Finding 2022-001 – Special Education Cluster – AL No.’s 84.027 & 84.173
Department of Education
Massachusetts Department of Elementary and Secondary Education
Massachusetts Department of Early Education and Care
Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Programs
Criteria: 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 the applicable cost principles. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis.
Condition and Context: Control deficiencies related to disbursements were noted as a result of the testing of internal controls over payroll. Specifically, a sample of payroll disbursements charged to the programs were tested in order to determine if adequate internal controls were in place. As a result of the testing of payroll disbursements charged to the programs, all of the employees tested were found to not have adequately approved employee payroll rate agreements.
Cause: Weaknesses in the design and operation of controls.
Effect or Potential Effect: Due to the weaknesses in internal controls noted above, there is a risk of inappropriate salaries and wages being paid.
Identification as a Repeat Finding: Yes, finding number 2021-001
Questioned Costs: Questioned costs are reported equal to $256,796, calculated as payroll charged to the programs.
Recommendation: The Town should improve internal controls over Activities Allowed/Allowable Costs by ensuring employee’s payroll rate agreements are approved by an appropriate level of management and in a timely manner.
Managements Response: Though we believe that Finding 2021-001occured due to staff turnover at the time of the rate agreement approval, the Town and the Schools will assure federal awards are expended only for allowable activities. Consistent with State and Federal requirements and as in Acushnet’s updated Federal Grant Procedures Manual (February 2023), the Town will maintain source documentation (invoices, time sheets, payroll stubs, etc.) – including approved payroll rate agreements – that support federal expenditures.
Finding 2022-002 – Special Education Cluster – AL No.’s 84.027 & 84.173
Department of Education
Massachusetts Department of Elementary and Secondary Education
Massachusetts Department of Early Education and Care
Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Programs
Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. As governmental subrecipients of states are also required to use the same state procurement policies and procedures for federal funds as for non‐federal funds, the Town is required to follow Massachusetts General Laws, Chapter (MGL) 30(b). MGL 30(b) requires the solicitation of three written or oral quotes for procurements of supplies between $10,000 and $49,999 and sealed bids or proposals for procurements of supplies $50,000 and over. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis.
Condition and Context: During fiscal year 2022, the Town did not comply with the required procurement policies and procedures process for procurements that exceeded both State and Federal thresholds.
Questioned Costs: Unkown
Cause: Weaknesses in the design and operation of controls.
Effect or Potential Effect: Due to the weaknesses in internal controls noted above, there is a risk that amounts charged to federal awards may not be in accordance with procurement, suspension, and debarment principles. No known questioned costs are reported, as it is not quantifiable.
Identification as a Repeat Finding: Yes, finding number 2021-002
Recommendation: The Town should address the weaknesses in internal controls noted above in order to ensure that procurements are conducted in accordance with federal and state requirements.
Managements Response: The Town and Schools have Acushnet’s Federal Grant Procedures Manual (February 2023) to ensure that procurements are conducted in accordance with Federal and State requirements – in particular, the procurement standards set out at 2 CFR sections 200.318 through 200.326
Finding 2022-003 – Special Education Cluster – AL No.’s 84.027 & 84.173
Department of Education
Massachusetts Department of Elementary and Secondary Education
Massachusetts Department of Early Education and Care
Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program
Criteria: Where employees work solely or partially on a single Federal program or cost objective, their salaries or wages must be supported by periodic certification that the employee worked on these programs for the period covered by the programs. The certifications should be prepared at least semi-annually, and should be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee.
Condition: During our test of controls over compliance with time and effort certifications the school department was not able to provide evidence that required certifications of time and effort for those employees whose time was spent either completely or partially spent on these programs were performed as required by Uniform Guidance.
Questioned Costs: Unknown
Context: During our test of payroll transactions of the SPED PL 94-142 grants it was noted that the time and effort certifications were not completed for the employees tested.
Effect: The School Department was not in compliance with the time and effort certification requirements.
