2023-004 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Child Nutrition Cluster – CFDA 10.553 & 10.555
Material Weakness in Internal Controls over Compliance and Compliance Finding
Criteria: Per 7 CFR Part 225.9 (d)(5), the School must retain records that support its claims for meal reimbursements.
Condition: Claims support could only be provided by the School for two months. For one month, support was in the form of spreadsheets with tray counts in lieu of a point-of-sale system. For the other month, the tray count spreadsheets were accompanied by reports from the point-of-sale system. The point-of-sale system reports provided did not agree to the amounts claimed for reimbursement. The tray counts did not indicate whether the meal provided was paid, free or reduced. The claims for reimbursement submitted by the School used allocation percentages derived from prior year claims when estimating amounts to be claimed as paid, free and reduced. The tray count spreadsheets for the other months could not be located by the School.
Cause: The Food Service Department did not maintain an adequate meal claiming system and the School did not adequately monitor its Food Service Department for compliance with Federal regulations.
Effect: Tray counts are not an accurate representation of the meals served nor appropriate support for the purposes of submitting claims for reimbursement. The pass-through agency disallowed $25,085.69 of meals claimed. A lack of a point-of-sale system also does not adequately safeguard the assets of the school lunch program.
Questioned Costs: $1,206,794.91, which represents the amounts reimbursed for fiscal year 2023 for claims submitted.
Perspective Information: The months tested do not represent a statistically valid sample.
Repeat Finding from Prior Year: No
Recommendation: The City should utilize a point-of-sale system for tracking student meal counts and submitting claims for reimbursements. Amounts claimed should be reconciled to the point-of-sale system reports before submitting.
Views of Responsible Official: Management agrees with the finding.
2023-005 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Child Nutrition Cluster – CFDA 10.553 & 10.555
Material Weakness in Internal Controls over Compliance and Compliance Finding
Criteria: Per 7 CFR Part 245.6, the School must provide meal benefit forms for use by families in making application for free or reduced-price meals. The School must determine household eligibility for free or reduced priced meals either through direct certification of the application process at or about the beginning of the school year.
Condition: Free or reduced meals applications could not be provided. The Food Service Department did not process free or reduced priced meals applications for the 2022-2023 school year.
Cause: The School did not adequately monitor its Food Service Department for compliance with Federal regulations.
Effect: Due to not maintaining an appropriate benefit issuance process, the School did not utilize benefit eligibility in the meals claiming process or notify families of their benefit status.
Questioned Costs: None
Repeat Finding from Prior Year: No
Recommendation: The City should process free and reduced-price meal applications at the beginning of the school year, notify the families of their benefit status and transfer the status on the application to the point-of-sale system to be used in the meals claiming process.
Views of Responsible Official: Management agrees with the finding.
2023-006 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Child Nutrition Cluster – CFDA 10.553 & 10.555
Material Weakness in Internal Controls over Compliance and Compliance Finding
Criteria: Per 7 CFR Part 245.6a(c), the School must verify eligibility of children in a sample of household applications approved for free and reduced priced meal benefits for that school year.
Condition: The Food Service Department did not perform its verification process by the date required by the state pass-through agency.
Cause: The Food Service Department did not process free or reduced priced meals applications for the 2022-2023 school year.
Effect: The School is not in compliance with federal regulations of the program.
Questioned Costs: None
Repeat Finding from Prior Year: No
Recommendation: The City should implement procedures to comply with the programs’ verification requirements in an accurate and timely manner.
Views of Responsible Official: Management agrees with the finding.
2023-007 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Child Nutrition Cluster – CFDA 10.553 & 10.555
Significant Deficiency in Internal Controls Over Compliance
Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred.
Condition: Suspension and debarment compliance was not verified for five covered transactions.
Cause: Lack of appropriate oversight resulted in required debarment checks not being performed or the appropriate certifications signed by the vendors.
Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. The five vendors were ultimately verified as not being suspended or debarred from participating in federal awards.
Questioned Costs: None
Repeat Finding from Prior Year: Yes; Finding 2022-007.
Recommendation: The City should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred.
Views of Responsible Official: Management agrees with the finding.
2023-004 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Child Nutrition Cluster – CFDA 10.553 & 10.555
Material Weakness in Internal Controls over Compliance and Compliance Finding
Criteria: Per 7 CFR Part 225.9 (d)(5), the School must retain records that support its claims for meal reimbursements.
Condition: Claims support could only be provided by the School for two months. For one month, support was in the form of spreadsheets with tray counts in lieu of a point-of-sale system. For the other month, the tray count spreadsheets were accompanied by reports from the point-of-sale system. The point-of-sale system reports provided did not agree to the amounts claimed for reimbursement. The tray counts did not indicate whether the meal provided was paid, free or reduced. The claims for reimbursement submitted by the School used allocation percentages derived from prior year claims when estimating amounts to be claimed as paid, free and reduced. The tray count spreadsheets for the other months could not be located by the School.
