Audit 31438

Program: U.S. DEPARTMENT OF EDUCATION Passed through the Commonwealth of Massachusetts?Department of Elementary and Secondary Education Special Education Cluster ? SPED Grants to States, IDEA, Part B (CFDA #84.027) Pass-through program number: 240-534231-2022-0660 Criteria: Established internal controls surrounding documentation of federal award compliance requirements should ensure that all charges to Federal awards for salaries and wages are based on records that accurately reflect the work performed. Accordingly, time and effort documentation are required to be maintained which clearly documents ?after-the -fact? determinations of amounts for which individuals have worked on the federal program. These records should ensure that individuals working on federal programs and the appropriate supervisory personnel, attest to the actual time individuals spend on the program. Budgetary allocations of the time should be consistent with grant programs, actual work, and established methodologies throughout the entity. Federal guidelines require these records are to be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition and Context: During the current year audit, we noted (2) individuals of the (7) individuals tested of the approximate population of (20) charged to the program for which complete time and effort certifications were not available for review. One of the individuals? certifications for the entire fiscal year were unavailable; the other individual?s certifications for the remaining four months of the year were unavailable. Both of these individuals retired at the end of the fiscal year. Cause: The District has yet to implement formalized grant administration policies and procedures to ensure all requirements of federal programs are formally documented as to applicability of each program?s compliance requirement and formal review and monitoring as to the District?s compliance with each throughout the fiscal year. Effect: Lack of documentation of internal controls policies and procedures that are routinely followed may lead to situations where ?time and effort? certifications, as well as other grant compliance requirements may not be met in a timely manner. Accordingly, potential unallowed costs may be present. Questioned Costs: Total salaries estimated for the months for which time & effort certifications were not on file for the aforementioned individuals was approximately $21,000. Perspective Information: This was a finding reported in fiscal year 2020 (2020-001). The District began to enhance its overall maintenance of certain time & effort certifications subsequently. However, the District has yet to implement more formalized grant administration and compliance policies and procedures as recommended by OMB. Auditor?s Recommendation: The District should establish a formalized grants policy and procedures manual which addresses OMB Uniform guidance and federal compliance requirements. Current internal control policies and procedures should be reviewed to ensure all documentation for ?after-the-fact? time and effort certifications are obtained and maintained on file in a timely manner. View of Responsible Official and Planned Corrective Action: The District will enhance the documentation surrounding aspects of Grant compliance and monitoring as well as adoption and implementation of formalized policies and procedures.

Other Matters: Finding No. 2022-002 Recommend enhancement of formalized documentation surrounding grant compliance and filing in accordance with OMB requirements. Criteria: Implementation of the Uniform Guidance highlighted the importance and requirement for grantees to maintain internal control policies and procedures surrounding the compliance and administration of federal grants, focusing on clearly defining the key components (control environment, risk assessment, control activities, information and communication, monitoring). This should include timely maintenance of documentation for completion of the schedule of expenditures of federal awards (SEFA) and completion of the Single Audit within nine months after year end. Condition: The District has yet to fully formalize documentation of all aspects of internal control surrounding grant compliance and administration as recommended by federal guidelines. Documentation of policies and procedures over grant compliance is currently in draft form and has yet to be fully implemented. Moreover, the District was not timely in the certain documentation and responses for the audit to be completed within the required timeframe. Effect: Lack of documentation of internal controls policies and procedures may lead to situations of noncompliance with federal requirements. In the current year, the District was unable to have the audit completed within the nine-month requirement. Perspective Information: The portion of the finding related to formalized policies and procedures was previously reported in the prior year?s audit report as finding in the prior years (2021-001; 2020-003; 2019-004). The submission deadline finding was new in the current year. Questioned Costs: None. Auditor?s Recommendation: We continue to recommend the District establish comprehensive grants management policies and procedures and further enhance the documentation surrounding aspects of grant compliance. The District should ensure all documentation related to the audit, including preparation of the SEFA, is prepared in a timely manner in order to ensure required deadlines are met. View of Responsible Official and Planned Corrective Action: The District will enhance the documentation surrounding aspects of Grant compliance and formalize the documentation for approval by the School Committee. The District anticipates completion of future audits within the Single Audit deadline.