Cause: Staffing turnover in the financial department lead to weakened standard procedures/protocols by inexperienced (temporary) staffing.
Identification as a Repeat Finding: N/A
Recommendation: We recommend the School Department follow procedures to ensure that semi-annual certifications and/or monthly certifications are prepared and signed by either the employees and/or supervisory official having first-hand knowledge of the work performed by the employees in a timely manner in order to comply with the time and effort certification requirement.
Management Response: As required, the School Department ensures that semi-annual certifications and/or monthly certifications are prepared and signed by either the employees and/or supervisory official having first-hand knowledge of the work performed by the employees in a timely manner in order to comply with the time and effort certification requirement. Certifications are filed in grant folders and employee personnel files.
Finding 2022-004 – Special Education Cluster – AL No.’s 84.027 & 84.173
Department of Education
Massachusetts Department of Elementary and Secondary Education
Massachusetts Department of Early Education and Care
Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Programs
Criteria: The Period of Availability for the SPED PL 94-142 Grant was September 29, 2021 through September 30, 2023.
Condition: During our test of controls over compliance it was noted that there are expenditures charged to the SPED PL 94-142 Grant (September 29, 2021 through September 30, 2023) for services outside of the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education.
Context: During our test of expenditures and review of the general ledger against the SPED PL 94-142 Grant as it is related to compliance it was noted that the first payroll charged to the grant were for services prior to the grant start date of September 29, 2021 and thus would be outside the period of performance and thus would not be allowable costs.
Effect: The School Department was not in compliance with the period of performance requirement as set forth by the Massachusetts Department of Elementary and Secondary Education.
Questioned Costs: Questioned costs for the first payroll charged to the grant whose service period was prior to the grant start date of September 29, 2021 was $7,249.98.
Cause: Staffing turnover in the financial department lead to weakened standard procedures/protocols by inexperienced (temporary) staffing.
Recommendation: We recommend the School Department follow procedures to ensure that expenditures charged to the grant are within the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education.
Managements Response: The School Department ensures that expenditures charged to the grant only once approved and within the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education (DESE). Accounting codes are not set up for individual grants until final approval from DESE.
Finding 2022-001 – Special Education Cluster – AL No.’s 84.027 & 84.173
Department of Education
Massachusetts Department of Elementary and Secondary Education
Massachusetts Department of Early Education and Care
Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Programs
Criteria: 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 the applicable cost principles. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis.
Condition and Context: Control deficiencies related to disbursements were noted as a result of the testing of internal controls over payroll. Specifically, a sample of payroll disbursements charged to the programs were tested in order to determine if adequate internal controls were in place. As a result of the testing of payroll disbursements charged to the programs, all of the employees tested were found to not have adequately approved employee payroll rate agreements.
Cause: Weaknesses in the design and operation of controls.
Effect or Potential Effect: Due to the weaknesses in internal controls noted above, there is a risk of inappropriate salaries and wages being paid.
Identification as a Repeat Finding: Yes, finding number 2021-001
Questioned Costs: Questioned costs are reported equal to $256,796, calculated as payroll charged to the programs.
Recommendation: The Town should improve internal controls over Activities Allowed/Allowable Costs by ensuring employee’s payroll rate agreements are approved by an appropriate level of management and in a timely manner.
Managements Response: Though we believe that Finding 2021-001occured due to staff turnover at the time of the rate agreement approval, the Town and the Schools will assure federal awards are expended only for allowable activities. Consistent with State and Federal requirements and as in Acushnet’s updated Federal Grant Procedures Manual (February 2023), the Town will maintain source documentation (invoices, time sheets, payroll stubs, etc.) – including approved payroll rate agreements – that support federal expenditures.
