Audit 349776

Finding number: 2024-003 Federal agency: U.S. Department of Agriculture Pass-through agency: Commonwealth Department of Elementary and Second Education Program: Child Nutrition Cluster – National School Lunch Program ALN #: 10.555 Award number: 13-035 Award year: July 1, 2023 to June 30, 2024 Finding: Internal Control and Compliance over Allowability and Reporting Prior Year Finding: Yes; 2023-003 Type of Finding: Significant Deficiency and Noncompliance Criteria Allowability: Reimbursement for meals served is not based on costs; it is determined solely by applying the applicable meals times rates formula. Financial Reporting: a. Claims for Reimbursement SFAs and sponsors must submit monthly claims for reimbursement for meals and snacks served to eligible students within 60 days following the last day of the month covered by the claim (7 CFR sections 210.8, 220.11, 215.10, and 225.15(c). The state agency has an additional 30 days to submit a consolidated report to FNS (7 CFR 210.5(d), 220.13(b)(2), 215.11(c)(2), and 225.8). b. Recordkeeping Each month’s claim for reimbursement and all data used in the claims review process must be maintained on file. Accurate records must be maintained justifying all meals claimed and documenting that all Program funds were spent only on allowable Child Nutrition Program costs. Failure to maintain such records may be grounds for denial of reimbursement for meals served and/or administrative costs claimed during the period covered by the records in question. Records are required to be retained for a period of three years after submission of the final Claim for Reimbursement for the fiscal year. Or, if audit findings have not been resolved, the records must be retained beyond the three-year period aslong as required for the resolution of the issues raised by the audit. School food authorities are required to make the information available to the Department and the state agency upon request. Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our completeness and accuracy testing of the City of Boston Public Schools Food and Nutrition Services (FNS) monthly claims for reimbursement and recordkeeping, which included the allowability of meals reimbursed, we noted that edit checks were performed and documented monthly at the school site level confirming meal count reports. However, out of a sample of 60 days across 12 schools, there were 14 days across 7 schools that did not agree to the underlying manual tally sheets. Additionally, out of a sample of 12 monthly Field Coordinator reviews across 72 school sites, there were 3 reviews where the City was unable to provide evidence that the Field Coordinator’s review and approval took place. Cause This appears to be due to insufficient policies and procedures surrounding the claims for reimbursement and recordkeeping. Effect Meal count reports utilized for the monthly claims for reimbursement are not complete and accuracy, nor do they have complete and accurate underlying records to substantiate the meals requested for reimbursement. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs $108 Recommendation We recommend that FNS enhance their policies and procedures to include a more thorough review and approval of meal counts at the school level to ensure allowability as well as completeness and accuracy of the meal counts submitted for reimbursement. Additionally, we recommend FNS re-enforce their policy to ensure underlying records are maintained in accordance with program requirements. View of Responsible Officials from the Auditee FNS agrees with the importance of accurate meal counting and claiming. Because most errors result from arithmetic or data entry mistakes when cafeteria staff record meals served on paper tally sheets and laterenter totals into the computer, we now require that all meals served in the cafeterias be recorded electronically in the POS system at the point of service. We are also exploring ways to use the electronic POS system to record meals that are served in classrooms. The monthly review of school edit check reports by the field coordinators is also now documented using a Google Form that each coordinator is required to complete each month for review by the financial analyst prior to submission of the claim. We will emphasize the importance of proper meal counting and retention of documents during training for cashiers and cafeteria managers.

Finding number: 2024-004 Federal agency: U.S. Department of Agriculture Pass-through agency: Commonwealth Department of Elementary and Second Education Program: Child and Adult Care Food Program ALN #: 10.558 Award number: 13-035-CF-815 Award year: July 1, 2023 to June 30, 2024 Finding: Internal Control over Allowability Prior Year Finding: No Type of Finding: Significant Deficiency Criteria Reimbursement for Operating Costs of Child and Adult Care Centers CACFP centers and sponsors of centers shall be reimbursed solely according to the meals-times-rates formula outlined in II, “Program Procedures.” Costs claimed by the institution as operating costs must be related to preparing and serving meals to children and/or adults under the CACFP (7 CFR 226.11(c) and definition of “operating costs” in 7 CFR 226.2). Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing over the allowability of meals reimbursed, we noted that edit checks were performed and documented monthly at the school site level confirming meal count reports. However, out of a sample of 12 monthly Field Coordinator reviews across 72 school sites, there were 3 reviews where the City was unable to provide evidence that the Field Coordinator’s review and approval took place. Cause Field Coordinator edit checks were not precise enough to detect meal count differences for those sites which use a hardcopy tally sheet to count meals priors to entering into the POS system. Additionally, the City was unable to provide documentation showing that the Field Coordinator's review and approval took place in cases. This appears to be due to an insufficient process for documenting and retaining evidence of the Field Coordinator's monthly review. Effect Meal count reports utilized for the monthly claims for reimbursement are not complete and accuracy, nor do they have complete and accurate underlying records to substantiate the meals requested for reimbursement. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs None Recommendation We recommend that FNS enhance their policies and procedures to include a more thorough review and approval of meal counts at the school level to ensure allowability as well as completeness and accuracy of the meal counts submitted for reimbursement. Additionally, we recommend FNS re-enforce their policy to ensure underlying records are maintained in accordance with program requirements. View of Responsible Officials from the Auditee FNS agrees with the importance of accurate meal counting and claiming. We have implemented a new standard operating procedure for after-school supper meals served under CACFP that includes more thorough review of meal counts and related documentation prior to submission of the claim, monthly documentation of the edit check review by Field Coordinators using a Google Form, and procedures for holding program and site-based staff accountable for correctly documenting meal counts and submitting paperwork in a timely manner.