Cause: The Food Service Department did not maintain an adequate meal claiming system and the School did not adequately monitor its Food Service Department for compliance with Federal regulations.
Effect: Tray counts are not an accurate representation of the meals served nor appropriate support for the purposes of submitting claims for reimbursement. The pass-through agency disallowed $25,085.69 of meals claimed. A lack of a point-of-sale system also does not adequately safeguard the assets of the school lunch program.
Questioned Costs: $1,206,794.91, which represents the amounts reimbursed for fiscal year 2023 for claims submitted.
Perspective Information: The months tested do not represent a statistically valid sample.
Repeat Finding from Prior Year: No
Recommendation: The City should utilize a point-of-sale system for tracking student meal counts and submitting claims for reimbursements. Amounts claimed should be reconciled to the point-of-sale system reports before submitting.
Views of Responsible Official: Management agrees with the finding.
2023-005 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Child Nutrition Cluster – CFDA 10.553 & 10.555
Material Weakness in Internal Controls over Compliance and Compliance Finding
Criteria: Per 7 CFR Part 245.6, the School must provide meal benefit forms for use by families in making application for free or reduced-price meals. The School must determine household eligibility for free or reduced priced meals either through direct certification of the application process at or about the beginning of the school year.
Condition: Free or reduced meals applications could not be provided. The Food Service Department did not process free or reduced priced meals applications for the 2022-2023 school year.
Cause: The School did not adequately monitor its Food Service Department for compliance with Federal regulations.
Effect: Due to not maintaining an appropriate benefit issuance process, the School did not utilize benefit eligibility in the meals claiming process or notify families of their benefit status.
Questioned Costs: None
Repeat Finding from Prior Year: No
Recommendation: The City should process free and reduced-price meal applications at the beginning of the school year, notify the families of their benefit status and transfer the status on the application to the point-of-sale system to be used in the meals claiming process.
Views of Responsible Official: Management agrees with the finding.
2023-006 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Child Nutrition Cluster – CFDA 10.553 & 10.555
Material Weakness in Internal Controls over Compliance and Compliance Finding
Criteria: Per 7 CFR Part 245.6a(c), the School must verify eligibility of children in a sample of household applications approved for free and reduced priced meal benefits for that school year.
Condition: The Food Service Department did not perform its verification process by the date required by the state pass-through agency.
Cause: The Food Service Department did not process free or reduced priced meals applications for the 2022-2023 school year.
Effect: The School is not in compliance with federal regulations of the program.
Questioned Costs: None
Repeat Finding from Prior Year: No
Recommendation: The City should implement procedures to comply with the programs’ verification requirements in an accurate and timely manner.
Views of Responsible Official: Management agrees with the finding.
2023-007 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Child Nutrition Cluster – CFDA 10.553 & 10.555
Significant Deficiency in Internal Controls Over Compliance
Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred.
Condition: Suspension and debarment compliance was not verified for five covered transactions.
Cause: Lack of appropriate oversight resulted in required debarment checks not being performed or the appropriate certifications signed by the vendors.
Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. The five vendors were ultimately verified as not being suspended or debarred from participating in federal awards.
Questioned Costs: None
Repeat Finding from Prior Year: Yes; Finding 2022-007.
Recommendation: The City should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred.
Views of Responsible Official: Management agrees with the finding.
2023-004 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Child Nutrition Cluster – CFDA 10.553 & 10.555
Material Weakness in Internal Controls over Compliance and Compliance Finding
Criteria: Per 7 CFR Part 225.9 (d)(5), the School must retain records that support its claims for meal reimbursements.
Condition: Claims support could only be provided by the School for two months. For one month, support was in the form of spreadsheets with tray counts in lieu of a point-of-sale system. For the other month, the tray count spreadsheets were accompanied by reports from the point-of-sale system. The point-of-sale system reports provided did not agree to the amounts claimed for reimbursement. The tray counts did not indicate whether the meal provided was paid, free or reduced. The claims for reimbursement submitted by the School used allocation percentages derived from prior year claims when estimating amounts to be claimed as paid, free and reduced. The tray count spreadsheets for the other months could not be located by the School.
Cause: The Food Service Department did not maintain an adequate meal claiming system and the School did not adequately monitor its Food Service Department for compliance with Federal regulations.
Effect: Tray counts are not an accurate representation of the meals served nor appropriate support for the purposes of submitting claims for reimbursement. The pass-through agency disallowed $25,085.69 of meals claimed. A lack of a point-of-sale system also does not adequately safeguard the assets of the school lunch program.
