provisions Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide equitable services to eligible private school children, their teachers, and their families. Grantees must conduct timely and meaningful consultation with private school officials to determine the kind of educational services to provide to eligible private school children. Grantees must also ensure that planned services are provided and that the required amount was used for private school children. Condition: The City was required to ensure that a portion of this grant was available for the equitable participation of students, families, and educators in non-profit, non-public (private) schools. Public school officials were required to initiate contact and make good faith efforts to have timely and meaningful consultation with private school officials regarding participation in programs and services. The City was also required to document these consultations via signed Affirmation of Consultation forms. The supporting documentation was not available upon request and was not provided in a timely manner. The information required to perform this testing was requested in May 2023, and was not provided until January 2024, after several repeated requests were made throughout that time. Context: The City did not provide sufficient documentation to demonstrate compliance with its requirement to conduct timely and meaningful consultations with officials from eligible private schools in a timely manner. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that the required consultations with private schools take place and that the consultations performed are adequately documented, retained and filed in an organized manner that is made readily available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all required forms. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that timely consultations with private schools occur, and that the required documentation is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 2023-005: Affirmation of Consultation Forms to Private Schools Compliance Requirement: Special Tests and Provisions Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide equitable services to eligible private school children, their teachers, and their families. Grantees must conduct timely and meaningful consultation with private school officials to determine the kind of educational services to provide to eligible private school children. Grantees must also ensure that planned services are provided and that the required amount was used for private school children. Condition: The City was required to ensure that a portion of this grant was available for the equitable participation of students, families, and educators in non-profit, non-public (private) schools. Public school officials were required to initiate contact and make good faith efforts to have timely and meaningful consultation with private school officials regarding participation in programs and services. The City was also required to document these consultations via signed Affirmation of Consultation forms. The supporting documentation was not available upon request and was not provided in a timely manner. The information required to perform this testing was requested in May 2023, and was not provided until January 2024, after several repeated requests were made throughout that time. Context: The City did not provide sufficient documentation to demonstrate compliance with its requirement to conduct timely and meaningful consultations with officials from eligible private schools in a timely manner. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that the required consultations with private schools take place and that the consultations performed are adequately documented, retained and filed in an organized manner that is made readily available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all required forms. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that timely consultations with private schools occur, and that the required documentation is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-006: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Education Stabilization Fund grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $3,487,658, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $440,173 for 83 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $440,173 of could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-003. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the education stabilization grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-006: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Education Stabilization Fund grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $3,487,658, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $440,173 for 83 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $440,173 of could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-003. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the education stabilization grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-006: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Education Stabilization Fund grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $3,487,658, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $440,173 for 83 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $440,173 of could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-003. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the education stabilization grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-006: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Education Stabilization Fund grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $3,487,658, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $440,173 for 83 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $440,173 of could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-003. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the education stabilization grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-006: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Education Stabilization Fund grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $3,487,658, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $440,173 for 83 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $440,173 of could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-003. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the education stabilization grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-006: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Education Stabilization Fund grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $3,487,658, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $440,173 for 83 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $440,173 of could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-003. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the education stabilization grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-006: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Education Stabilization Fund grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $3,487,658, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $440,173 for 83 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $440,173 of could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-003. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the education stabilization grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-006: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Education Stabilization Fund grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2023 totaled $3,487,658, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $440,173 for 83 employees paid out of the grant during those pay periods. From the pay periods selected for testing, $440,173 of could not be substantiated through time and effort reports or any similar internal control process. Repeat Finding: This matter was reported as a finding in the previous year as finding 2022-003. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the education stabilization grant for 2024, as well as into future periods.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-007: Controls for the Purchase of Capital Equipment Compliance Requirement: Equipment/Real Property Management Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must obtain prior approval from the pass-through entity for capital expenditures related to general and special purpose equipment purchases. Condition: The City was required to obtain prior approval from the pass-through entity for capital expenditures related to general or special purpose equipment. The City purchased security camera equipment and was unable to provide evidence that prior approval was obtained. Context: The City did not maintain sufficient documentation to demonstrate that approval was obtained prior to the purchase of capital equipment. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that approval is obtained prior to the purchase of capital equipment and that documentation of the approval is retained. Questioned Costs: The City expended a total of $4,564,014 in Education Stabilization Funds in 2023, of which $619,967 was charged to a contract services account. Of the total charged to the contract services account, $302,687 was selected for testing and $73,629 was spent on the purchase of security camera equipment without prior approval from the pass-through entity. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the need to obtain prior approval from the pass-through entity for capital expenditures paid from the Education Stabilization Funds grants. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required approvals are obtained and the documentation is maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-007: Controls for the Purchase of Capital Equipment Compliance Requirement: Equipment/Real Property Management Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must obtain prior approval from the pass-through entity for capital expenditures related to general and special purpose equipment purchases. Condition: The City was required to obtain prior approval from the pass-through entity for capital expenditures related to general or special purpose equipment. The City purchased security camera equipment and was unable to provide evidence that prior approval was obtained. Context: The City did not maintain sufficient documentation to demonstrate that approval was obtained prior to the purchase of capital equipment. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that approval is obtained prior to the purchase of capital equipment and that documentation of the approval is retained. Questioned Costs: The City expended a total of $4,564,014 in Education Stabilization Funds in 2023, of which $619,967 was charged to a contract services account. Of the total charged to the contract services account, $302,687 was selected for testing and $73,629 was spent on the purchase of security camera equipment without prior approval from the pass-through entity. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the need to obtain prior approval from the pass-through entity for capital expenditures paid from the Education Stabilization Funds grants. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required approvals are obtained and the documentation is maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-007: Controls for the Purchase of Capital Equipment Compliance Requirement: Equipment/Real Property Management Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must obtain prior approval from the pass-through entity for capital expenditures related to general and special purpose equipment purchases. Condition: The City was required to obtain prior approval from the pass-through entity for capital expenditures related to general or special purpose equipment. The City purchased security camera equipment and was unable to provide evidence that prior approval was obtained. Context: The City did not maintain sufficient documentation to demonstrate that approval was obtained prior to the purchase of capital equipment. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that approval is obtained prior to the purchase of capital equipment and that documentation of the approval is retained. Questioned Costs: The City expended a total of $4,564,014 in Education Stabilization Funds in 2023, of which $619,967 was charged to a contract services account. Of the total charged to the contract services account, $302,687 was selected for testing and $73,629 was spent on the purchase of security camera equipment without prior approval from the pass-through entity. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the need to obtain prior approval from the pass-through entity for capital expenditures paid from the Education Stabilization Funds grants. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required approvals are obtained and the documentation is maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-007: Controls for the Purchase of Capital Equipment Compliance Requirement: Equipment/Real Property Management Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must obtain prior approval from the pass-through entity for capital expenditures related to general and special purpose equipment purchases. Condition: The City was required to obtain prior approval from the pass-through entity for capital expenditures related to general or special purpose equipment. The City purchased security camera equipment and was unable to provide evidence that prior approval was obtained. Context: The City did not maintain sufficient documentation to demonstrate that approval was obtained prior to the purchase of capital equipment. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that approval is obtained prior to the purchase of capital equipment and that documentation of the approval is retained. Questioned Costs: The City expended a total of $4,564,014 in Education Stabilization Funds in 2023, of which $619,967 was charged to a contract services account. Of the total charged to the contract services account, $302,687 was selected for testing and $73,629 was spent on the purchase of security camera equipment without prior approval from the pass-through entity. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the need to obtain prior approval from the pass-through entity for capital expenditures paid from the Education Stabilization Funds grants. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required approvals are obtained and the documentation is maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-007: Controls for the Purchase of Capital Equipment Compliance Requirement: Equipment/Real Property Management Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must obtain prior approval from the pass-through entity for capital expenditures related to general and special purpose equipment purchases. Condition: The City was required to obtain prior approval from the pass-through entity for capital expenditures related to general or special purpose equipment. The City purchased security camera equipment and was unable to provide evidence that prior approval was obtained. Context: The City did not maintain sufficient documentation to demonstrate that approval was obtained prior to the purchase of capital equipment. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that approval is obtained prior to the purchase of capital equipment and that documentation of the approval is retained. Questioned Costs: The City expended a total of $4,564,014 in Education Stabilization Funds in 2023, of which $619,967 was charged to a contract services account. Of the total charged to the contract services account, $302,687 was selected for testing and $73,629 was spent on the purchase of security camera equipment without prior approval from the pass-through entity. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the need to obtain prior approval from the pass-through entity for capital expenditures paid from the Education Stabilization Funds grants. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required approvals are obtained and the documentation is maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-007: Controls for the Purchase of Capital Equipment Compliance Requirement: Equipment/Real Property Management Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must obtain prior approval from the pass-through entity for capital expenditures related to general and special purpose equipment purchases. Condition: The City was required to obtain prior approval from the pass-through entity for capital expenditures related to general or special purpose equipment. The City purchased security camera equipment and was unable to provide evidence that prior approval was obtained. Context: The City did not maintain sufficient documentation to demonstrate that approval was obtained prior to the purchase of capital equipment. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that approval is obtained prior to the purchase of capital equipment and that documentation of the approval is retained. Questioned Costs: The City expended a total of $4,564,014 in Education Stabilization Funds in 2023, of which $619,967 was charged to a contract services account. Of the total charged to the contract services account, $302,687 was selected for testing and $73,629 was spent on the purchase of security camera equipment without prior approval from the pass-through entity. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the need to obtain prior approval from the pass-through entity for capital expenditures paid from the Education Stabilization Funds grants. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required approvals are obtained and the documentation is maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-007: Controls for the Purchase of Capital Equipment Compliance Requirement: Equipment/Real Property Management Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must obtain prior approval from the pass-through entity for capital expenditures related to general and special purpose equipment purchases. Condition: The City was required to obtain prior approval from the pass-through entity for capital expenditures related to general or special purpose equipment. The City purchased security camera equipment and was unable to provide evidence that prior approval was obtained. Context: The City did not maintain sufficient documentation to demonstrate that approval was obtained prior to the purchase of capital equipment. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that approval is obtained prior to the purchase of capital equipment and that documentation of the approval is retained. Questioned Costs: The City expended a total of $4,564,014 in Education Stabilization Funds in 2023, of which $619,967 was charged to a contract services account. Of the total charged to the contract services account, $302,687 was selected for testing and $73,629 was spent on the purchase of security camera equipment without prior approval from the pass-through entity. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the need to obtain prior approval from the pass-through entity for capital expenditures paid from the Education Stabilization Funds grants. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required approvals are obtained and the documentation is maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-007: Controls for the Purchase of Capital Equipment Compliance Requirement: Equipment/Real Property Management Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must obtain prior approval from the pass-through entity for capital expenditures related to general and special purpose equipment purchases. Condition: The City was required to obtain prior approval from the pass-through entity for capital expenditures related to general or special purpose equipment. The City purchased security camera equipment and was unable to provide evidence that prior approval was obtained. Context: The City did not maintain sufficient documentation to demonstrate that approval was obtained prior to the purchase of capital equipment. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure that approval is obtained prior to the purchase of capital equipment and that documentation of the approval is retained. Questioned Costs: The City expended a total of $4,564,014 in Education Stabilization Funds in 2023, of which $619,967 was charged to a contract services account. Of the total charged to the contract services account, $302,687 was selected for testing and $73,629 was spent on the purchase of security camera equipment without prior approval from the pass-through entity. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the need to obtain prior approval from the pass-through entity for capital expenditures paid from the Education Stabilization Funds grants. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required approvals are obtained and the documentation is maintained in an organized manner. Management plans to implement these procedures in 2024.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-008: Reporting to the State Compliance Requirement: Reporting Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must comply with reporting requirements established by the Massachusetts Department of Elementary and Secondary Education, the City’s Pass-Through Grantor (State). In order for the State to comply with federal reporting requirements, the City is required to submit complete and accurate “Recipient Data Collection Forms” to the State. Condition: The City was unable to provide copies of the Recipient Data Collection Forms submitted to the State. Context: The City did not maintain sufficient documentation to demonstrate compliance with grant reporting requirements. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure and demonstrate that required reporting is completed, retained, and available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all required reports. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required reporting is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.   D. Summary Schedule of Prior Audit Findings and Questioned Costs 2022-001: Controls for Monitoring Payroll Charged to the Grant Condition and Criteria: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City did not maintain sufficient supporting documentation to demonstrate compliance with federal and state time and effort reporting requirements. Recommendation: The City should implement procedures to ensure compliance with all grant requirements. Current Status: It was anticipated that the recommendation would be implemented in 2023, however this did not occur. This matter has been reported in finding 2023-002.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-008: Reporting to the State Compliance Requirement: Reporting Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must comply with reporting requirements established by the Massachusetts Department of Elementary and Secondary Education, the City’s Pass-Through Grantor (State). In order for the State to comply with federal reporting requirements, the City is required to submit complete and accurate “Recipient Data Collection Forms” to the State. Condition: The City was unable to provide copies of the Recipient Data Collection Forms submitted to the State. Context: The City did not maintain sufficient documentation to demonstrate compliance with grant reporting requirements. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure and demonstrate that required reporting is completed, retained, and available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all required reports. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required reporting is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.   D. Summary Schedule of Prior Audit Findings and Questioned Costs 2022-001: Controls for Monitoring Payroll Charged to the Grant Condition and Criteria: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City did not maintain sufficient supporting documentation to demonstrate compliance with federal and state time and effort reporting requirements. Recommendation: The City should implement procedures to ensure compliance with all grant requirements. Current Status: It was anticipated that the recommendation would be implemented in 2023, however this did not occur. This matter has been reported in finding 2023-002.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-008: Reporting to the State Compliance Requirement: Reporting Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must comply with reporting requirements established by the Massachusetts Department of Elementary and Secondary Education, the City’s Pass-Through Grantor (State). In order for the State to comply with federal reporting requirements, the City is required to submit complete and accurate “Recipient Data Collection Forms” to the State. Condition: The City was unable to provide copies of the Recipient Data Collection Forms submitted to the State. Context: The City did not maintain sufficient documentation to demonstrate compliance with grant reporting requirements. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure and demonstrate that required reporting is completed, retained, and available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all required reports. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required reporting is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.   D. Summary Schedule of Prior Audit Findings and Questioned Costs 2022-001: Controls for Monitoring Payroll Charged to the Grant Condition and Criteria: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City did not maintain sufficient supporting documentation to demonstrate compliance with federal and state time and effort reporting requirements. Recommendation: The City should implement procedures to ensure compliance with all grant requirements. Current Status: It was anticipated that the recommendation would be implemented in 2023, however this did not occur. This matter has been reported in finding 2023-002.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-008: Reporting to the State Compliance Requirement: Reporting Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must comply with reporting requirements established by the Massachusetts Department of Elementary and Secondary Education, the City’s Pass-Through Grantor (State). In order for the State to comply with federal reporting requirements, the City is required to submit complete and accurate “Recipient Data Collection Forms” to the State. Condition: The City was unable to provide copies of the Recipient Data Collection Forms submitted to the State. Context: The City did not maintain sufficient documentation to demonstrate compliance with grant reporting requirements. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure and demonstrate that required reporting is completed, retained, and available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all required reports. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required reporting is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.   D. Summary Schedule of Prior Audit Findings and Questioned Costs 2022-001: Controls for Monitoring Payroll Charged to the Grant Condition and Criteria: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City did not maintain sufficient supporting documentation to demonstrate compliance with federal and state time and effort reporting requirements. Recommendation: The City should implement procedures to ensure compliance with all grant requirements. Current Status: It was anticipated that the recommendation would be implemented in 2023, however this did not occur. This matter has been reported in finding 2023-002.