Audit 349662

FY End
2024-06-30
Total Expended
$31.01M
Findings
4
Programs
10
Year: 2024 Accepted: 2025-03-28

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
538986 2024-001 Material Weakness - P
538987 2024-002 Significant Deficiency Yes M
1115428 2024-001 Material Weakness - P
1115429 2024-002 Significant Deficiency Yes M

Contacts

Name Title Type
ZCPNEJ3THRH3 Lisa Rogers Auditee
5088244028 Grady Connor Auditor
No contacts on file

Notes to SEFA

Title: Basis of Presentation Accounting Policies: Accounting policies and financial reporting practices permitted for municipalities in Massachusetts are prescribed by the Uniform Municipal Accounting System (UMAS) promulgated by the Commonwealth of Massachusetts Department of Revenue. Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The information included in the Schedule may not fully agree with other federal award reports the County submits to federal awarding or pass-through entities. De Minimis Rate Used: N Rate Explanation: The County did not use a diminimis cost rate. The County of Bristol, Massachusetts (the County) is a governmental entity established by the laws of the Commonwealth of Massachusetts. All operations related to the County’s federal grant programs are included in the scope of the OMB Uniform Guidance. The U.S. Department of Treasury has been designated as the County’s oversight agency for purposes of the audit. The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal award activity of the County of Bristol, Massachusetts for the year ended June 30, 2024. The information in the Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations (CFR), 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 the County it is not intended to and does not present the financial position, or changes in the financial position of the County.
Title: Summary of Significant Accounting Policies Accounting Policies: Accounting policies and financial reporting practices permitted for municipalities in Massachusetts are prescribed by the Uniform Municipal Accounting System (UMAS) promulgated by the Commonwealth of Massachusetts Department of Revenue. Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The information included in the Schedule may not fully agree with other federal award reports the County submits to federal awarding or pass-through entities. De Minimis Rate Used: N Rate Explanation: The County did not use a diminimis cost rate. Accounting policies and financial reporting practices permitted for municipalities in Massachusetts are prescribed by the Uniform Municipal Accounting System (UMAS) promulgated by the Commonwealth of Massachusetts Department of Revenue. Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The information included in the Schedule may not fully agree with other federal award reports the County submits to federal awarding or pass-through entities.
Title: Indirect Cost Rate Accounting Policies: Accounting policies and financial reporting practices permitted for municipalities in Massachusetts are prescribed by the Uniform Municipal Accounting System (UMAS) promulgated by the Commonwealth of Massachusetts Department of Revenue. Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The information included in the Schedule may not fully agree with other federal award reports the County submits to federal awarding or pass-through entities. De Minimis Rate Used: N Rate Explanation: The County did not use a diminimis cost rate. The County has not elected to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance.
Title: Cash and Non-cash assistance Accounting Policies: Accounting policies and financial reporting practices permitted for municipalities in Massachusetts are prescribed by the Uniform Municipal Accounting System (UMAS) promulgated by the Commonwealth of Massachusetts Department of Revenue. Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The information included in the Schedule may not fully agree with other federal award reports the County submits to federal awarding or pass-through entities. De Minimis Rate Used: N Rate Explanation: The County did not use a diminimis cost rate. The County received non-cash assistance related to the Child Nutrition cluster (National School Lunch- Assistance listing #10.555), for the year ended June 30, 2024. Cash assistance – expenditures represent federal reimbursement for meals during the year. Non-cash assistance – represent food commodities received under a state distribution formula and are valued at federally published wholesale prices for purposes of this schedule. Such commodities are not recorded in the financial records, although memorandum records are maintained.
Title: COVID-19 pandemic related funding Accounting Policies: Accounting policies and financial reporting practices permitted for municipalities in Massachusetts are prescribed by the Uniform Municipal Accounting System (UMAS) promulgated by the Commonwealth of Massachusetts Department of Revenue. Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The information included in the Schedule may not fully agree with other federal award reports the County submits to federal awarding or pass-through entities. De Minimis Rate Used: N Rate Explanation: The County did not use a diminimis cost rate. Programs identified in the accompanying Schedule of Expenditures of Federal Awards which have been funded pursuant to federal legislation as a result of the coronavirus pandemic have been specifically indicated with the prefix- COVID-19.
Title: Subrecipient pass-through awards Accounting Policies: Accounting policies and financial reporting practices permitted for municipalities in Massachusetts are prescribed by the Uniform Municipal Accounting System (UMAS) promulgated by the Commonwealth of Massachusetts Department of Revenue. Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The information included in the Schedule may not fully agree with other federal award reports the County submits to federal awarding or pass-through entities. De Minimis Rate Used: N Rate Explanation: The County did not use a diminimis cost rate. The County’s subrecipients for the year ended June 30, 2024, are associated with amounts paid for eligible program costs of the County’s Coronavirus State and Local Fiscal Recovery Funds – Assistance listing #21.027. This is accounted for in the County’s American Rescue Plan Program. The County’s payments to subrecipients during the fiscal year ending June 30, 2024, are represented in the following table. Returned funds represent funds returned to the County on current year applications. See the Notes to the SEFA for chart/table.