Finding 2022-002 – Special Education Cluster – AL No.’s 84.027 & 84.173
Department of Education
Massachusetts Department of Elementary and Secondary Education
Massachusetts Department of Early Education and Care
Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Programs
Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. As governmental subrecipients of states are also required to use the same state procurement policies and procedures for federal funds as for non‐federal funds, the Town is required to follow Massachusetts General Laws, Chapter (MGL) 30(b). MGL 30(b) requires the solicitation of three written or oral quotes for procurements of supplies between $10,000 and $49,999 and sealed bids or proposals for procurements of supplies $50,000 and over. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis.
Condition and Context: During fiscal year 2022, the Town did not comply with the required procurement policies and procedures process for procurements that exceeded both State and Federal thresholds.
Questioned Costs: Unkown
Cause: Weaknesses in the design and operation of controls.
Effect or Potential Effect: Due to the weaknesses in internal controls noted above, there is a risk that amounts charged to federal awards may not be in accordance with procurement, suspension, and debarment principles. No known questioned costs are reported, as it is not quantifiable.
Identification as a Repeat Finding: Yes, finding number 2021-002
Recommendation: The Town should address the weaknesses in internal controls noted above in order to ensure that procurements are conducted in accordance with federal and state requirements.
Managements Response: The Town and Schools have Acushnet’s Federal Grant Procedures Manual (February 2023) to ensure that procurements are conducted in accordance with Federal and State requirements – in particular, the procurement standards set out at 2 CFR sections 200.318 through 200.326
Finding 2022-003 – Special Education Cluster – AL No.’s 84.027 & 84.173
Department of Education
Massachusetts Department of Elementary and Secondary Education
Massachusetts Department of Early Education and Care
Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program
Criteria: Where employees work solely or partially on a single Federal program or cost objective, their salaries or wages must be supported by periodic certification that the employee worked on these programs for the period covered by the programs. The certifications should be prepared at least semi-annually, and should be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee.
Condition: During our test of controls over compliance with time and effort certifications the school department was not able to provide evidence that required certifications of time and effort for those employees whose time was spent either completely or partially spent on these programs were performed as required by Uniform Guidance.
Questioned Costs: Unknown
Context: During our test of payroll transactions of the SPED PL 94-142 grants it was noted that the time and effort certifications were not completed for the employees tested.
Effect: The School Department was not in compliance with the time and effort certification requirements.
Cause: Staffing turnover in the financial department lead to weakened standard procedures/protocols by inexperienced (temporary) staffing.
Identification as a Repeat Finding: N/A
Recommendation: We recommend the School Department follow procedures to ensure that semi-annual certifications and/or monthly certifications are prepared and signed by either the employees and/or supervisory official having first-hand knowledge of the work performed by the employees in a timely manner in order to comply with the time and effort certification requirement.
Management Response: As required, the School Department ensures that semi-annual certifications and/or monthly certifications are prepared and signed by either the employees and/or supervisory official having first-hand knowledge of the work performed by the employees in a timely manner in order to comply with the time and effort certification requirement. Certifications are filed in grant folders and employee personnel files.
Finding 2022-001 – Special Education Cluster – AL No.’s 84.027 & 84.173
Department of Education
Massachusetts Department of Elementary and Secondary Education
Massachusetts Department of Early Education and Care
Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Programs
Criteria: 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 the applicable cost principles. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis.
Condition and Context: Control deficiencies related to disbursements were noted as a result of the testing of internal controls over payroll. Specifically, a sample of payroll disbursements charged to the programs were tested in order to determine if adequate internal controls were in place. As a result of the testing of payroll disbursements charged to the programs, all of the employees tested were found to not have adequately approved employee payroll rate agreements.
Cause: Weaknesses in the design and operation of controls.
Effect or Potential Effect: Due to the weaknesses in internal controls noted above, there is a risk of inappropriate salaries and wages being paid.
Identification as a Repeat Finding: Yes, finding number 2021-001
Questioned Costs: Questioned costs are reported equal to $256,796, calculated as payroll charged to the programs.
Recommendation: The Town should improve internal controls over Activities Allowed/Allowable Costs by ensuring employee’s payroll rate agreements are approved by an appropriate level of management and in a timely manner.