Finding number: 2024-005 Federal agency: U.S. Department of Housing and Urban Development Pass-through agency: N/A – Direct Funding Program: CDBG Entitlement/Special Purpose Grants Cluster ALN #: 14.218 Award number: Various Award year: Various Finding: Internal Control over FFATA Reporting Prior Year Finding: No Type of Finding: Significant Deficiency Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No.109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reporting should be made in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of the Special Reporting for Federal Funding Accounting and Transparency Act (FFATA) reports, we were unable to verify the review and approval of the FFATA reports by the City Auditor’s Office for 7 out of 7 reports selected for testing. Additionally, we were unable to verify the reports were submitted timely. Cause This appears to be due to lack of a formal documented review over when the FFATA reports were approved and submitted. Effect The City Auditor’s Office has an insufficient process in place to ensure the timely filing of the FFATA reports. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation We recommend that the City Auditor’s Office re-enforce control procedures to ensure that the FFATA reports formal review, approval and submission is documented. View of Responsible Officials from the Auditee The City has performed reviews and approvals prior to FFATA reports being submitted, however it has been verbal due to the proximity of the individuals working on this activity. The City will implement Google Calendar meetings and email confirmations once review is completed so that there is documentation of review approval and submission of FFATA reports.

Finding number: 2024-006 Federal agency: U.S. Department of Education Pass-through agency: Commonwealth Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies ALN #: 84.010 Award number: 0305-000549-2024-0035 Award year: September 12, 2023 to September 30, 2025 Finding: Internal Control and Compliance over Payroll Costs Prior Year Finding: Yes; 2023-006 Type of Finding: Significant Deficiency and Noncompliance Criteria In accordance with 2 CFR 200.430(i)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both Federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of allowable costs associated with payroll charges, we noted that the City of Boston Public Schools (BPS) documents time and attendance of employees on daily timesheets signed by the employee, and that these timesheets are approved by the Department Head/Supervisor on a Department Time Summary Report (DTSR). However, for our sample of 60 payroll transactions charged to the program, 3 transactions were not supported by a completed timesheet. Cause This appears to be due to an insufficient system for collecting, filing and maintaining supporting documentation for payroll transactions charged to Federal programs. Effect Insufficient review of payroll documentation increases the risk of inaccurate payroll costs being allocated to a grant award. Additionally, BPS is not in compliance with 2 CFR 200.430(i)(1) regarding documentation in support of salaries and wages charge to the federal program. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: Questioned costs of $13,382, for unsupported payroll charges, were charged to ALN # 84.010, Award No. 0305-000549-2024-0035 Recommendation We recommend that BPS re-enforce its policies and procedures to ensure their review of payroll charges and records are retained to ensure that all payroll costs charged to the federal program are supported by documentation as required by 2 CFR 200.430(i)(1). View of Responsible Officials from the Auditee BPS will add additional guidance around timesheet retention to the trainings for new timekeepers and at the annual payroll training held every August.

Finding number: 2024-007 Federal agency: U.S. Department of Education Pass-through agency: Commonwealth Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies ALN #: 84.010 Award number: Various Award year: Various Finding: Internal Control over Annual Report Card, High School Graduation Rate Prior Year Finding: Yes; 2023-009 Type of Finding: Significant Deficiency Criteria An SEA and its LEAs must report graduation rate data for all public high schools at the school, LEA, and state levels using the four-year adjusted cohort rate and, at an SEA’s or LEA’s discretion, one or more extended-year adjusted cohort rates. Graduation rate data must be reported both in the aggregate and disaggregated by the subgroups in Section 1111(c)(2) of the ESEA, homeless status, status as a child in foster care using a four-year adjusted cohort graduation rate (and any extended-year adjusted cohort rates) (ESEA sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25)(20 USC 6311(h)(1)(C)(iii)(II) and 7801(23), (25). Except as noted below, only students who earn a regular high school diploma may be counted as a graduate for purposes of calculating graduation rates. The term “regular high school diploma” means the standard high school diploma that is awarded to the preponderance of students in the state and that is fully aligned with the state standards (but not to alternate academic achievement standards for students with the most significant cognitive disabilities) or a higher diploma. A regular high school diploma does not include a recognized equivalent of a diploma, such as a general equivalency diploma (GED), certificate of completion, certificate of attendance, or similar lesser credential (ESEA, Section 8101(43) (20 USC 7801(43). An SEA may, but is not required to, award a state-defined alternate diploma for students with the most significant cognitive disabilities who take an alternate assessment aligned with alternate academic achievement standards. That diploma must be standards based, aligned with the state’s requirements for a regular high school diploma, and obtained within the time period for which the state ensures the availability of a free appropriate public education. If an SEA awards an alternate diploma, the SEA may count those students in its four-year and any extended-year adjusted cohort graduation rate, even if the student takes more than four years to receive the alternate diploma (ESEA, Section 8101(23)(A)(ii)(I)(bb), (25)(A)(ii)(I)(bb) (20 USC 7801(23)(A)(ii)(I)(bb), (25)(A)(ii)(I)(bb). To remove a student from the cohort, a school or LEA must confirm, in writing, that the student transferred out, emigrated to another country, transferred to a prison or juvenile facility, or is deceased. To confirm that a student transferred out, the school or LEA must have official written documentation that the student enrolled in another school or in an educational program that culminates in the award of a regular high school diploma. A student who is retained in grade, enrolls in a GED program, or leaves school for any other reason may not be counted as having transferred out for the purpose of calculating graduation rate and must remain in the adjusted cohort (ESEA sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25) (20 USC 6311(h)(1)(C)(iii)(II) and 7801(23), (25). Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition Per the City of Boston Public School’s (BPS) Student Withdrawal Procedures policy, school leaders are required to sign off, via a Google Form, prior to state data submissions in October, March and June that there is sufficient documentation to support all students who have withdrawn from their school. During our testing of 14 public high schools in which BPS is responsible for reporting graduation data, 6 school leaders did not submit their school’s certification for the data submission timeframe selected. Additionally, we noted 2 schools where the school leader provided a certification; however, their certification was not submitted prior to the state’s data submission. Lastly, we noted that for 2 of 60 students removed from their respective cohorts in the Student Information Management System (SIMS) selected for testing, the City of Boston Public Schools (BPS) could not provide any official written documentation that the student emigrated to another country, is deceased, or is enrolled in another school or in an education program that culminates in the award of a regular high school diploma. Cause This appears to be due to an insufficient system for collecting school leader’s certifications prior to state submission and insufficient review of supporting documentation before removal of students from the adjusted cohort graduation rate. Effect BPS is potentially misstating the number of students in the adjusted cohorts used by the Commonwealth of Massachusetts to determine the 4-year adjusted cohort graduation rate. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation BPS management should re-enforce their policy and the requirements with staff related to the removal of students from the adjusted cohorts used to determine the 4-year adjusted cohort graduation rate. In addition,BPS management should re-enforce their policies and procedures to obtain and monitor official written documentation of student transfers that is required to remove students from their respective cohort. View of Responsible Officials from the Auditee While all school leaders have not completed the certification form, BPS central office staff conduct reviews of all withdrawal documentation prior to state reporting submissions. For any student found to not have sufficient documentation in that testing, central office staff reach out to school leaders to alert them to the issue and instruct them to upload sufficient documentation. If that documentation is not uploaded by a certain date, the withdrawal codes for those students are changed to reflect a dropout status. In this year’s sample of 60 students, BPS was able to produce documentation for 58 students, a marked improvement from previous year’s samples.

