Audit 345320

FY End
2024-06-30
Total Expended
$20.06M
Findings
4
Programs
18
Year: 2024 Accepted: 2025-03-10
Auditor: Cohnreznick LLP

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
526390 2024-002 Significant Deficiency Yes I
526391 2024-002 Significant Deficiency Yes I
1102832 2024-002 Significant Deficiency Yes I
1102833 2024-002 Significant Deficiency Yes I

Contacts

Name Title Type
DEF8RN9BAUD3 Jillian Rupple Auditee
5084276448 Brian Martin Auditor
No contacts on file

Notes to SEFA

Title: (1) Basis of Presentation Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards , wherein certain types of expenditures are not allowable or are limited as to reimbursement. Father Bill's & MainSpring, Inc. and Affiliates has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: Father Bill's & MainSpring, Inc. and Affiliates has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal award activity of Father Bill's & MainSpring, Inc. and Affiliates under programs of the federal government for the year ended June 30, 2024. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of Father Bill's & MainSpring, Inc. and Affiliates, it is not intended to and does not present the consolidated financial position, changes in net assets, or cash flows of Father Bill's & MainSpring, Inc. and Affiliates.
Title: (2) Summary of Significant Accounting Policies Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards , wherein certain types of expenditures are not allowable or are limited as to reimbursement. Father Bill's & MainSpring, Inc. and Affiliates has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: Father Bill's & MainSpring, Inc. and Affiliates has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards , wherein certain types of expenditures are not allowable or are limited as to reimbursement. Father Bill's & MainSpring, Inc. and Affiliates has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance.
Title: (3) Federal Loan Programs Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards , wherein certain types of expenditures are not allowable or are limited as to reimbursement. Father Bill's & MainSpring, Inc. and Affiliates has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: Father Bill's & MainSpring, Inc. and Affiliates has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The federal loan programs listed below are administered directly by Father Bill's & MainSpring, Inc. and Affiliates, and balances and transactions relating to the programs are included in Father Bill's & MainSpring, Inc. and Affiliates's basic consolidated financial statements. Loans outstanding at the beginning of the year and loans made during the year are included in the federal expenditures presented in the Schedule. The balance of loans outstanding as of June 30, 2024 consists of: Federal Assistance Listing Number Program Name Passed Through Outstanding June 30, 2024 14.239 Home Investment Partnerships Program City of Brockton $ 575,000 14.239 Home Investment Partnerships Program Commonwealth of Massachusetts, 110,000 Executive Office of Housing and Livable Communities 14.239 Home Investment Partnerships Program Brockton Housing Authority 100,000 14.275 Housing Trust Fund Commonwealth of Massachusetts, 1,000,000 Executive Office of Housing and Livable Communities 21.027 Coronavirus State and Local Fiscal Recovery Funds Community Economic Development Assistance 6,823,152 Corporation $ 8,608,152

