Federal agency: U.S. Department of Education
Federal program title: Special Education Cluster
Assistance Listing Number: 84.027, 84.173
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and Massachusetts Department of Early Education and Care
Pass-Through Number(s): Various (see Schedule of Expenditures of Federal Awards)
Award Period: July 1, 2021 – June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance
Compliance Requirement: Suspension and Debarment
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition and Context: For two of three vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities.
Questioned Costs: None
Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities.
Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities.
Repeat Finding: Yes (Finding 2022-001)
Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities.
Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Education
Federal program title: Special Education Cluster
Assistance Listing Number: 84.027, 84.173
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and Massachusetts Department of Early Education and Care
Pass-Through Number(s): Various (see Schedule of Expenditures of Federal Awards)
Award Period: July 1, 2021 – June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance
Compliance Requirement: Suspension and Debarment
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition and Context: For two of three vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities.
Questioned Costs: None
Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities.
Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities.
Repeat Finding: Yes (Finding 2022-001)
Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities.
Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Education
Federal program title: Adult Education - Basic Grants to States
Assistance Listing Number: 84.002
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education
Pass-Through Number(s): Code 340
Award Period: July 1, 2022 – June 30, 2023
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Material Noncompliance (Modified Opinion)
Compliance Requirements: Activities Allowed or Unallowed and Allowable Cost/Cost Principles
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Condition and Context: For all payroll charges selected for testing, the City could not provide records that accurately reflected the work performed.
Questioned Costs: $1,047,536
Cause: Procedures to maintain records that accurately reflect the work performed for payroll charges to the grant need to be implemented and/or strengthened.
Effect: Noncompliance with the federal program occurred and we could not determine the allowability of payroll charges to the grant.
Repeat Finding: No
Recommendation: We recommend procedures to maintain records that accurately reflect the work performed for payroll charges to the grant be implemented/strengthened.
Views of Responsible Officials: Management agrees with the finding
Federal agency: U.S. Department of Education
Federal program title: Adult Education - Basic Grants to States
Assistance Listing Number: 84.002
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education
Pass-Through Number(s): Code 340
Award Period: July 1, 2022 – June 30, 2023
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Material Noncompliance (Modified Opinion)
Compliance Requirements: Eligibility
Criteria or Specific Requirement: The federal Office of Management and Budget's Compliance Supplement states that audit objectives for eligibility include determining whether required eligibility determinations were made (including obtaining any required documentation/verification), that individual program participants or groups of participants (including area of service delivery) were determined to be eligible, and that only eligible individuals or groups of individuals participated in the program.
Condition and Context: For a significant majority of program participants selected for testing, the City could not provide adequate records related to eligibility determinations.
Questioned Costs: None (questioned costs are reported in finding 2023-002)
Cause: Procedures to maintain records related to eligibility determinations need to be implemented and/or strengthened.
Effect: Noncompliance with the federal program occurred and we could not determine the eligibility of the majority of program participants selected for testing.
Repeat Finding: No
Recommendation: We recommend procedures to maintain records related to eligibility determinations be implemented/strengthened.
Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Education
Federal program title: Special Education Cluster
Assistance Listing Number: 84.027, 84.173
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and Massachusetts Department of Early Education and Care
Pass-Through Number(s): Various (see Schedule of Expenditures of Federal Awards)
Award Period: July 1, 2021 – June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance
Compliance Requirement: Suspension and Debarment
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition and Context: For two of three vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities.
Questioned Costs: None
Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities.
Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities.
Repeat Finding: Yes (Finding 2022-001)
Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities.
Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Education
Federal program title: Special Education Cluster
Assistance Listing Number: 84.027, 84.173
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and Massachusetts Department of Early Education and Care
Pass-Through Number(s): Various (see Schedule of Expenditures of Federal Awards)
Award Period: July 1, 2021 – June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance
Compliance Requirement: Suspension and Debarment
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition and Context: For two of three vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities.
Questioned Costs: None
Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities.
Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities.
Repeat Finding: Yes (Finding 2022-001)
Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities.
Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Education
Federal program title: Adult Education - Basic Grants to States
Assistance Listing Number: 84.002
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education
Pass-Through Number(s): Code 340
Award Period: July 1, 2022 – June 30, 2023
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Material Noncompliance (Modified Opinion)
Compliance Requirements: Activities Allowed or Unallowed and Allowable Cost/Cost Principles
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Condition and Context: For all payroll charges selected for testing, the City could not provide records that accurately reflected the work performed.
Questioned Costs: $1,047,536
Cause: Procedures to maintain records that accurately reflect the work performed for payroll charges to the grant need to be implemented and/or strengthened.
Effect: Noncompliance with the federal program occurred and we could not determine the allowability of payroll charges to the grant.
Repeat Finding: No
Recommendation: We recommend procedures to maintain records that accurately reflect the work performed for payroll charges to the grant be implemented/strengthened.
Views of Responsible Officials: Management agrees with the finding
Federal agency: U.S. Department of Education
Federal program title: Adult Education - Basic Grants to States
Assistance Listing Number: 84.002
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education
Pass-Through Number(s): Code 340
Award Period: July 1, 2022 – June 30, 2023
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Material Noncompliance (Modified Opinion)
Compliance Requirements: Eligibility
Criteria or Specific Requirement: The federal Office of Management and Budget's Compliance Supplement states that audit objectives for eligibility include determining whether required eligibility determinations were made (including obtaining any required documentation/verification), that individual program participants or groups of participants (including area of service delivery) were determined to be eligible, and that only eligible individuals or groups of individuals participated in the program.
Condition and Context: For a significant majority of program participants selected for testing, the City could not provide adequate records related to eligibility determinations.
Questioned Costs: None (questioned costs are reported in finding 2023-002)
Cause: Procedures to maintain records related to eligibility determinations need to be implemented and/or strengthened.
Effect: Noncompliance with the federal program occurred and we could not determine the eligibility of the majority of program participants selected for testing.
Repeat Finding: No
Recommendation: We recommend procedures to maintain records related to eligibility determinations be implemented/strengthened.
Views of Responsible Officials: Management agrees with the finding.