Finding number: 2024-008 Federal agency: U.S. Department of Education Pass-through agency: Commonwealth Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies ALN #: 84.010 Award number: Various Award year: Various Finding: Internal Control over Assessment System Security Prior Year Finding: Yes; 2023-010 Type of Finding: Significant Deficiency Criteria SEAs, in consultation with LEAs, are required to establish and maintain an assessment system that is valid, reliable, and consistent with relevant professional and technical standards. Within their assessment system, SEAs must have policies and procedures to maintain test security and ensure that LEAs implement those policies and procedures (Title I, Section 1111(b)(2)(B)(iii) of the ESEA (20 USC 6311(b)(2)(B)(iii). Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition Each year schools who administer the Massachusetts Comprehensive Assessment System (MCAS) test are required to review and sign the Superintendent’s Assurance of Proper MCAS Test Administration form (Assurance Form), attesting their school will meet all the requirements and test administration protocols as outlined by the City of Boston Public Schools (BPS) and the Massachusetts Department of Secondary Education. During our testing of 16 schools in which BPS is responsible for administering the MCAS test, the form for one school were not obtained. Cause This appears to be due to an insufficient system for collecting and retaining school leader’s certifications ensuring they will meet all requirements and test administration protocols.Effect Schools are potentially not following all requirements and protocols related to the administration of the MCAS test and therefore not maintaining an assessment system that is valid, reliable and consistent with professional technical standards. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation BPS management should re-enforce their policy and the requirements to obtain and monitor official written documentation of school’s compliance with the administration of the MCAS test. View of Responsible Officials from the Auditee In addition to the superintendent’s assurance form, staff from the Office of Data and Accountability conduct announced and unannounced visits to schools during MCAS testing. These visits include observations of testing locations and test material storage, as well as support when questions arise. Observation notes are stored centrally.

Finding number: 2024-009 Federal agency: U.S. Department of Education Pass-through agency: Commonwealth Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies; Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants); and Student Support and Academic Enrichment Program ALN #: 84.010; 84.367; 84.424 Award number: Various Award year: Various Finding: Internal Control over Participation of Private School Children Prior Year Finding: Yes; 2023-008 Type of Finding: Significant Deficiency Criteria For programs funded under Title I, Part A (Assistance Listing 84.010), an LEA, after timely and meaningful consultation with private school officials, must provide equitable services to eligible private school children, their teachers, and their families. Eligible private school children are those who reside in a participating public school attendance area and have educational needs under Section 1115(c) of the ESEA (20 USC 6315(c). The amount of funds an LEA makes available for equitable services under Title I, Part A must be equal to the proportion of funds generated by private school children from low-income families who reside in participating public school attendance areas. An LEA must determine the proportional share available for services for eligible private school children based on the total amount of Title I funds received prior to any expenditures or transfers of funds within the program, such as reservations for administration, parental involvement, and district-wide activities (20 USC 6320(a)(4)(A). LEAs determine the proportional share by multiplying the proportion of children from low-income families who attend private schools and live in participating Title I attendance areas by the LEA’s total Title I allocation (including any funds transferred into Title I). For more information, see Title I, Part A of the ESEA: Providing Equitable Services to Eligible Private School Children, Teachers, and Families (October 7, 2019) (https://oese.ed.gov/files/2020/07/equitable-services-guidance100419.pdf). For programs under Title VIII of the ESEA (Assistance Listing 84.011, 84.365, 84.367, and 84.424), an agency, consortium, or entity receiving financial assistance under an applicable program must provide eligible private school children and their teachers or other education personnel with equitable services or other benefits under the program. Before an agency, consortium, or entity makes any decision that affects the opportunity of eligible private school children, teachers, and other educational personnel to participate, the agency, consortium, or entity must engage in timely and meaningful consultation with private school officials. Expenditures for services and benefits to eligible private school children and their teachers andother education personnel must be equal on a per-pupil basis to the expenditures for participating public school children and their teachers and other educational personnel, taking into account the number and education needs of the children, teachers and other education personnel to be services (Section 8501 of ESEA (20 USC 7881); 34 CFR sections 299.6 through 299.9). The control of funds used to provide equitable services to eligible private school students, teachers and other educational personnel, and families, and title to materials, equipment, and property purchased with those funds must be in a public agency and the public agency must administer the funds, materials, equipment, and property. The provision of equitable services must be by employees of a public agency or through a contract by the public agency with an individual, association, agency, or organization that is independent of the private school. The contract must be under the control of the public agency (Sections 1117(d), and 8501(d) of ESEA (20 USC 6320(d), and 7881(d); section 18005(b) of the CARES Act; 34 CFR sections 76.661, 200.64(b)(3), 200.67, and 299.9). Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition ALN 84.010: As part of the City of Boston Public School’s (BPS) policy over compliance with private school funding, we noted the data on children from low-income families who reside in the participating Title I public school attendance area and attend the private school is provided by the private school officials, which is then inputted and calculated by BPS on their Title I application. We were able to verify that the amount of funds available for equitable services for BPS was determined by multiplying the proportion of private school children from low-income families residing in participating public school attendance areas by the LEA’s total Title I, Part A allocation. However, we were unable to confirm completeness and accuracy of the eligible private school children counts used in the calculation as BPS did not retain the correspondence from the schools to support the data ultimately included in their calculation. ALN 84.367 and ALN 84.424: As part of BPS’ policy over compliance with private school funding, we noted the private school student count is provided by the private school officials, which is then inputted and calculated by BPS on their Title II and Title IV applications. We were able to verify that the amount of funds available for equitable services for BPS are equal on a per-pupil basis. However, we were unable to confirm completeness and accuracy of the eligible private school children counts used in the calculation as BPS did not retain the correspondence from the schools to support the data ultimately included in their calculation.Cause This appears to be due to an insufficient system in place to ensure retention of all supporting documentation related to compliance with providing equitable services for eligible private school children. Effect BPS is potentially using inaccurate or incomplete data when calculating the amount of funds available for equitable services for eligible private school children. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation When utilizing data provided by private school officials to determine the eligible private school child count, we recommend BPS retain copies of their correspondence to ensure completeness and accuracy of the calculation. View of Responsible Officials from the Auditee BPS requests that private schools wishing to participate in receiving Title funds submit detailed student eligibility information, and which is saved to an internal drive, with other supporting documentation pertaining to equitable services compliance. This adjustment to record keeping practice has been instituted beginning with the FY25 grant application cycle.