Managements Response: Though we believe that Finding 2021-001occured due to staff turnover at the time of the rate agreement approval, the Town and the Schools will assure federal awards are expended only for allowable activities. Consistent with State and Federal requirements and as in Acushnet’s updated Federal Grant Procedures Manual (February 2023), the Town will maintain source documentation (invoices, time sheets, payroll stubs, etc.) – including approved payroll rate agreements – that support federal expenditures.
Finding 2022-003 – Special Education Cluster – AL No.’s 84.027 & 84.173
Department of Education
Massachusetts Department of Elementary and Secondary Education
Massachusetts Department of Early Education and Care
Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program
Criteria: Where employees work solely or partially on a single Federal program or cost objective, their salaries or wages must be supported by periodic certification that the employee worked on these programs for the period covered by the programs. The certifications should be prepared at least semi-annually, and should be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee.
Condition: During our test of controls over compliance with time and effort certifications the school department was not able to provide evidence that required certifications of time and effort for those employees whose time was spent either completely or partially spent on these programs were performed as required by Uniform Guidance.
Questioned Costs: Unknown
Context: During our test of payroll transactions of the SPED PL 94-142 grants it was noted that the time and effort certifications were not completed for the employees tested.
Effect: The School Department was not in compliance with the time and effort certification requirements.
Cause: Staffing turnover in the financial department lead to weakened standard procedures/protocols by inexperienced (temporary) staffing.
Identification as a Repeat Finding: N/A
Recommendation: We recommend the School Department follow procedures to ensure that semi-annual certifications and/or monthly certifications are prepared and signed by either the employees and/or supervisory official having first-hand knowledge of the work performed by the employees in a timely manner in order to comply with the time and effort certification requirement.
Management Response: As required, the School Department ensures that semi-annual certifications and/or monthly certifications are prepared and signed by either the employees and/or supervisory official having first-hand knowledge of the work performed by the employees in a timely manner in order to comply with the time and effort certification requirement. Certifications are filed in grant folders and employee personnel files.
Finding 2022-001 – Special Education Cluster – AL No.’s 84.027 & 84.173
Department of Education
Massachusetts Department of Elementary and Secondary Education
Massachusetts Department of Early Education and Care
Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Programs
Criteria: 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 the applicable cost principles. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis.
Condition and Context: Control deficiencies related to disbursements were noted as a result of the testing of internal controls over payroll. Specifically, a sample of payroll disbursements charged to the programs were tested in order to determine if adequate internal controls were in place. As a result of the testing of payroll disbursements charged to the programs, all of the employees tested were found to not have adequately approved employee payroll rate agreements.
Cause: Weaknesses in the design and operation of controls.
Effect or Potential Effect: Due to the weaknesses in internal controls noted above, there is a risk of inappropriate salaries and wages being paid.
Identification as a Repeat Finding: Yes, finding number 2021-001
Questioned Costs: Questioned costs are reported equal to $256,796, calculated as payroll charged to the programs.
Recommendation: The Town should improve internal controls over Activities Allowed/Allowable Costs by ensuring employee’s payroll rate agreements are approved by an appropriate level of management and in a timely manner.
Managements Response: Though we believe that Finding 2021-001occured due to staff turnover at the time of the rate agreement approval, the Town and the Schools will assure federal awards are expended only for allowable activities. Consistent with State and Federal requirements and as in Acushnet’s updated Federal Grant Procedures Manual (February 2023), the Town will maintain source documentation (invoices, time sheets, payroll stubs, etc.) – including approved payroll rate agreements – that support federal expenditures.
Finding 2022-002 – Special Education Cluster – AL No.’s 84.027 & 84.173
Department of Education
Massachusetts Department of Elementary and Secondary Education
Massachusetts Department of Early Education and Care
Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Programs
Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. As governmental subrecipients of states are also required to use the same state procurement policies and procedures for federal funds as for non‐federal funds, the Town is required to follow Massachusetts General Laws, Chapter (MGL) 30(b). MGL 30(b) requires the solicitation of three written or oral quotes for procurements of supplies between $10,000 and $49,999 and sealed bids or proposals for procurements of supplies $50,000 and over. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis.
