Federal agency: U.S. Department of Agriculture
Federal program title: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555 and 10.559
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education
Pass-Through Number(s): 09-100
Award Period: July 1, 2023 – June 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Other Matters
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 the four 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: No
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 Agriculture
Federal program title: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555 and 10.559
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education
Pass-Through Number(s): 09-100
Award Period: July 1, 2023 – June 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Other Matters
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 the four 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: No
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 Agriculture
Federal program title: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555 and 10.559
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education
Pass-Through Number(s): 09-100
Award Period: July 1, 2023 – June 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Other Matters
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 the four 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: No
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 Agriculture
Federal program title: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555 and 10.559
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education
Pass-Through Number(s): 09-100
Award Period: July 1, 2023 – June 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Other Matters
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 the four 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: No
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 Agriculture
Federal program title: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555 and 10.559
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education
Pass-Through Number(s): 09-100
Award Period: July 1, 2023 – June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
Compliance Requirements: Procurement
Criteria or Specific Requirement: The federal Office of Management and Budget's Compliance
Supplement requires the examination of procurement files to verify that they document the history of
the procurement.
Condition and Context: For 1 of 6 vendors in our statistically valid sample, a fully signed and executed
contract was not maintained on file.
Questioned Costs: None
Cause: Procedures to obtain and file all fully signed and executed contracts need to be strengthened.
Effect: Internal controls over procurement are not fully documented.
Repeat Finding: No
Recommendation: We recommend procedures to obtain and file all fully signed and executed contracts
be strengthened.
Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Agriculture
Federal program title: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555 and 10.559
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education
Pass-Through Number(s): 09-100
Award Period: July 1, 2023 – June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
Compliance Requirements: Procurement
Criteria or Specific Requirement: The federal Office of Management and Budget's Compliance
Supplement requires the examination of procurement files to verify that they document the history of
the procurement.
Condition and Context: For 1 of 6 vendors in our statistically valid sample, a fully signed and executed
contract was not maintained on file.
Questioned Costs: None
Cause: Procedures to obtain and file all fully signed and executed contracts need to be strengthened.
Effect: Internal controls over procurement are not fully documented.
Repeat Finding: No
Recommendation: We recommend procedures to obtain and file all fully signed and executed contracts
be strengthened.
Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Agriculture
Federal program title: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555 and 10.559
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education
Pass-Through Number(s): 09-100
Award Period: July 1, 2023 – June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
Compliance Requirements: Procurement
Criteria or Specific Requirement: The federal Office of Management and Budget's Compliance
Supplement requires the examination of procurement files to verify that they document the history of
the procurement.
Condition and Context: For 1 of 6 vendors in our statistically valid sample, a fully signed and executed
contract was not maintained on file.
Questioned Costs: None
Cause: Procedures to obtain and file all fully signed and executed contracts need to be strengthened.
Effect: Internal controls over procurement are not fully documented.
Repeat Finding: No
Recommendation: We recommend procedures to obtain and file all fully signed and executed contracts
be strengthened.
Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Agriculture
Federal program title: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555 and 10.559
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education
Pass-Through Number(s): 09-100
Award Period: July 1, 2023 – June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
Compliance Requirements: Procurement
Criteria or Specific Requirement: The federal Office of Management and Budget's Compliance
Supplement requires the examination of procurement files to verify that they document the history of
the procurement.
Condition and Context: For 1 of 6 vendors in our statistically valid sample, a fully signed and executed
contract was not maintained on file.
Questioned Costs: None
Cause: Procedures to obtain and file all fully signed and executed contracts need to be strengthened.
Effect: Internal controls over procurement are not fully documented.
Repeat Finding: No
Recommendation: We recommend procedures to obtain and file all fully signed and executed contracts
be strengthened.
Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Treasury
Federal program title: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Pass-Through Agency: Massachusetts Department of Revenue
Pass-Through Number(s): ARPACNTYSH100
Award Period: July 1, 2023 – June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matter
Compliance Requirements: Reporting
Criteria or Specific Requirement: The grant program requires the filing of quarterly Project and
Expenditure reports.
Condition and Context: 1 of 4 quarterly reports was not filed.
Questioned Costs: None
Cause: Procedures to file all required reports need to be strengthened.
Effect: Noncompliance with the federal program occurred.