Finding number: 2024-009 Federal agency: U.S. Department of Education Pass-through agency: Commonwealth Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies; Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants); and Student Support and Academic Enrichment Program ALN #: 84.010; 84.367; 84.424 Award number: Various Award year: Various Finding: Internal Control over Participation of Private School Children Prior Year Finding: Yes; 2023-008 Type of Finding: Significant Deficiency Criteria For programs funded under Title I, Part A (Assistance Listing 84.010), an LEA, after timely and meaningful consultation with private school officials, must provide equitable services to eligible private school children, their teachers, and their families. Eligible private school children are those who reside in a participating public school attendance area and have educational needs under Section 1115(c) of the ESEA (20 USC 6315(c). The amount of funds an LEA makes available for equitable services under Title I, Part A must be equal to the proportion of funds generated by private school children from low-income families who reside in participating public school attendance areas. An LEA must determine the proportional share available for services for eligible private school children based on the total amount of Title I funds received prior to any expenditures or transfers of funds within the program, such as reservations for administration, parental involvement, and district-wide activities (20 USC 6320(a)(4)(A). LEAs determine the proportional share by multiplying the proportion of children from low-income families who attend private schools and live in participating Title I attendance areas by the LEA’s total Title I allocation (including any funds transferred into Title I). For more information, see Title I, Part A of the ESEA: Providing Equitable Services to Eligible Private School Children, Teachers, and Families (October 7, 2019) (https://oese.ed.gov/files/2020/07/equitable-services-guidance100419.pdf). For programs under Title VIII of the ESEA (Assistance Listing 84.011, 84.365, 84.367, and 84.424), an agency, consortium, or entity receiving financial assistance under an applicable program must provide eligible private school children and their teachers or other education personnel with equitable services or other benefits under the program. Before an agency, consortium, or entity makes any decision that affects the opportunity of eligible private school children, teachers, and other educational personnel to participate, the agency, consortium, or entity must engage in timely and meaningful consultation with private school officials. Expenditures for services and benefits to eligible private school children and their teachers andother education personnel must be equal on a per-pupil basis to the expenditures for participating public school children and their teachers and other educational personnel, taking into account the number and education needs of the children, teachers and other education personnel to be services (Section 8501 of ESEA (20 USC 7881); 34 CFR sections 299.6 through 299.9). The control of funds used to provide equitable services to eligible private school students, teachers and other educational personnel, and families, and title to materials, equipment, and property purchased with those funds must be in a public agency and the public agency must administer the funds, materials, equipment, and property. The provision of equitable services must be by employees of a public agency or through a contract by the public agency with an individual, association, agency, or organization that is independent of the private school. The contract must be under the control of the public agency (Sections 1117(d), and 8501(d) of ESEA (20 USC 6320(d), and 7881(d); section 18005(b) of the CARES Act; 34 CFR sections 76.661, 200.64(b)(3), 200.67, and 299.9). Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition ALN 84.010: As part of the City of Boston Public School’s (BPS) policy over compliance with private school funding, we noted the data on children from low-income families who reside in the participating Title I public school attendance area and attend the private school is provided by the private school officials, which is then inputted and calculated by BPS on their Title I application. We were able to verify that the amount of funds available for equitable services for BPS was determined by multiplying the proportion of private school children from low-income families residing in participating public school attendance areas by the LEA’s total Title I, Part A allocation. However, we were unable to confirm completeness and accuracy of the eligible private school children counts used in the calculation as BPS did not retain the correspondence from the schools to support the data ultimately included in their calculation. ALN 84.367 and ALN 84.424: As part of BPS’ policy over compliance with private school funding, we noted the private school student count is provided by the private school officials, which is then inputted and calculated by BPS on their Title II and Title IV applications. We were able to verify that the amount of funds available for equitable services for BPS are equal on a per-pupil basis. However, we were unable to confirm completeness and accuracy of the eligible private school children counts used in the calculation as BPS did not retain the correspondence from the schools to support the data ultimately included in their calculation.Cause This appears to be due to an insufficient system in place to ensure retention of all supporting documentation related to compliance with providing equitable services for eligible private school children. Effect BPS is potentially using inaccurate or incomplete data when calculating the amount of funds available for equitable services for eligible private school children. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation When utilizing data provided by private school officials to determine the eligible private school child count, we recommend BPS retain copies of their correspondence to ensure completeness and accuracy of the calculation. View of Responsible Officials from the Auditee BPS requests that private schools wishing to participate in receiving Title funds submit detailed student eligibility information, and which is saved to an internal drive, with other supporting documentation pertaining to equitable services compliance. This adjustment to record keeping practice has been instituted beginning with the FY25 grant application cycle.