Questioned Costs: $1,206,794.91, which represents the amounts reimbursed for fiscal year 2023 for claims submitted.
Perspective Information: The months tested do not represent a statistically valid sample.
Repeat Finding from Prior Year: No
Recommendation: The City should utilize a point-of-sale system for tracking student meal counts and submitting claims for reimbursements. Amounts claimed should be reconciled to the point-of-sale system reports before submitting.
Views of Responsible Official: Management agrees with the finding.
2023-005 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Child Nutrition Cluster – CFDA 10.553 & 10.555
Material Weakness in Internal Controls over Compliance and Compliance Finding
Criteria: Per 7 CFR Part 245.6, the School must provide meal benefit forms for use by families in making application for free or reduced-price meals. The School must determine household eligibility for free or reduced priced meals either through direct certification of the application process at or about the beginning of the school year.
Condition: Free or reduced meals applications could not be provided. The Food Service Department did not process free or reduced priced meals applications for the 2022-2023 school year.
Cause: The School did not adequately monitor its Food Service Department for compliance with Federal regulations.
Effect: Due to not maintaining an appropriate benefit issuance process, the School did not utilize benefit eligibility in the meals claiming process or notify families of their benefit status.
Questioned Costs: None
Repeat Finding from Prior Year: No
Recommendation: The City should process free and reduced-price meal applications at the beginning of the school year, notify the families of their benefit status and transfer the status on the application to the point-of-sale system to be used in the meals claiming process.
Views of Responsible Official: Management agrees with the finding.
2023-006 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Child Nutrition Cluster – CFDA 10.553 & 10.555
Material Weakness in Internal Controls over Compliance and Compliance Finding
Criteria: Per 7 CFR Part 245.6a(c), the School must verify eligibility of children in a sample of household applications approved for free and reduced priced meal benefits for that school year.
Condition: The Food Service Department did not perform its verification process by the date required by the state pass-through agency.
Cause: The Food Service Department did not process free or reduced priced meals applications for the 2022-2023 school year.
Effect: The School is not in compliance with federal regulations of the program.
Questioned Costs: None
Repeat Finding from Prior Year: No
Recommendation: The City should implement procedures to comply with the programs’ verification requirements in an accurate and timely manner.
Views of Responsible Official: Management agrees with the finding.
2023-007 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Child Nutrition Cluster – CFDA 10.553 & 10.555
Significant Deficiency in Internal Controls Over Compliance
Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred.
Condition: Suspension and debarment compliance was not verified for five covered transactions.
Cause: Lack of appropriate oversight resulted in required debarment checks not being performed or the appropriate certifications signed by the vendors.
Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. The five vendors were ultimately verified as not being suspended or debarred from participating in federal awards.
Questioned Costs: None
Repeat Finding from Prior Year: Yes; Finding 2022-007.
Recommendation: The City should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred.
Views of Responsible Official: Management agrees with the finding.
2023-010 U.S. Department of the Treasury
COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – ALN 21.027
Material Weakness in Internal Controls over Compliance and Compliance Finding
Criteria: Recipients can calculate lost revenue for the years 2020, 2021, 2022 and 2023 based on the formula provided in the Final Rule to determine the amount of SLFRF funds that can be used for the “provision of government services”.
Condition: The City did not reconcile its 2021 and 2022 revenue loss calculations with the final adjusted general ledger. Calendar year 2021 revenue was understated by $5,040,960 and calendar year 2022 revenue was understated by $1,455,486 in the 2021 and 2022 revenue loss calculations, respectively.
Cause: Numerous adjusting journal entries were posted to the City’s general ledger for state education aid that were not properly reflected in the revenue loss calculations.
Effect: As of June 30, 2023, the City has yet to spend more than the revenue loss calculated, net of the understated revenue. However, the City is at risk of spending in excess of allowable revenue loss if the calculations are not updated and performed timely and accurately.
Questioned Costs: None
Repeat Finding from Prior Year: No.
Recommendation: Revenue loss calculations should be updated to reflect the accurate revenues of the City as posted on the general ledger. The City should implement procedures to reconcile future revenue loss calculations to the revenue as reported in the general ledger.
Views of Responsible Official: Management agrees with the finding.
2023-008 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Special Education Cluster (IDEA) – ALN 84.027 & 84.173
COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X & 84.173X
Material Weakness in Internal Controls over Compliance and Compliance Finding
Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition.
Condition: Five vendors were awarded a contract without a competitive procurement process.
Cause: The School relied on State procurement exemptions which do not apply to Federal procurements.
Effect: The School is not in compliance with Federal procurement requirements.