Condition and Context: During fiscal year 2022, the Town did not comply with the required procurement policies and procedures process for procurements that exceeded both State and Federal thresholds.
Questioned Costs: Unkown
Cause: Weaknesses in the design and operation of controls.
Effect or Potential Effect: Due to the weaknesses in internal controls noted above, there is a risk that amounts charged to federal awards may not be in accordance with procurement, suspension, and debarment principles. No known questioned costs are reported, as it is not quantifiable.
Identification as a Repeat Finding: Yes, finding number 2021-002
Recommendation: The Town should address the weaknesses in internal controls noted above in order to ensure that procurements are conducted in accordance with federal and state requirements.
Managements Response: The Town and Schools have Acushnet’s Federal Grant Procedures Manual (February 2023) to ensure that procurements are conducted in accordance with Federal and State requirements – in particular, the procurement standards set out at 2 CFR sections 200.318 through 200.326
Finding 2022-003 – Special Education Cluster – AL No.’s 84.027 & 84.173
Department of Education
Massachusetts Department of Elementary and Secondary Education
Massachusetts Department of Early Education and Care
Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program
Criteria: Where employees work solely or partially on a single Federal program or cost objective, their salaries or wages must be supported by periodic certification that the employee worked on these programs for the period covered by the programs. The certifications should be prepared at least semi-annually, and should be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee.
Condition: During our test of controls over compliance with time and effort certifications the school department was not able to provide evidence that required certifications of time and effort for those employees whose time was spent either completely or partially spent on these programs were performed as required by Uniform Guidance.
Questioned Costs: Unknown
Context: During our test of payroll transactions of the SPED PL 94-142 grants it was noted that the time and effort certifications were not completed for the employees tested.
Effect: The School Department was not in compliance with the time and effort certification requirements.
Cause: Staffing turnover in the financial department lead to weakened standard procedures/protocols by inexperienced (temporary) staffing.
Identification as a Repeat Finding: N/A
Recommendation: We recommend the School Department follow procedures to ensure that semi-annual certifications and/or monthly certifications are prepared and signed by either the employees and/or supervisory official having first-hand knowledge of the work performed by the employees in a timely manner in order to comply with the time and effort certification requirement.
Management Response: As required, the School Department ensures that semi-annual certifications and/or monthly certifications are prepared and signed by either the employees and/or supervisory official having first-hand knowledge of the work performed by the employees in a timely manner in order to comply with the time and effort certification requirement. Certifications are filed in grant folders and employee personnel files.
Finding 2022-004 – Special Education Cluster – AL No.’s 84.027 & 84.173
Department of Education
Massachusetts Department of Elementary and Secondary Education
Massachusetts Department of Early Education and Care
Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Programs
Criteria: The Period of Availability for the SPED PL 94-142 Grant was September 29, 2021 through September 30, 2023.
Condition: During our test of controls over compliance it was noted that there are expenditures charged to the SPED PL 94-142 Grant (September 29, 2021 through September 30, 2023) for services outside of the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education.
Context: During our test of expenditures and review of the general ledger against the SPED PL 94-142 Grant as it is related to compliance it was noted that the first payroll charged to the grant were for services prior to the grant start date of September 29, 2021 and thus would be outside the period of performance and thus would not be allowable costs.
Effect: The School Department was not in compliance with the period of performance requirement as set forth by the Massachusetts Department of Elementary and Secondary Education.
Questioned Costs: Questioned costs for the first payroll charged to the grant whose service period was prior to the grant start date of September 29, 2021 was $7,249.98.
Cause: Staffing turnover in the financial department lead to weakened standard procedures/protocols by inexperienced (temporary) staffing.
Recommendation: We recommend the School Department follow procedures to ensure that expenditures charged to the grant are within the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education.