Finding number: 2024-009 Federal agency: U.S. Department of Education Pass-through agency: Commonwealth Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies; Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants); and Student Support and Academic Enrichment Program ALN #: 84.010; 84.367; 84.424 Award number: Various Award year: Various Finding: Internal Control over Participation of Private School Children Prior Year Finding: Yes; 2023-008 Type of Finding: Significant Deficiency Criteria For programs funded under Title I, Part A (Assistance Listing 84.010), an LEA, after timely and meaningful consultation with private school officials, must provide equitable services to eligible private school children, their teachers, and their families. Eligible private school children are those who reside in a participating public school attendance area and have educational needs under Section 1115(c) of the ESEA (20 USC 6315(c). The amount of funds an LEA makes available for equitable services under Title I, Part A must be equal to the proportion of funds generated by private school children from low-income families who reside in participating public school attendance areas. An LEA must determine the proportional share available for services for eligible private school children based on the total amount of Title I funds received prior to any expenditures or transfers of funds within the program, such as reservations for administration, parental involvement, and district-wide activities (20 USC 6320(a)(4)(A). LEAs determine the proportional share by multiplying the proportion of children from low-income families who attend private schools and live in participating Title I attendance areas by the LEA’s total Title I allocation (including any funds transferred into Title I). For more information, see Title I, Part A of the ESEA: Providing Equitable Services to Eligible Private School Children, Teachers, and Families (October 7, 2019) (https://oese.ed.gov/files/2020/07/equitable-services-guidance100419.pdf). For programs under Title VIII of the ESEA (Assistance Listing 84.011, 84.365, 84.367, and 84.424), an agency, consortium, or entity receiving financial assistance under an applicable program must provide eligible private school children and their teachers or other education personnel with equitable services or other benefits under the program. Before an agency, consortium, or entity makes any decision that affects the opportunity of eligible private school children, teachers, and other educational personnel to participate, the agency, consortium, or entity must engage in timely and meaningful consultation with private school officials. Expenditures for services and benefits to eligible private school children and their teachers andother education personnel must be equal on a per-pupil basis to the expenditures for participating public school children and their teachers and other educational personnel, taking into account the number and education needs of the children, teachers and other education personnel to be services (Section 8501 of ESEA (20 USC 7881); 34 CFR sections 299.6 through 299.9). The control of funds used to provide equitable services to eligible private school students, teachers and other educational personnel, and families, and title to materials, equipment, and property purchased with those funds must be in a public agency and the public agency must administer the funds, materials, equipment, and property. The provision of equitable services must be by employees of a public agency or through a contract by the public agency with an individual, association, agency, or organization that is independent of the private school. The contract must be under the control of the public agency (Sections 1117(d), and 8501(d) of ESEA (20 USC 6320(d), and 7881(d); section 18005(b) of the CARES Act; 34 CFR sections 76.661, 200.64(b)(3), 200.67, and 299.9). Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition ALN 84.010: As part of the City of Boston Public School’s (BPS) policy over compliance with private school funding, we noted the data on children from low-income families who reside in the participating Title I public school attendance area and attend the private school is provided by the private school officials, which is then inputted and calculated by BPS on their Title I application. We were able to verify that the amount of funds available for equitable services for BPS was determined by multiplying the proportion of private school children from low-income families residing in participating public school attendance areas by the LEA’s total Title I, Part A allocation. However, we were unable to confirm completeness and accuracy of the eligible private school children counts used in the calculation as BPS did not retain the correspondence from the schools to support the data ultimately included in their calculation. ALN 84.367 and ALN 84.424: As part of BPS’ policy over compliance with private school funding, we noted the private school student count is provided by the private school officials, which is then inputted and calculated by BPS on their Title II and Title IV applications. We were able to verify that the amount of funds available for equitable services for BPS are equal on a per-pupil basis. However, we were unable to confirm completeness and accuracy of the eligible private school children counts used in the calculation as BPS did not retain the correspondence from the schools to support the data ultimately included in their calculation.Cause This appears to be due to an insufficient system in place to ensure retention of all supporting documentation related to compliance with providing equitable services for eligible private school children. Effect BPS is potentially using inaccurate or incomplete data when calculating the amount of funds available for equitable services for eligible private school children. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation When utilizing data provided by private school officials to determine the eligible private school child count, we recommend BPS retain copies of their correspondence to ensure completeness and accuracy of the calculation. View of Responsible Officials from the Auditee BPS requests that private schools wishing to participate in receiving Title funds submit detailed student eligibility information, and which is saved to an internal drive, with other supporting documentation pertaining to equitable services compliance. This adjustment to record keeping practice has been instituted beginning with the FY25 grant application cycle.

Finding number: 2024-010 Federal agency: U.S. Department of Education Pass-through agency: Commonwealth Department of Elementary and Secondary Education Program: Special Education (IDEA) Cluster ALN #: 84.027; 84.173 Award number: 240-714716-2023-0035; 0240-000558-2024-0035 Award year: October 3, 2022 to September 30, 2024; October 2, 2023 to September 30, 2025 Finding: Internal Control and Compliance over Payroll Costs Prior Year Finding: Yes; 2023-011 Type of Finding: Significant Deficiency and Noncompliance Criteria In accordance with 2 CFR 200.430(i)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both Federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that thenon-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of allowable costs associated with payroll charges, we noted that the City of Boston Public Schools (BPS) documents time and attendance of employees on daily timesheets signed by the employee, and that these timesheets are approved by the Department Head/Supervisor on a Department Time Summary Report (DTSR). However, for our sample of 60 payroll transactions charged to the program, 4 DTSR’s were not approved. Additionally, although the DTSR was approved, the transactions were not supported by a completed timesheet for an additional 3 selections. Cause This appears to be due to an insufficient system for collecting, filing and maintaining supporting documentation for payroll transactions charged to Federal programs. Effect Insufficient review of payroll documentation increases the risk of inaccurate payroll costs being allocated to a grant award. Additionally, BPS is not in compliance with 2 CFR 200.430(i)(1) regarding documentation in support of salaries and wages charge to the federal program. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: Questioned costs of $13,149, for unsupported payroll charges Recommendation We recommend that BPS re-enforce its policies and procedures to ensure their review of payroll charges and records are retained and documented to ensure that all payroll costs charged to the federal program are supported by documentation as required by 2 CFR 200.430(i)(1). View of Responsible Officials from the Auditee BPS will add additional guidance around timesheet retention to the trainings for new timekeepers and at the annual payroll training held every August. Additionally, BPS is exploring electronic timesheets, with a pilot focusing on staff that work at multiple sites.