Questioned Costs: $131,341.65
Repeat Finding from Prior Year: No.
Recommendation: The City should implement procedures to perform competitive procurement procedures on all applicable contracts for goods and services.
Views of Responsible Official: Management agrees with the finding.
2023-009 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Special Education Cluster (IDEA) – ALN 84.027 & 84.173
COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X & 84.173X
Significant Deficiency in Internal Controls Over Compliance
Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred.
Condition: Suspension and debarment compliance was not verified for two covered transactions.
Cause: Lack of appropriate oversight resulted in required debarment checks not being performed or the appropriate certifications signed by the vendors.
Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. The two vendors were ultimately verified as not being suspended or debarred from participating in federal awards.
Questioned Costs: None
Repeat Finding from Prior Year: No.
Recommendation: The City should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred.
Views of Responsible Official: Management agrees with the finding.
2023-008 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Special Education Cluster (IDEA) – ALN 84.027 & 84.173
COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X & 84.173X
Material Weakness in Internal Controls over Compliance and Compliance Finding
Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition.
Condition: Five vendors were awarded a contract without a competitive procurement process.
Cause: The School relied on State procurement exemptions which do not apply to Federal procurements.
Effect: The School is not in compliance with Federal procurement requirements.
Questioned Costs: $131,341.65
Repeat Finding from Prior Year: No.
Recommendation: The City should implement procedures to perform competitive procurement procedures on all applicable contracts for goods and services.
Views of Responsible Official: Management agrees with the finding.
2023-009 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Special Education Cluster (IDEA) – ALN 84.027 & 84.173
COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X & 84.173X
Significant Deficiency in Internal Controls Over Compliance
Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred.
Condition: Suspension and debarment compliance was not verified for two covered transactions.
Cause: Lack of appropriate oversight resulted in required debarment checks not being performed or the appropriate certifications signed by the vendors.
Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. The two vendors were ultimately verified as not being suspended or debarred from participating in federal awards.
Questioned Costs: None
Repeat Finding from Prior Year: No.
Recommendation: The City should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred.
Views of Responsible Official: Management agrees with the finding.
2023-008 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Special Education Cluster (IDEA) – ALN 84.027 & 84.173
COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X & 84.173X
Material Weakness in Internal Controls over Compliance and Compliance Finding
Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition.
Condition: Five vendors were awarded a contract without a competitive procurement process.
Cause: The School relied on State procurement exemptions which do not apply to Federal procurements.
Effect: The School is not in compliance with Federal procurement requirements.
Questioned Costs: $131,341.65
Repeat Finding from Prior Year: No.
Recommendation: The City should implement procedures to perform competitive procurement procedures on all applicable contracts for goods and services.
Views of Responsible Official: Management agrees with the finding.
2023-009 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Special Education Cluster (IDEA) – ALN 84.027 & 84.173
COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X & 84.173X
Significant Deficiency in Internal Controls Over Compliance
Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred.
Condition: Suspension and debarment compliance was not verified for two covered transactions.
Cause: Lack of appropriate oversight resulted in required debarment checks not being performed or the appropriate certifications signed by the vendors.
Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. The two vendors were ultimately verified as not being suspended or debarred from participating in federal awards.
Questioned Costs: None
Repeat Finding from Prior Year: No.
Recommendation: The City should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred.
Views of Responsible Official: Management agrees with the finding.
2023-008 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Special Education Cluster (IDEA) – ALN 84.027 & 84.173
COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X & 84.173X
Material Weakness in Internal Controls over Compliance and Compliance Finding
Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition.
Condition: Five vendors were awarded a contract without a competitive procurement process.
Cause: The School relied on State procurement exemptions which do not apply to Federal procurements.
Effect: The School is not in compliance with Federal procurement requirements.
Questioned Costs: $131,341.65
Repeat Finding from Prior Year: No.
Recommendation: The City should implement procedures to perform competitive procurement procedures on all applicable contracts for goods and services.
Views of Responsible Official: Management agrees with the finding.
2023-009 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Special Education Cluster (IDEA) – ALN 84.027 & 84.173
COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X & 84.173X
Significant Deficiency in Internal Controls Over Compliance
Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred.
Condition: Suspension and debarment compliance was not verified for two covered transactions.
Cause: Lack of appropriate oversight resulted in required debarment checks not being performed or the appropriate certifications signed by the vendors.
Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. The two vendors were ultimately verified as not being suspended or debarred from participating in federal awards.
Questioned Costs: None
Repeat Finding from Prior Year: No.
Recommendation: The City should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred.
Views of Responsible Official: Management agrees with the finding.