Managements Response: The School Department ensures that expenditures charged to the grant only once approved and within the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education (DESE). Accounting codes are not set up for individual grants until final approval from DESE.
Finding 2022-001 – Special Education Cluster – AL No.’s 84.027 & 84.173
Department of Education
Massachusetts Department of Elementary and Secondary Education
Massachusetts Department of Early Education and Care
Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Programs
Criteria: 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 the applicable cost principles. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis.
Condition and Context: Control deficiencies related to disbursements were noted as a result of the testing of internal controls over payroll. Specifically, a sample of payroll disbursements charged to the programs were tested in order to determine if adequate internal controls were in place. As a result of the testing of payroll disbursements charged to the programs, all of the employees tested were found to not have adequately approved employee payroll rate agreements.
Cause: Weaknesses in the design and operation of controls.
Effect or Potential Effect: Due to the weaknesses in internal controls noted above, there is a risk of inappropriate salaries and wages being paid.
Identification as a Repeat Finding: Yes, finding number 2021-001
Questioned Costs: Questioned costs are reported equal to $256,796, calculated as payroll charged to the programs.
Recommendation: The Town should improve internal controls over Activities Allowed/Allowable Costs by ensuring employee’s payroll rate agreements are approved by an appropriate level of management and in a timely manner.
Managements Response: Though we believe that Finding 2021-001occured due to staff turnover at the time of the rate agreement approval, the Town and the Schools will assure federal awards are expended only for allowable activities. Consistent with State and Federal requirements and as in Acushnet’s updated Federal Grant Procedures Manual (February 2023), the Town will maintain source documentation (invoices, time sheets, payroll stubs, etc.) – including approved payroll rate agreements – that support federal expenditures.
Finding 2022-002 – Special Education Cluster – AL No.’s 84.027 & 84.173
Department of Education
Massachusetts Department of Elementary and Secondary Education
Massachusetts Department of Early Education and Care
Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Programs
Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. As governmental subrecipients of states are also required to use the same state procurement policies and procedures for federal funds as for non‐federal funds, the Town is required to follow Massachusetts General Laws, Chapter (MGL) 30(b). MGL 30(b) requires the solicitation of three written or oral quotes for procurements of supplies between $10,000 and $49,999 and sealed bids or proposals for procurements of supplies $50,000 and over. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis.
Condition and Context: During fiscal year 2022, the Town did not comply with the required procurement policies and procedures process for procurements that exceeded both State and Federal thresholds.
Questioned Costs: Unkown
Cause: Weaknesses in the design and operation of controls.
Effect or Potential Effect: Due to the weaknesses in internal controls noted above, there is a risk that amounts charged to federal awards may not be in accordance with procurement, suspension, and debarment principles. No known questioned costs are reported, as it is not quantifiable.
Identification as a Repeat Finding: Yes, finding number 2021-002
Recommendation: The Town should address the weaknesses in internal controls noted above in order to ensure that procurements are conducted in accordance with federal and state requirements.
Managements Response: The Town and Schools have Acushnet’s Federal Grant Procedures Manual (February 2023) to ensure that procurements are conducted in accordance with Federal and State requirements – in particular, the procurement standards set out at 2 CFR sections 200.318 through 200.326
Finding 2022-003 – Special Education Cluster – AL No.’s 84.027 & 84.173
Department of Education
Massachusetts Department of Elementary and Secondary Education
Massachusetts Department of Early Education and Care
Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program
Criteria: Where employees work solely or partially on a single Federal program or cost objective, their salaries or wages must be supported by periodic certification that the employee worked on these programs for the period covered by the programs. The certifications should be prepared at least semi-annually, and should be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee.
Condition: During our test of controls over compliance with time and effort certifications the school department was not able to provide evidence that required certifications of time and effort for those employees whose time was spent either completely or partially spent on these programs were performed as required by Uniform Guidance.
Questioned Costs: Unknown
Context: During our test of payroll transactions of the SPED PL 94-142 grants it was noted that the time and effort certifications were not completed for the employees tested.