Finding number: 2024-010 Federal agency: U.S. Department of Education Pass-through agency: Commonwealth Department of Elementary and Secondary Education Program: Special Education (IDEA) Cluster ALN #: 84.027; 84.173 Award number: 240-714716-2023-0035; 0240-000558-2024-0035 Award year: October 3, 2022 to September 30, 2024; October 2, 2023 to September 30, 2025 Finding: Internal Control and Compliance over Payroll Costs Prior Year Finding: Yes; 2023-011 Type of Finding: Significant Deficiency and Noncompliance Criteria In accordance with 2 CFR 200.430(i)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both Federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that thenon-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of allowable costs associated with payroll charges, we noted that the City of Boston Public Schools (BPS) documents time and attendance of employees on daily timesheets signed by the employee, and that these timesheets are approved by the Department Head/Supervisor on a Department Time Summary Report (DTSR). However, for our sample of 60 payroll transactions charged to the program, 4 DTSR’s were not approved. Additionally, although the DTSR was approved, the transactions were not supported by a completed timesheet for an additional 3 selections. Cause This appears to be due to an insufficient system for collecting, filing and maintaining supporting documentation for payroll transactions charged to Federal programs. Effect Insufficient review of payroll documentation increases the risk of inaccurate payroll costs being allocated to a grant award. Additionally, BPS is not in compliance with 2 CFR 200.430(i)(1) regarding documentation in support of salaries and wages charge to the federal program. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: Questioned costs of $13,149, for unsupported payroll charges Recommendation We recommend that BPS re-enforce its policies and procedures to ensure their review of payroll charges and records are retained and documented to ensure that all payroll costs charged to the federal program are supported by documentation as required by 2 CFR 200.430(i)(1). View of Responsible Officials from the Auditee BPS will add additional guidance around timesheet retention to the trainings for new timekeepers and at the annual payroll training held every August. Additionally, BPS is exploring electronic timesheets, with a pilot focusing on staff that work at multiple sites.

Finding number: 2024-011 Federal agency: U.S. Department of Education Pass-through agency: Commonwealth Department of Elementary and Secondary Education Program: Student Support and Academic Enrichment Program ALN #: 84.424 Award number: 0309-000548-2024-0035 Award year: September 12, 2023 to September 30, 2025 Finding: Internal Control and Compliance over Period of Performance Prior Year Finding: No Type of Finding: Material Weakness and Material Noncompliance Criteria Period of Performance A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308, 200.309, and 200.403(h). A period of performance may contain one or more budget periods. LEAs and SEAs must obligate funds during the 27 months, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. This maximum period includes a 15-month period of initial availability plus a 12-month period for carryover. Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of period of performance associated with those expenditures charged to grant awards which began during fiscal year 2024 and cost transfers, we noted noncompliance for 2 expenditures out of a sample of 4. Per review of the underlying vendor invoices, the service period for these expenditures started prior to the award start date of September 12, 2023.Cause This appears to be due to an insufficient review of invoices to ensure the underlying services performed by vendors are within the grant awards outlined grant period. Effect Insufficient review of vendor invoices increases the risk of costs being charged to a grant award outside its approved budget period. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: $1,250,864 Recommendation We recommend that the Boston Public Schools (BPS) re-enforce its policies and procedures to ensure their review of expenditures charged to the award also includes a detailed review of the underlying vendor service period. View of Responsible Officials from the Auditee BPS will take a multi-step approach to ensuring accuracy of spending to the grant award period: 1. Reinforce our existing practice of ensuring that period of service is reflected on Purchase Orders, which it was for the PO’s in question. 2. Working with major suppliers to ensure they understand the grant funded nature of their program and the eligible dates of service, which are outlined on the Purchase Order 3. Review / Update training for our Accounts Payable team on ensuring that the period of service on an invoice matches the period of service on the Purchase Order 4. Review / Update training for our State & Federal Grants, Programs, and Compliance teams to ensure that expenses are reviewed before the end of the grant period to ensure compliance with federal regulations.

Finding number: 2024-012 Federal agency: U.S. Department of Homeland Security Pass-through agency: N/A – Direct Funding Program: Staffing for Adequate Fire and Emergency Response (SAFER) ALN #: 97.083 Award number: EMW-2020-FF-00996 Award year: February 27, 2022 to February 26, 2025 Finding: Internal Control over Financial Reporting and Performance Reporting Prior Year Finding: Yes; 2023-015 and 2023-016 Type of Finding: Significant Deficiency Criteria Financial Reporting Per the Department of Homeland Security (DHS) Notice of Funding Opportunity (NOFO) for Fiscal Year 2020 Staffing for Adequate Fire and Emergency Response (SAFER) Grant Program, recipients of the SAFER Program grants are required to submit an FFR (SF-425) on a semi-annual basis. The FFR is to be submitted using the online FEMA GO based on the calendar year beginning with the period after the start of the period of performance. Grant recipients are required to submit an FFR throughout the entire period of performance of the grant. Reports are due: 1. No later than July 30 (for the period January 1 – June 30) 2. No later than January 30 (for the period July 1 – December 31) 3. Within 120 days after the end of the period of performance Performance Reporting Per the Department of Homeland Security (DHS) Notice of Funding Opportunity (NOFO) for Fiscal Year 2020 Staffing for Adequate Fire and Emergency Response (SAFER) Grant Program and the Federal Emergency Management Agency (FEMA) Grant Programs Directorate Information Bulletin No. 471, the recipient is responsible for completing and submitting a Programmatic Performance Report (PPR) using FEMA GO. For those awards which began in prior year, the PPR is due every six months based on the calendar year until the period of performance ends, and no later than 30 days after the six-month period end.Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition Financial Reporting During our testing of both semi-annual Federal Financial SF-425 (SF-425) reports, we were unable to verify approval of the SF-425 for reporting period ending 12/31/2023 by the Deputy Commissioner of the Boston Fire Department prior to submission. Performance Reporting Additionally, during our testing over both required semi-annual performance progress reports (PPRs) for fiscal year 2023, we noted the semi-annual PPR covering July 1, 2023 to December 31, 2023 was filed 65 days late on April 5, 2024. Additionally, we noted the semi-annual PPR covering January 1, 2024 to June 30, 2024 was filed one day late on August 1, 2024. Cause Financial Reporting This appears to be due to lack of a formal documented review over the semi-annual SF-425 reports. Progress Reporting This appears to be due to inadequate program detail to ensure complete and accurate information for reporting at the time of the submission deadlines. Effect Financial Reporting The Boston Fire Department (BFD) does not have effective internal controls over the Federal award to ensure the completeness and accuracy of the semi-annual SF-425 Financial Report. Performance Reporting The BFD has an insufficient process in place to ensure completeness and accuracy of the period expenditures and the timely filing of the semi-annual PPRs. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs NoneRecommendation We recommend that the BFD re-enforce control procedures to ensure that the SF-425 Financial Reports formal review and approval is documented. Additionally, we recommend that the BPD implement control procedures to ensure that the PPRs are filed timely and reviewed against supporting schedules to ensure completeness and accuracy of each report prior to submission. View of Responsible Officials from the Auditee BFD has taken considerable steps to incorporate and implement proper control procedures surrounding all grant related matters, i.e. programmatic and financial reporting and oversight. In August 2023, the department hired a Financial Grants Manager with more than ten years of experience working in municipal government with grants to ensure proper financial oversight is established and enforced. In February 2024, the department hired a Programmatic Grants Manager to ensure and implement proper policies and procedures regarding programmatic aspects of the department’s external funds. The department has acquired licenses for Airtable, an online platform for creating and sharing relational databases. It combines the features of a database and a spreadsheet, allowing users to store, organize, and collaborate on information about anything. This platform allows the department to track upcoming reporting deadlines, maintain information regarding grant related purchases, etc. The Programmatic and Financial Grants Manager have been reviewing all currently funded grants, to include SAFER, to ensure that the general ledger postings accurately reflect allowable costs so that when reports are filed the information reported in FEMA GO is accurate and complete. The Department projected that timely and accurate filing will be in effect no later than in January 2025 in order to complete the semi-annual reports due for the period ending December 31, 2024. The department had a high success rate in ensuring timely completion, approval and submission of financial reports for the most recently reporting period.