Finding Details

Finding No. 2024-002 - Procurement, Suspension and Debarment - Significant Deficiency Name of Federal Agency: U.S Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Identification number unavailable. Program year 2024 Name of Pass-through Entity (if applicable): The Community Economic Development Assistance Corporation, the City of Brockton and the Plymouth County Commissioners. Criteria: In accordance with §200.318(a), General Procurement Standards, a nonfederal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that the nonfederal entity must maintain records sufficient to detail the history of the procurement. In addition, in accordance with §200.213 and §180.300, nonfederal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition/Context: For 2 procurement samples out of a total of 2 tested, management did not provide adequate supporting documentation for the procurement including ensuring proper suspension and debarment checks were performed. Cause: The Agency did not have adequate policies, procedures, and controls in place to ensure compliance with the general procurement standards and suspension and debarment requirements. Effect or Potential Effect: Failure to perform procurement procedures in accordance with a written policy that complies with the Uniform Guidance could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in entering into a contract with an entity that is barred from performing work for the U.S. government. Questioned Costs: None Identification as a Repeat Finding: This is a repeat finding (see prior year finding number: 2023- 002). Recommendation: We recommend that the Agency establish written procurement policies and procedures to ensure that the Agency is in compliance with the Uniform Guidance and that all staff are trained on this policy to ensure compliance and related internal controls over compliance are operating effectively. Views of Responsible Officials: Management agrees with the finding and is in the process of revising internal controls to address procurement, suspension and debarment requirements. Additionally, management has retroactively performed this requirement to the applicable transactions during the audit period, noting no vendors were suspended or debarred.
Finding No. 2024-002 - Procurement, Suspension and Debarment - Significant Deficiency Name of Federal Agency: U.S Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Identification number unavailable. Program year 2024 Name of Pass-through Entity (if applicable): The Community Economic Development Assistance Corporation, the City of Brockton and the Plymouth County Commissioners. Criteria: In accordance with §200.318(a), General Procurement Standards, a nonfederal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that the nonfederal entity must maintain records sufficient to detail the history of the procurement. In addition, in accordance with §200.213 and §180.300, nonfederal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition/Context: For 2 procurement samples out of a total of 2 tested, management did not provide adequate supporting documentation for the procurement including ensuring proper suspension and debarment checks were performed. Cause: The Agency did not have adequate policies, procedures, and controls in place to ensure compliance with the general procurement standards and suspension and debarment requirements. Effect or Potential Effect: Failure to perform procurement procedures in accordance with a written policy that complies with the Uniform Guidance could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in entering into a contract with an entity that is barred from performing work for the U.S. government. Questioned Costs: None Identification as a Repeat Finding: This is a repeat finding (see prior year finding number: 2023- 002). Recommendation: We recommend that the Agency establish written procurement policies and procedures to ensure that the Agency is in compliance with the Uniform Guidance and that all staff are trained on this policy to ensure compliance and related internal controls over compliance are operating effectively. Views of Responsible Officials: Management agrees with the finding and is in the process of revising internal controls to address procurement, suspension and debarment requirements. Additionally, management has retroactively performed this requirement to the applicable transactions during the audit period, noting no vendors were suspended or debarred.
Finding No. 2024-002 - Procurement, Suspension and Debarment - Significant Deficiency Name of Federal Agency: U.S Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Identification number unavailable. Program year 2024 Name of Pass-through Entity (if applicable): The Community Economic Development Assistance Corporation, the City of Brockton and the Plymouth County Commissioners. Criteria: In accordance with §200.318(a), General Procurement Standards, a nonfederal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that the nonfederal entity must maintain records sufficient to detail the history of the procurement. In addition, in accordance with §200.213 and §180.300, nonfederal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition/Context: For 2 procurement samples out of a total of 2 tested, management did not provide adequate supporting documentation for the procurement including ensuring proper suspension and debarment checks were performed. Cause: The Agency did not have adequate policies, procedures, and controls in place to ensure compliance with the general procurement standards and suspension and debarment requirements. Effect or Potential Effect: Failure to perform procurement procedures in accordance with a written policy that complies with the Uniform Guidance could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in entering into a contract with an entity that is barred from performing work for the U.S. government. Questioned Costs: None Identification as a Repeat Finding: This is a repeat finding (see prior year finding number: 2023- 002). Recommendation: We recommend that the Agency establish written procurement policies and procedures to ensure that the Agency is in compliance with the Uniform Guidance and that all staff are trained on this policy to ensure compliance and related internal controls over compliance are operating effectively. Views of Responsible Officials: Management agrees with the finding and is in the process of revising internal controls to address procurement, suspension and debarment requirements. Additionally, management has retroactively performed this requirement to the applicable transactions during the audit period, noting no vendors were suspended or debarred.
Finding No. 2024-002 - Procurement, Suspension and Debarment - Significant Deficiency Name of Federal Agency: U.S Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Identification number unavailable. Program year 2024 Name of Pass-through Entity (if applicable): The Community Economic Development Assistance Corporation, the City of Brockton and the Plymouth County Commissioners. Criteria: In accordance with §200.318(a), General Procurement Standards, a nonfederal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that the nonfederal entity must maintain records sufficient to detail the history of the procurement. In addition, in accordance with §200.213 and §180.300, nonfederal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition/Context: For 2 procurement samples out of a total of 2 tested, management did not provide adequate supporting documentation for the procurement including ensuring proper suspension and debarment checks were performed. Cause: The Agency did not have adequate policies, procedures, and controls in place to ensure compliance with the general procurement standards and suspension and debarment requirements. Effect or Potential Effect: Failure to perform procurement procedures in accordance with a written policy that complies with the Uniform Guidance could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in entering into a contract with an entity that is barred from performing work for the U.S. government. Questioned Costs: None Identification as a Repeat Finding: This is a repeat finding (see prior year finding number: 2023- 002). Recommendation: We recommend that the Agency establish written procurement policies and procedures to ensure that the Agency is in compliance with the Uniform Guidance and that all staff are trained on this policy to ensure compliance and related internal controls over compliance are operating effectively. Views of Responsible Officials: Management agrees with the finding and is in the process of revising internal controls to address procurement, suspension and debarment requirements. Additionally, management has retroactively performed this requirement to the applicable transactions during the audit period, noting no vendors were suspended or debarred.