2023-004 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Child Nutrition Cluster – CFDA 10.553 & 10.555
Material Weakness in Internal Controls over Compliance and Compliance Finding
Criteria: Per 7 CFR Part 225.9 (d)(5), the School must retain records that support its claims for meal reimbursements.
Condition: Claims support could only be provided by the School for two months. For one month, support was in the form of spreadsheets with tray counts in lieu of a point-of-sale system. For the other month, the tray count spreadsheets were accompanied by reports from the point-of-sale system. The point-of-sale system reports provided did not agree to the amounts claimed for reimbursement. The tray counts did not indicate whether the meal provided was paid, free or reduced. The claims for reimbursement submitted by the School used allocation percentages derived from prior year claims when estimating amounts to be claimed as paid, free and reduced. The tray count spreadsheets for the other months could not be located by the School.
Cause: The Food Service Department did not maintain an adequate meal claiming system and the School did not adequately monitor its Food Service Department for compliance with Federal regulations.
Effect: Tray counts are not an accurate representation of the meals served nor appropriate support for the purposes of submitting claims for reimbursement. The pass-through agency disallowed $25,085.69 of meals claimed. A lack of a point-of-sale system also does not adequately safeguard the assets of the school lunch program.
Questioned Costs: $1,206,794.91, which represents the amounts reimbursed for fiscal year 2023 for claims submitted.
Perspective Information: The months tested do not represent a statistically valid sample.
Repeat Finding from Prior Year: No
Recommendation: The City should utilize a point-of-sale system for tracking student meal counts and submitting claims for reimbursements. Amounts claimed should be reconciled to the point-of-sale system reports before submitting.
Views of Responsible Official: Management agrees with the finding.
2023-005 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Child Nutrition Cluster – CFDA 10.553 & 10.555
Material Weakness in Internal Controls over Compliance and Compliance Finding
Criteria: Per 7 CFR Part 245.6, the School must provide meal benefit forms for use by families in making application for free or reduced-price meals. The School must determine household eligibility for free or reduced priced meals either through direct certification of the application process at or about the beginning of the school year.
Condition: Free or reduced meals applications could not be provided. The Food Service Department did not process free or reduced priced meals applications for the 2022-2023 school year.
Cause: The School did not adequately monitor its Food Service Department for compliance with Federal regulations.
Effect: Due to not maintaining an appropriate benefit issuance process, the School did not utilize benefit eligibility in the meals claiming process or notify families of their benefit status.
Questioned Costs: None
Repeat Finding from Prior Year: No
Recommendation: The City should process free and reduced-price meal applications at the beginning of the school year, notify the families of their benefit status and transfer the status on the application to the point-of-sale system to be used in the meals claiming process.
Views of Responsible Official: Management agrees with the finding.
2023-006 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Child Nutrition Cluster – CFDA 10.553 & 10.555
Material Weakness in Internal Controls over Compliance and Compliance Finding
Criteria: Per 7 CFR Part 245.6a(c), the School must verify eligibility of children in a sample of household applications approved for free and reduced priced meal benefits for that school year.
Condition: The Food Service Department did not perform its verification process by the date required by the state pass-through agency.
Cause: The Food Service Department did not process free or reduced priced meals applications for the 2022-2023 school year.
Effect: The School is not in compliance with federal regulations of the program.
Questioned Costs: None
Repeat Finding from Prior Year: No
Recommendation: The City should implement procedures to comply with the programs’ verification requirements in an accurate and timely manner.
Views of Responsible Official: Management agrees with the finding.
2023-007 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Child Nutrition Cluster – CFDA 10.553 & 10.555
Significant Deficiency in Internal Controls Over Compliance
Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred.
Condition: Suspension and debarment compliance was not verified for five covered transactions.
Cause: Lack of appropriate oversight resulted in required debarment checks not being performed or the appropriate certifications signed by the vendors.
Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. The five vendors were ultimately verified as not being suspended or debarred from participating in federal awards.
Questioned Costs: None
Repeat Finding from Prior Year: Yes; Finding 2022-007.
Recommendation: The City should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred.
Views of Responsible Official: Management agrees with the finding.
2023-004 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Child Nutrition Cluster – CFDA 10.553 & 10.555
Material Weakness in Internal Controls over Compliance and Compliance Finding
Criteria: Per 7 CFR Part 225.9 (d)(5), the School must retain records that support its claims for meal reimbursements.
Condition: Claims support could only be provided by the School for two months. For one month, support was in the form of spreadsheets with tray counts in lieu of a point-of-sale system. For the other month, the tray count spreadsheets were accompanied by reports from the point-of-sale system. The point-of-sale system reports provided did not agree to the amounts claimed for reimbursement. The tray counts did not indicate whether the meal provided was paid, free or reduced. The claims for reimbursement submitted by the School used allocation percentages derived from prior year claims when estimating amounts to be claimed as paid, free and reduced. The tray count spreadsheets for the other months could not be located by the School.