Effect: The School Department was not in compliance with the time and effort certification requirements.
Cause: Staffing turnover in the financial department lead to weakened standard procedures/protocols by inexperienced (temporary) staffing.
Identification as a Repeat Finding: N/A
Recommendation: We recommend the School Department follow procedures to ensure that semi-annual certifications and/or monthly certifications are prepared and signed by either the employees and/or supervisory official having first-hand knowledge of the work performed by the employees in a timely manner in order to comply with the time and effort certification requirement.
Management Response: As required, the School Department ensures that semi-annual certifications and/or monthly certifications are prepared and signed by either the employees and/or supervisory official having first-hand knowledge of the work performed by the employees in a timely manner in order to comply with the time and effort certification requirement. Certifications are filed in grant folders and employee personnel files.
Finding 2022-001 – Special Education Cluster – AL No.’s 84.027 & 84.173
Department of Education
Massachusetts Department of Elementary and Secondary Education
Massachusetts Department of Early Education and Care
Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Programs
Criteria: 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 the applicable cost principles. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis.
Condition and Context: Control deficiencies related to disbursements were noted as a result of the testing of internal controls over payroll. Specifically, a sample of payroll disbursements charged to the programs were tested in order to determine if adequate internal controls were in place. As a result of the testing of payroll disbursements charged to the programs, all of the employees tested were found to not have adequately approved employee payroll rate agreements.
Cause: Weaknesses in the design and operation of controls.
Effect or Potential Effect: Due to the weaknesses in internal controls noted above, there is a risk of inappropriate salaries and wages being paid.
Identification as a Repeat Finding: Yes, finding number 2021-001
Questioned Costs: Questioned costs are reported equal to $256,796, calculated as payroll charged to the programs.
Recommendation: The Town should improve internal controls over Activities Allowed/Allowable Costs by ensuring employee’s payroll rate agreements are approved by an appropriate level of management and in a timely manner.
Managements Response: Though we believe that Finding 2021-001occured due to staff turnover at the time of the rate agreement approval, the Town and the Schools will assure federal awards are expended only for allowable activities. Consistent with State and Federal requirements and as in Acushnet’s updated Federal Grant Procedures Manual (February 2023), the Town will maintain source documentation (invoices, time sheets, payroll stubs, etc.) – including approved payroll rate agreements – that support federal expenditures.
Finding 2022-003 – Special Education Cluster – AL No.’s 84.027 & 84.173
Department of Education
Massachusetts Department of Elementary and Secondary Education
Massachusetts Department of Early Education and Care
Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program
Criteria: Where employees work solely or partially on a single Federal program or cost objective, their salaries or wages must be supported by periodic certification that the employee worked on these programs for the period covered by the programs. The certifications should be prepared at least semi-annually, and should be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee.
Condition: During our test of controls over compliance with time and effort certifications the school department was not able to provide evidence that required certifications of time and effort for those employees whose time was spent either completely or partially spent on these programs were performed as required by Uniform Guidance.
Questioned Costs: Unknown
Context: During our test of payroll transactions of the SPED PL 94-142 grants it was noted that the time and effort certifications were not completed for the employees tested.
Effect: The School Department was not in compliance with the time and effort certification requirements.
Cause: Staffing turnover in the financial department lead to weakened standard procedures/protocols by inexperienced (temporary) staffing.
Identification as a Repeat Finding: N/A
Recommendation: We recommend the School Department follow procedures to ensure that semi-annual certifications and/or monthly certifications are prepared and signed by either the employees and/or supervisory official having first-hand knowledge of the work performed by the employees in a timely manner in order to comply with the time and effort certification requirement.
Management Response: As required, the School Department ensures that semi-annual certifications and/or monthly certifications are prepared and signed by either the employees and/or supervisory official having first-hand knowledge of the work performed by the employees in a timely manner in order to comply with the time and effort certification requirement. Certifications are filed in grant folders and employee personnel files.