Repeat Finding: No
Recommendation: We recommend procedures to file all required reports be 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, 2023 – June 30, 2024
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: $29,613
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: Yes (Finding 2023-002)
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, 2023 – June 30, 2024
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 2024-002)
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: Yes (Finding 2023-003)
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, 2023 – June 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Other Matters
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 the two 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 2023-001)
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, 2023 – June 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Other Matters
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 the two 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 2023-001)
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 Agriculture
Federal program title: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555 and 10.559
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education
Pass-Through Number(s): 09-100
Award Period: July 1, 2023 – June 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Other Matters
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 the four 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: No
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 Agriculture
Federal program title: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555 and 10.559
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education
Pass-Through Number(s): 09-100
Award Period: July 1, 2023 – June 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Other Matters
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 the four 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: No
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 Agriculture
Federal program title: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555 and 10.559
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education
Pass-Through Number(s): 09-100
Award Period: July 1, 2023 – June 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Other Matters
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 the four 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: No
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 Agriculture
Federal program title: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555 and 10.559
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education
Pass-Through Number(s): 09-100
Award Period: July 1, 2023 – June 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Other Matters
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 the four 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: No
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 Agriculture
Federal program title: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555 and 10.559
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education
Pass-Through Number(s): 09-100
Award Period: July 1, 2023 – June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
Compliance Requirements: Procurement
Criteria or Specific Requirement: The federal Office of Management and Budget's Compliance
Supplement requires the examination of procurement files to verify that they document the history of
the procurement.
Condition and Context: For 1 of 6 vendors in our statistically valid sample, a fully signed and executed
contract was not maintained on file.
Questioned Costs: None
Cause: Procedures to obtain and file all fully signed and executed contracts need to be strengthened.
Effect: Internal controls over procurement are not fully documented.
Repeat Finding: No
Recommendation: We recommend procedures to obtain and file all fully signed and executed contracts
be strengthened.
Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Agriculture
Federal program title: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555 and 10.559
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education
Pass-Through Number(s): 09-100
Award Period: July 1, 2023 – June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
Compliance Requirements: Procurement
Criteria or Specific Requirement: The federal Office of Management and Budget's Compliance
Supplement requires the examination of procurement files to verify that they document the history of
the procurement.
Condition and Context: For 1 of 6 vendors in our statistically valid sample, a fully signed and executed
contract was not maintained on file.
Questioned Costs: None
Cause: Procedures to obtain and file all fully signed and executed contracts need to be strengthened.
Effect: Internal controls over procurement are not fully documented.
Repeat Finding: No
Recommendation: We recommend procedures to obtain and file all fully signed and executed contracts
be strengthened.
Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Agriculture
Federal program title: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555 and 10.559
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education
Pass-Through Number(s): 09-100
Award Period: July 1, 2023 – June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
Compliance Requirements: Procurement
Criteria or Specific Requirement: The federal Office of Management and Budget's Compliance
Supplement requires the examination of procurement files to verify that they document the history of
the procurement.
Condition and Context: For 1 of 6 vendors in our statistically valid sample, a fully signed and executed
contract was not maintained on file.
Questioned Costs: None
Cause: Procedures to obtain and file all fully signed and executed contracts need to be strengthened.
Effect: Internal controls over procurement are not fully documented.
Repeat Finding: No
Recommendation: We recommend procedures to obtain and file all fully signed and executed contracts
be strengthened.
Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Agriculture
Federal program title: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555 and 10.559
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education
Pass-Through Number(s): 09-100
Award Period: July 1, 2023 – June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
Compliance Requirements: Procurement
Criteria or Specific Requirement: The federal Office of Management and Budget's Compliance
Supplement requires the examination of procurement files to verify that they document the history of
the procurement.
Condition and Context: For 1 of 6 vendors in our statistically valid sample, a fully signed and executed
contract was not maintained on file.
Questioned Costs: None
Cause: Procedures to obtain and file all fully signed and executed contracts need to be strengthened.
Effect: Internal controls over procurement are not fully documented.
Repeat Finding: No
Recommendation: We recommend procedures to obtain and file all fully signed and executed contracts
be strengthened.
Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Treasury
Federal program title: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Pass-Through Agency: Massachusetts Department of Revenue
Pass-Through Number(s): ARPACNTYSH100
Award Period: July 1, 2023 – June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matter
Compliance Requirements: Reporting
Criteria or Specific Requirement: The grant program requires the filing of quarterly Project and
Expenditure reports.
Condition and Context: 1 of 4 quarterly reports was not filed.
Questioned Costs: None
Cause: Procedures to file all required reports need to be strengthened.
Effect: Noncompliance with the federal program occurred.
Repeat Finding: No
Recommendation: We recommend procedures to file all required reports be 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, 2023 – June 30, 2024
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: $29,613
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: Yes (Finding 2023-002)
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, 2023 – June 30, 2024
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 2024-002)
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: Yes (Finding 2023-003)
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, 2023 – June 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Other Matters
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 the two 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 2023-001)
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, 2023 – June 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Other Matters
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 the two 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 2023-001)
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.