Finding Details

Procurement Criteria: The Uniform Guidance requires management to design and implement formalized internal control policies and procedures which address the compliance requirements (including procurement) associated with all federal programs administered by the grantee. Condition and context: During the current year audit, we noted (2) instances in which documentation for suspension/debarment from participating in federal awards programs was not available for our review. Additionally, while contracts (state format) with these vendors were on file, the contractual provisions indicated by the Uniform Guidance to be included in contracts involving federal funds were not present. Cause: The County utilized state approved format for contracts which did not address the requirements outlined in the Uniform Guidance for federal funds. Effect or potential effect: Noncompliance with federal provisions (including suspension/debarment) could occur. Questioned costs: $386,914. This represents the total amount paid in fiscal year 2024 associated with the two contracts identified ($140,000 and $246,914, respectively). Auditor’s recommendation: We recommend the County review procurement policies and procedures in accordance with the Uniform Guidance. Additionally, we recommend standard contractual language utilized by the County be updated accordingly. We recommend legal counsel be consulted as deemed necessary. The County should annually review federal compliance requirements for all federal programs on an annual basis.
Subrecipient monitoring Criteria: The Uniform Guidance requires grantees to design and implement formalized internal control policies and procedures which address the compliance requirements associated with all federal programs administered by the grantee. Condition and context: The County has implemented a process for subrecipient monitoring through the third-party consultant which had been engaged in the overall assistance with administration of the program. Pursuant to the agreement with the consultant, the County agrees to assume all management responsibilities; oversee services; evaluate the adequacy and results of the services; and accept responsibility for the results of the services. The first formalized subrecipient monitoring reporting began with the quarter ending June 30, 2023, issued to the County December 28, 2023. Additional quarterly monitoring reports were as follows: quarter ending September 30, 2023, issued June 8, 2024, and quarter ending December 31, 2023, issued August 5, 2024. As noted in the prior year audit, we recommended the County evaluate and enhance overall documentation as to the administration and monitoring associated with the program. However, management has not formally documented how these responsibilities are met. Cause: Due to the nature of the award and complexities involved, the County (with other counties) were required to engage third parties to assist with the administration of the program. Effect or potential effect: Noncompliance could occur. Questioned costs: None. Auditor’s recommendation: We continue to recommend the County formally document its overall responsibilities (and documentation thereof) as to management responsibilities. This should include, but not be limited to: responsibilities, duties, extent and adequacy of monitoring, timeliness, evaluation and acceptance of results.
Procurement Criteria: The Uniform Guidance requires management to design and implement formalized internal control policies and procedures which address the compliance requirements (including procurement) associated with all federal programs administered by the grantee. Condition and context: During the current year audit, we noted (2) instances in which documentation for suspension/debarment from participating in federal awards programs was not available for our review. Additionally, while contracts (state format) with these vendors were on file, the contractual provisions indicated by the Uniform Guidance to be included in contracts involving federal funds were not present. Cause: The County utilized state approved format for contracts which did not address the requirements outlined in the Uniform Guidance for federal funds. Effect or potential effect: Noncompliance with federal provisions (including suspension/debarment) could occur. Questioned costs: $386,914. This represents the total amount paid in fiscal year 2024 associated with the two contracts identified ($140,000 and $246,914, respectively). Auditor’s recommendation: We recommend the County review procurement policies and procedures in accordance with the Uniform Guidance. Additionally, we recommend standard contractual language utilized by the County be updated accordingly. We recommend legal counsel be consulted as deemed necessary. The County should annually review federal compliance requirements for all federal programs on an annual basis.
Subrecipient monitoring Criteria: The Uniform Guidance requires grantees to design and implement formalized internal control policies and procedures which address the compliance requirements associated with all federal programs administered by the grantee. Condition and context: The County has implemented a process for subrecipient monitoring through the third-party consultant which had been engaged in the overall assistance with administration of the program. Pursuant to the agreement with the consultant, the County agrees to assume all management responsibilities; oversee services; evaluate the adequacy and results of the services; and accept responsibility for the results of the services. The first formalized subrecipient monitoring reporting began with the quarter ending June 30, 2023, issued to the County December 28, 2023. Additional quarterly monitoring reports were as follows: quarter ending September 30, 2023, issued June 8, 2024, and quarter ending December 31, 2023, issued August 5, 2024. As noted in the prior year audit, we recommended the County evaluate and enhance overall documentation as to the administration and monitoring associated with the program. However, management has not formally documented how these responsibilities are met. Cause: Due to the nature of the award and complexities involved, the County (with other counties) were required to engage third parties to assist with the administration of the program. Effect or potential effect: Noncompliance could occur. Questioned costs: None. Auditor’s recommendation: We continue to recommend the County formally document its overall responsibilities (and documentation thereof) as to management responsibilities. This should include, but not be limited to: responsibilities, duties, extent and adequacy of monitoring, timeliness, evaluation and acceptance of results.