Cause: The Food Service Department did not maintain an adequate meal claiming system and the School did not adequately monitor its Food Service Department for compliance with Federal regulations.
Effect: Tray counts are not an accurate representation of the meals served nor appropriate support for the purposes of submitting claims for reimbursement. The pass-through agency disallowed $25,085.69 of meals claimed. A lack of a point-of-sale system also does not adequately safeguard the assets of the school lunch program.
Questioned Costs: $1,206,794.91, which represents the amounts reimbursed for fiscal year 2023 for claims submitted.
Perspective Information: The months tested do not represent a statistically valid sample.
Repeat Finding from Prior Year: No
Recommendation: The City should utilize a point-of-sale system for tracking student meal counts and submitting claims for reimbursements. Amounts claimed should be reconciled to the point-of-sale system reports before submitting.
Views of Responsible Official: Management agrees with the finding.
2023-005 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Child Nutrition Cluster – CFDA 10.553 & 10.555
Material Weakness in Internal Controls over Compliance and Compliance Finding
Criteria: Per 7 CFR Part 245.6, the School must provide meal benefit forms for use by families in making application for free or reduced-price meals. The School must determine household eligibility for free or reduced priced meals either through direct certification of the application process at or about the beginning of the school year.
Condition: Free or reduced meals applications could not be provided. The Food Service Department did not process free or reduced priced meals applications for the 2022-2023 school year.
Cause: The School did not adequately monitor its Food Service Department for compliance with Federal regulations.
Effect: Due to not maintaining an appropriate benefit issuance process, the School did not utilize benefit eligibility in the meals claiming process or notify families of their benefit status.
Questioned Costs: None
Repeat Finding from Prior Year: No
Recommendation: The City should process free and reduced-price meal applications at the beginning of the school year, notify the families of their benefit status and transfer the status on the application to the point-of-sale system to be used in the meals claiming process.
Views of Responsible Official: Management agrees with the finding.
2023-006 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Child Nutrition Cluster – CFDA 10.553 & 10.555
Material Weakness in Internal Controls over Compliance and Compliance Finding
Criteria: Per 7 CFR Part 245.6a(c), the School must verify eligibility of children in a sample of household applications approved for free and reduced priced meal benefits for that school year.
Condition: The Food Service Department did not perform its verification process by the date required by the state pass-through agency.
Cause: The Food Service Department did not process free or reduced priced meals applications for the 2022-2023 school year.
Effect: The School is not in compliance with federal regulations of the program.
Questioned Costs: None
Repeat Finding from Prior Year: No
Recommendation: The City should implement procedures to comply with the programs’ verification requirements in an accurate and timely manner.
Views of Responsible Official: Management agrees with the finding.
2023-007 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Child Nutrition Cluster – CFDA 10.553 & 10.555
Significant Deficiency in Internal Controls Over Compliance
Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred.
Condition: Suspension and debarment compliance was not verified for five covered transactions.
Cause: Lack of appropriate oversight resulted in required debarment checks not being performed or the appropriate certifications signed by the vendors.
Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. The five vendors were ultimately verified as not being suspended or debarred from participating in federal awards.
Questioned Costs: None
Repeat Finding from Prior Year: Yes; Finding 2022-007.
Recommendation: The City should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred.
Views of Responsible Official: Management agrees with the finding.
2023-004 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Child Nutrition Cluster – CFDA 10.553 & 10.555
Material Weakness in Internal Controls over Compliance and Compliance Finding
Criteria: Per 7 CFR Part 225.9 (d)(5), the School must retain records that support its claims for meal reimbursements.
Condition: Claims support could only be provided by the School for two months. For one month, support was in the form of spreadsheets with tray counts in lieu of a point-of-sale system. For the other month, the tray count spreadsheets were accompanied by reports from the point-of-sale system. The point-of-sale system reports provided did not agree to the amounts claimed for reimbursement. The tray counts did not indicate whether the meal provided was paid, free or reduced. The claims for reimbursement submitted by the School used allocation percentages derived from prior year claims when estimating amounts to be claimed as paid, free and reduced. The tray count spreadsheets for the other months could not be located by the School.
Cause: The Food Service Department did not maintain an adequate meal claiming system and the School did not adequately monitor its Food Service Department for compliance with Federal regulations.
Effect: Tray counts are not an accurate representation of the meals served nor appropriate support for the purposes of submitting claims for reimbursement. The pass-through agency disallowed $25,085.69 of meals claimed. A lack of a point-of-sale system also does not adequately safeguard the assets of the school lunch program.