Program: U.S. DEPARTMENT OF EDUCATION Passed through the Commonwealth of Massachusetts?Department of Elementary and Secondary Education Special Education Cluster ? SPED Grants to States, IDEA, Part B (CFDA #84.027) Pass-through program number: 240-534231-2022-0660 Criteria: Established internal controls surrounding documentation of federal award compliance requirements should ensure that all charges to Federal awards for salaries and wages are based on records that accurately reflect the work performed. Accordingly, time and effort documentation are required to be maintained which clearly documents ?after-the -fact? determinations of amounts for which individuals have worked on the federal program. These records should ensure that individuals working on federal programs and the appropriate supervisory personnel, attest to the actual time individuals spend on the program. Budgetary allocations of the time should be consistent with grant programs, actual work, and established methodologies throughout the entity. Federal guidelines require these records are to be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition and Context: During the current year audit, we noted (2) individuals of the (7) individuals tested of the approximate population of (20) charged to the program for which complete time and effort certifications were not available for review. One of the individuals? certifications for the entire fiscal year were unavailable; the other individual?s certifications for the remaining four months of the year were unavailable. Both of these individuals retired at the end of the fiscal year. Cause: The District has yet to implement formalized grant administration policies and procedures to ensure all requirements of federal programs are formally documented as to applicability of each program?s compliance requirement and formal review and monitoring as to the District?s compliance with each throughout the fiscal year. Effect: Lack of documentation of internal controls policies and procedures that are routinely followed may lead to situations where ?time and effort? certifications, as well as other grant compliance requirements may not be met in a timely manner. Accordingly, potential unallowed costs may be present. Questioned Costs: Total salaries estimated for the months for which time & effort certifications were not on file for the aforementioned individuals was approximately $21,000. Perspective Information: This was a finding reported in fiscal year 2020 (2020-001). The District began to enhance its overall maintenance of certain time & effort certifications subsequently. However, the District has yet to implement more formalized grant administration and compliance policies and procedures as recommended by OMB. Auditor?s Recommendation: The District should establish a formalized grants policy and procedures manual which addresses OMB Uniform guidance and federal compliance requirements. Current internal control policies and procedures should be reviewed to ensure all documentation for ?after-the-fact? time and effort certifications are obtained and maintained on file in a timely manner. View of Responsible Official and Planned Corrective Action: The District will enhance the documentation surrounding aspects of Grant compliance and monitoring as well as adoption and implementation of formalized policies and procedures.

Other Matters: Finding No. 2022-002 Recommend enhancement of formalized documentation surrounding grant compliance and filing in accordance with OMB requirements. Criteria: Implementation of the Uniform Guidance highlighted the importance and requirement for grantees to maintain internal control policies and procedures surrounding the compliance and administration of federal grants, focusing on clearly defining the key components (control environment, risk assessment, control activities, information and communication, monitoring). This should include timely maintenance of documentation for completion of the schedule of expenditures of federal awards (SEFA) and completion of the Single Audit within nine months after year end. Condition: The District has yet to fully formalize documentation of all aspects of internal control surrounding grant compliance and administration as recommended by federal guidelines. Documentation of policies and procedures over grant compliance is currently in draft form and has yet to be fully implemented. Moreover, the District was not timely in the certain documentation and responses for the audit to be completed within the required timeframe. Effect: Lack of documentation of internal controls policies and procedures may lead to situations of noncompliance with federal requirements. In the current year, the District was unable to have the audit completed within the nine-month requirement. Perspective Information: The portion of the finding related to formalized policies and procedures was previously reported in the prior year?s audit report as finding in the prior years (2021-001; 2020-003; 2019-004). The submission deadline finding was new in the current year. Questioned Costs: None. Auditor?s Recommendation: We continue to recommend the District establish comprehensive grants management policies and procedures and further enhance the documentation surrounding aspects of grant compliance. The District should ensure all documentation related to the audit, including preparation of the SEFA, is prepared in a timely manner in order to ensure required deadlines are met. View of Responsible Official and Planned Corrective Action: The District will enhance the documentation surrounding aspects of Grant compliance and formalize the documentation for approval by the School Committee. The District anticipates completion of future audits within the Single Audit deadline.