Finding number: 2024-003 Federal agency: U.S. Department of Agriculture Pass-through agency: Commonwealth Department of Elementary and Second Education Program: Child Nutrition Cluster – National School Lunch Program ALN #: 10.555 Award number: 13-035 Award year: July 1, 2023 to June 30, 2024 Finding: Internal Control and Compliance over Allowability and Reporting Prior Year Finding: Yes; 2023-003 Type of Finding: Significant Deficiency and Noncompliance Criteria Allowability: Reimbursement for meals served is not based on costs; it is determined solely by applying the applicable meals times rates formula. Financial Reporting: a. Claims for Reimbursement SFAs and sponsors must submit monthly claims for reimbursement for meals and snacks served to eligible students within 60 days following the last day of the month covered by the claim (7 CFR sections 210.8, 220.11, 215.10, and 225.15(c). The state agency has an additional 30 days to submit a consolidated report to FNS (7 CFR 210.5(d), 220.13(b)(2), 215.11(c)(2), and 225.8). b. Recordkeeping Each month’s claim for reimbursement and all data used in the claims review process must be maintained on file. Accurate records must be maintained justifying all meals claimed and documenting that all Program funds were spent only on allowable Child Nutrition Program costs. Failure to maintain such records may be grounds for denial of reimbursement for meals served and/or administrative costs claimed during the period covered by the records in question. Records are required to be retained for a period of three years after submission of the final Claim for Reimbursement for the fiscal year. Or, if audit findings have not been resolved, the records must be retained beyond the three-year period aslong as required for the resolution of the issues raised by the audit. School food authorities are required to make the information available to the Department and the state agency upon request. Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our completeness and accuracy testing of the City of Boston Public Schools Food and Nutrition Services (FNS) monthly claims for reimbursement and recordkeeping, which included the allowability of meals reimbursed, we noted that edit checks were performed and documented monthly at the school site level confirming meal count reports. However, out of a sample of 60 days across 12 schools, there were 14 days across 7 schools that did not agree to the underlying manual tally sheets. Additionally, out of a sample of 12 monthly Field Coordinator reviews across 72 school sites, there were 3 reviews where the City was unable to provide evidence that the Field Coordinator’s review and approval took place. Cause This appears to be due to insufficient policies and procedures surrounding the claims for reimbursement and recordkeeping. Effect Meal count reports utilized for the monthly claims for reimbursement are not complete and accuracy, nor do they have complete and accurate underlying records to substantiate the meals requested for reimbursement. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs $108 Recommendation We recommend that FNS enhance their policies and procedures to include a more thorough review and approval of meal counts at the school level to ensure allowability as well as completeness and accuracy of the meal counts submitted for reimbursement. Additionally, we recommend FNS re-enforce their policy to ensure underlying records are maintained in accordance with program requirements. View of Responsible Officials from the Auditee FNS agrees with the importance of accurate meal counting and claiming. Because most errors result from arithmetic or data entry mistakes when cafeteria staff record meals served on paper tally sheets and laterenter totals into the computer, we now require that all meals served in the cafeterias be recorded electronically in the POS system at the point of service. We are also exploring ways to use the electronic POS system to record meals that are served in classrooms. The monthly review of school edit check reports by the field coordinators is also now documented using a Google Form that each coordinator is required to complete each month for review by the financial analyst prior to submission of the claim. We will emphasize the importance of proper meal counting and retention of documents during training for cashiers and cafeteria managers.

Finding number: 2024-004 Federal agency: U.S. Department of Agriculture Pass-through agency: Commonwealth Department of Elementary and Second Education Program: Child and Adult Care Food Program ALN #: 10.558 Award number: 13-035-CF-815 Award year: July 1, 2023 to June 30, 2024 Finding: Internal Control over Allowability Prior Year Finding: No Type of Finding: Significant Deficiency Criteria Reimbursement for Operating Costs of Child and Adult Care Centers CACFP centers and sponsors of centers shall be reimbursed solely according to the meals-times-rates formula outlined in II, “Program Procedures.” Costs claimed by the institution as operating costs must be related to preparing and serving meals to children and/or adults under the CACFP (7 CFR 226.11(c) and definition of “operating costs” in 7 CFR 226.2). Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing over the allowability of meals reimbursed, we noted that edit checks were performed and documented monthly at the school site level confirming meal count reports. However, out of a sample of 12 monthly Field Coordinator reviews across 72 school sites, there were 3 reviews where the City was unable to provide evidence that the Field Coordinator’s review and approval took place. Cause Field Coordinator edit checks were not precise enough to detect meal count differences for those sites which use a hardcopy tally sheet to count meals priors to entering into the POS system. Additionally, the City was unable to provide documentation showing that the Field Coordinator's review and approval took place in cases. This appears to be due to an insufficient process for documenting and retaining evidence of the Field Coordinator's monthly review. Effect Meal count reports utilized for the monthly claims for reimbursement are not complete and accuracy, nor do they have complete and accurate underlying records to substantiate the meals requested for reimbursement. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs None Recommendation We recommend that FNS enhance their policies and procedures to include a more thorough review and approval of meal counts at the school level to ensure allowability as well as completeness and accuracy of the meal counts submitted for reimbursement. Additionally, we recommend FNS re-enforce their policy to ensure underlying records are maintained in accordance with program requirements. View of Responsible Officials from the Auditee FNS agrees with the importance of accurate meal counting and claiming. We have implemented a new standard operating procedure for after-school supper meals served under CACFP that includes more thorough review of meal counts and related documentation prior to submission of the claim, monthly documentation of the edit check review by Field Coordinators using a Google Form, and procedures for holding program and site-based staff accountable for correctly documenting meal counts and submitting paperwork in a timely manner.