Questioned Costs: $1,206,794.91, which represents the amounts reimbursed for fiscal year 2023 for claims submitted.
Perspective Information: The months tested do not represent a statistically valid sample.
Repeat Finding from Prior Year: No
Recommendation: The City should utilize a point-of-sale system for tracking student meal counts and submitting claims for reimbursements. Amounts claimed should be reconciled to the point-of-sale system reports before submitting.
Views of Responsible Official: Management agrees with the finding.
2023-005 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Child Nutrition Cluster – CFDA 10.553 & 10.555
Material Weakness in Internal Controls over Compliance and Compliance Finding
Criteria: Per 7 CFR Part 245.6, the School must provide meal benefit forms for use by families in making application for free or reduced-price meals. The School must determine household eligibility for free or reduced priced meals either through direct certification of the application process at or about the beginning of the school year.
Condition: Free or reduced meals applications could not be provided. The Food Service Department did not process free or reduced priced meals applications for the 2022-2023 school year.
Cause: The School did not adequately monitor its Food Service Department for compliance with Federal regulations.
Effect: Due to not maintaining an appropriate benefit issuance process, the School did not utilize benefit eligibility in the meals claiming process or notify families of their benefit status.
Questioned Costs: None
Repeat Finding from Prior Year: No
Recommendation: The City should process free and reduced-price meal applications at the beginning of the school year, notify the families of their benefit status and transfer the status on the application to the point-of-sale system to be used in the meals claiming process.
Views of Responsible Official: Management agrees with the finding.
2023-006 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Child Nutrition Cluster – CFDA 10.553 & 10.555
Material Weakness in Internal Controls over Compliance and Compliance Finding
Criteria: Per 7 CFR Part 245.6a(c), the School must verify eligibility of children in a sample of household applications approved for free and reduced priced meal benefits for that school year.
Condition: The Food Service Department did not perform its verification process by the date required by the state pass-through agency.
Cause: The Food Service Department did not process free or reduced priced meals applications for the 2022-2023 school year.
Effect: The School is not in compliance with federal regulations of the program.
Questioned Costs: None
Repeat Finding from Prior Year: No
Recommendation: The City should implement procedures to comply with the programs’ verification requirements in an accurate and timely manner.
Views of Responsible Official: Management agrees with the finding.
2023-007 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Child Nutrition Cluster – CFDA 10.553 & 10.555
Significant Deficiency in Internal Controls Over Compliance
Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred.
Condition: Suspension and debarment compliance was not verified for five covered transactions.
Cause: Lack of appropriate oversight resulted in required debarment checks not being performed or the appropriate certifications signed by the vendors.
Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. The five vendors were ultimately verified as not being suspended or debarred from participating in federal awards.
Questioned Costs: None
Repeat Finding from Prior Year: Yes; Finding 2022-007.
Recommendation: The City should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred.
Views of Responsible Official: Management agrees with the finding.
2023-010 U.S. Department of the Treasury
COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – ALN 21.027
Material Weakness in Internal Controls over Compliance and Compliance Finding
Criteria: Recipients can calculate lost revenue for the years 2020, 2021, 2022 and 2023 based on the formula provided in the Final Rule to determine the amount of SLFRF funds that can be used for the “provision of government services”.
Condition: The City did not reconcile its 2021 and 2022 revenue loss calculations with the final adjusted general ledger. Calendar year 2021 revenue was understated by $5,040,960 and calendar year 2022 revenue was understated by $1,455,486 in the 2021 and 2022 revenue loss calculations, respectively.
Cause: Numerous adjusting journal entries were posted to the City’s general ledger for state education aid that were not properly reflected in the revenue loss calculations.
Effect: As of June 30, 2023, the City has yet to spend more than the revenue loss calculated, net of the understated revenue. However, the City is at risk of spending in excess of allowable revenue loss if the calculations are not updated and performed timely and accurately.
Questioned Costs: None
Repeat Finding from Prior Year: No.
Recommendation: Revenue loss calculations should be updated to reflect the accurate revenues of the City as posted on the general ledger. The City should implement procedures to reconcile future revenue loss calculations to the revenue as reported in the general ledger.
Views of Responsible Official: Management agrees with the finding.
2023-008 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Special Education Cluster (IDEA) – ALN 84.027 & 84.173
COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X & 84.173X
Material Weakness in Internal Controls over Compliance and Compliance Finding
Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition.
Condition: Five vendors were awarded a contract without a competitive procurement process.
Cause: The School relied on State procurement exemptions which do not apply to Federal procurements.
Effect: The School is not in compliance with Federal procurement requirements.