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-008: Reporting to the State Compliance Requirement: Reporting Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must comply with reporting requirements established by the Massachusetts Department of Elementary and Secondary Education, the City’s Pass-Through Grantor (State). In order for the State to comply with federal reporting requirements, the City is required to submit complete and accurate “Recipient Data Collection Forms” to the State. Condition: The City was unable to provide copies of the Recipient Data Collection Forms submitted to the State. Context: The City did not maintain sufficient documentation to demonstrate compliance with grant reporting requirements. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure and demonstrate that required reporting is completed, retained, and available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all required reports. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required reporting is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.   D. Summary Schedule of Prior Audit Findings and Questioned Costs 2022-001: Controls for Monitoring Payroll Charged to the Grant Condition and Criteria: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City did not maintain sufficient supporting documentation to demonstrate compliance with federal and state time and effort reporting requirements. Recommendation: The City should implement procedures to ensure compliance with all grant requirements. Current Status: It was anticipated that the recommendation would be implemented in 2023, however this did not occur. This matter has been reported in finding 2023-002.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-008: Reporting to the State Compliance Requirement: Reporting Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must comply with reporting requirements established by the Massachusetts Department of Elementary and Secondary Education, the City’s Pass-Through Grantor (State). In order for the State to comply with federal reporting requirements, the City is required to submit complete and accurate “Recipient Data Collection Forms” to the State. Condition: The City was unable to provide copies of the Recipient Data Collection Forms submitted to the State. Context: The City did not maintain sufficient documentation to demonstrate compliance with grant reporting requirements. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure and demonstrate that required reporting is completed, retained, and available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all required reports. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required reporting is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.   D. Summary Schedule of Prior Audit Findings and Questioned Costs 2022-001: Controls for Monitoring Payroll Charged to the Grant Condition and Criteria: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City did not maintain sufficient supporting documentation to demonstrate compliance with federal and state time and effort reporting requirements. Recommendation: The City should implement procedures to ensure compliance with all grant requirements. Current Status: It was anticipated that the recommendation would be implemented in 2023, however this did not occur. This matter has been reported in finding 2023-002.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-008: Reporting to the State Compliance Requirement: Reporting Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must comply with reporting requirements established by the Massachusetts Department of Elementary and Secondary Education, the City’s Pass-Through Grantor (State). In order for the State to comply with federal reporting requirements, the City is required to submit complete and accurate “Recipient Data Collection Forms” to the State. Condition: The City was unable to provide copies of the Recipient Data Collection Forms submitted to the State. Context: The City did not maintain sufficient documentation to demonstrate compliance with grant reporting requirements. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure and demonstrate that required reporting is completed, retained, and available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all required reports. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required reporting is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.   D. Summary Schedule of Prior Audit Findings and Questioned Costs 2022-001: Controls for Monitoring Payroll Charged to the Grant Condition and Criteria: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City did not maintain sufficient supporting documentation to demonstrate compliance with federal and state time and effort reporting requirements. Recommendation: The City should implement procedures to ensure compliance with all grant requirements. Current Status: It was anticipated that the recommendation would be implemented in 2023, however this did not occur. This matter has been reported in finding 2023-002.

U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2023-008: Reporting to the State Compliance Requirement: Reporting Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must comply with reporting requirements established by the Massachusetts Department of Elementary and Secondary Education, the City’s Pass-Through Grantor (State). In order for the State to comply with federal reporting requirements, the City is required to submit complete and accurate “Recipient Data Collection Forms” to the State. Condition: The City was unable to provide copies of the Recipient Data Collection Forms submitted to the State. Context: The City did not maintain sufficient documentation to demonstrate compliance with grant reporting requirements. Effect: The City has not complied with the grant requirements. Cause: Management has not established guidelines and procedures to ensure and demonstrate that required reporting is completed, retained, and available for inspection during the audit. Questioned Costs: None reported. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all required reports. The documentation should be filed in an organized manner and readily available for inspection during the audit. Views of Responsible Officials and Planned Corrective Actions: The School District will implement internal control procedures to ensure that the required reporting is completed, retained and maintained in an organized manner. Management plans to implement these procedures in 2024.   D. Summary Schedule of Prior Audit Findings and Questioned Costs 2022-001: Controls for Monitoring Payroll Charged to the Grant Condition and Criteria: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City did not maintain sufficient supporting documentation to demonstrate compliance with federal and state time and effort reporting requirements. Recommendation: The City should implement procedures to ensure compliance with all grant requirements. Current Status: It was anticipated that the recommendation would be implemented in 2023, however this did not occur. This matter has been reported in finding 2023-002.