Questioned Costs: $131,341.65
Repeat Finding from Prior Year: No.
Recommendation: The City should implement procedures to perform competitive procurement procedures on all applicable contracts for goods and services.
Views of Responsible Official: Management agrees with the finding.
2023-009 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Special Education Cluster (IDEA) – ALN 84.027 & 84.173
COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X & 84.173X
Significant Deficiency in Internal Controls Over Compliance
Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred.
Condition: Suspension and debarment compliance was not verified for two covered transactions.
Cause: Lack of appropriate oversight resulted in required debarment checks not being performed or the appropriate certifications signed by the vendors.
Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. The two vendors were ultimately verified as not being suspended or debarred from participating in federal awards.
Questioned Costs: None
Repeat Finding from Prior Year: No.
Recommendation: The City should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred.
Views of Responsible Official: Management agrees with the finding.
2023-008 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Special Education Cluster (IDEA) – ALN 84.027 & 84.173
COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X & 84.173X
Material Weakness in Internal Controls over Compliance and Compliance Finding
Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition.
Condition: Five vendors were awarded a contract without a competitive procurement process.
Cause: The School relied on State procurement exemptions which do not apply to Federal procurements.
Effect: The School is not in compliance with Federal procurement requirements.
Questioned Costs: $131,341.65
Repeat Finding from Prior Year: No.
Recommendation: The City should implement procedures to perform competitive procurement procedures on all applicable contracts for goods and services.
Views of Responsible Official: Management agrees with the finding.
2023-009 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Special Education Cluster (IDEA) – ALN 84.027 & 84.173
COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X & 84.173X
Significant Deficiency in Internal Controls Over Compliance
Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred.
Condition: Suspension and debarment compliance was not verified for two covered transactions.
Cause: Lack of appropriate oversight resulted in required debarment checks not being performed or the appropriate certifications signed by the vendors.
Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. The two vendors were ultimately verified as not being suspended or debarred from participating in federal awards.
Questioned Costs: None
Repeat Finding from Prior Year: No.
Recommendation: The City should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred.
Views of Responsible Official: Management agrees with the finding.
2023-008 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Special Education Cluster (IDEA) – ALN 84.027 & 84.173
COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X & 84.173X
Material Weakness in Internal Controls over Compliance and Compliance Finding
Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition.
Condition: Five vendors were awarded a contract without a competitive procurement process.
Cause: The School relied on State procurement exemptions which do not apply to Federal procurements.
Effect: The School is not in compliance with Federal procurement requirements.
Questioned Costs: $131,341.65
Repeat Finding from Prior Year: No.
Recommendation: The City should implement procedures to perform competitive procurement procedures on all applicable contracts for goods and services.
Views of Responsible Official: Management agrees with the finding.
2023-009 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Special Education Cluster (IDEA) – ALN 84.027 & 84.173
COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X & 84.173X
Significant Deficiency in Internal Controls Over Compliance
Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred.
Condition: Suspension and debarment compliance was not verified for two covered transactions.
Cause: Lack of appropriate oversight resulted in required debarment checks not being performed or the appropriate certifications signed by the vendors.
Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. The two vendors were ultimately verified as not being suspended or debarred from participating in federal awards.
Questioned Costs: None
Repeat Finding from Prior Year: No.
Recommendation: The City should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred.
Views of Responsible Official: Management agrees with the finding.
2023-008 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Special Education Cluster (IDEA) – ALN 84.027 & 84.173
COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X & 84.173X
Material Weakness in Internal Controls over Compliance and Compliance Finding
Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition.
Condition: Five vendors were awarded a contract without a competitive procurement process.
Cause: The School relied on State procurement exemptions which do not apply to Federal procurements.
Effect: The School is not in compliance with Federal procurement requirements.
Questioned Costs: $131,341.65
Repeat Finding from Prior Year: No.
Recommendation: The City should implement procedures to perform competitive procurement procedures on all applicable contracts for goods and services.
Views of Responsible Official: Management agrees with the finding.
2023-009 U.S. Department of Agriculture
Passed-through the Commonwealth of Massachusetts’ Department of
Elementary and Secondary Education
Special Education Cluster (IDEA) – ALN 84.027 & 84.173
COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X & 84.173X
Significant Deficiency in Internal Controls Over Compliance
Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred.
Condition: Suspension and debarment compliance was not verified for two covered transactions.
Cause: Lack of appropriate oversight resulted in required debarment checks not being performed or the appropriate certifications signed by the vendors.
Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. The two vendors were ultimately verified as not being suspended or debarred from participating in federal awards.
Questioned Costs: None
Repeat Finding from Prior Year: No.
Recommendation: The City should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred.
Views of Responsible Official: Management agrees with the finding.