Finding number: 2024-005 Federal agency: U.S. Department of Housing and Urban Development Pass-through agency: N/A – Direct Funding Program: CDBG Entitlement/Special Purpose Grants Cluster ALN #: 14.218 Award number: Various Award year: Various Finding: Internal Control over FFATA Reporting Prior Year Finding: No Type of Finding: Significant Deficiency Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No.109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reporting should be made in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of the Special Reporting for Federal Funding Accounting and Transparency Act (FFATA) reports, we were unable to verify the review and approval of the FFATA reports by the City Auditor’s Office for 7 out of 7 reports selected for testing. Additionally, we were unable to verify the reports were submitted timely. Cause This appears to be due to lack of a formal documented review over when the FFATA reports were approved and submitted. Effect The City Auditor’s Office has an insufficient process in place to ensure the timely filing of the FFATA reports. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation We recommend that the City Auditor’s Office re-enforce control procedures to ensure that the FFATA reports formal review, approval and submission is documented. View of Responsible Officials from the Auditee The City has performed reviews and approvals prior to FFATA reports being submitted, however it has been verbal due to the proximity of the individuals working on this activity. The City will implement Google Calendar meetings and email confirmations once review is completed so that there is documentation of review approval and submission of FFATA reports.

Finding number: 2024-006 Federal agency: U.S. Department of Education Pass-through agency: Commonwealth Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies ALN #: 84.010 Award number: 0305-000549-2024-0035 Award year: September 12, 2023 to September 30, 2025 Finding: Internal Control and Compliance over Payroll Costs Prior Year Finding: Yes; 2023-006 Type of Finding: Significant Deficiency and Noncompliance Criteria In accordance with 2 CFR 200.430(i)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both Federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of allowable costs associated with payroll charges, we noted that the City of Boston Public Schools (BPS) documents time and attendance of employees on daily timesheets signed by the employee, and that these timesheets are approved by the Department Head/Supervisor on a Department Time Summary Report (DTSR). However, for our sample of 60 payroll transactions charged to the program, 3 transactions were not supported by a completed timesheet. Cause This appears to be due to an insufficient system for collecting, filing and maintaining supporting documentation for payroll transactions charged to Federal programs. Effect Insufficient review of payroll documentation increases the risk of inaccurate payroll costs being allocated to a grant award. Additionally, BPS is not in compliance with 2 CFR 200.430(i)(1) regarding documentation in support of salaries and wages charge to the federal program. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: Questioned costs of $13,382, for unsupported payroll charges, were charged to ALN # 84.010, Award No. 0305-000549-2024-0035 Recommendation We recommend that BPS re-enforce its policies and procedures to ensure their review of payroll charges and records are retained to ensure that all payroll costs charged to the federal program are supported by documentation as required by 2 CFR 200.430(i)(1). View of Responsible Officials from the Auditee BPS will add additional guidance around timesheet retention to the trainings for new timekeepers and at the annual payroll training held every August.

Finding number: 2024-007 Federal agency: U.S. Department of Education Pass-through agency: Commonwealth Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies ALN #: 84.010 Award number: Various Award year: Various Finding: Internal Control over Annual Report Card, High School Graduation Rate Prior Year Finding: Yes; 2023-009 Type of Finding: Significant Deficiency Criteria An SEA and its LEAs must report graduation rate data for all public high schools at the school, LEA, and state levels using the four-year adjusted cohort rate and, at an SEA’s or LEA’s discretion, one or more extended-year adjusted cohort rates. Graduation rate data must be reported both in the aggregate and disaggregated by the subgroups in Section 1111(c)(2) of the ESEA, homeless status, status as a child in foster care using a four-year adjusted cohort graduation rate (and any extended-year adjusted cohort rates) (ESEA sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25)(20 USC 6311(h)(1)(C)(iii)(II) and 7801(23), (25). Except as noted below, only students who earn a regular high school diploma may be counted as a graduate for purposes of calculating graduation rates. The term “regular high school diploma” means the standard high school diploma that is awarded to the preponderance of students in the state and that is fully aligned with the state standards (but not to alternate academic achievement standards for students with the most significant cognitive disabilities) or a higher diploma. A regular high school diploma does not include a recognized equivalent of a diploma, such as a general equivalency diploma (GED), certificate of completion, certificate of attendance, or similar lesser credential (ESEA, Section 8101(43) (20 USC 7801(43). An SEA may, but is not required to, award a state-defined alternate diploma for students with the most significant cognitive disabilities who take an alternate assessment aligned with alternate academic achievement standards. That diploma must be standards based, aligned with the state’s requirements for a regular high school diploma, and obtained within the time period for which the state ensures the availability of a free appropriate public education. If an SEA awards an alternate diploma, the SEA may count those students in its four-year and any extended-year adjusted cohort graduation rate, even if the student takes more than four years to receive the alternate diploma (ESEA, Section 8101(23)(A)(ii)(I)(bb), (25)(A)(ii)(I)(bb) (20 USC 7801(23)(A)(ii)(I)(bb), (25)(A)(ii)(I)(bb). To remove a student from the cohort, a school or LEA must confirm, in writing, that the student transferred out, emigrated to another country, transferred to a prison or juvenile facility, or is deceased. To confirm that a student transferred out, the school or LEA must have official written documentation that the student enrolled in another school or in an educational program that culminates in the award of a regular high school diploma. A student who is retained in grade, enrolls in a GED program, or leaves school for any other reason may not be counted as having transferred out for the purpose of calculating graduation rate and must remain in the adjusted cohort (ESEA sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25) (20 USC 6311(h)(1)(C)(iii)(II) and 7801(23), (25). Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition Per the City of Boston Public School’s (BPS) Student Withdrawal Procedures policy, school leaders are required to sign off, via a Google Form, prior to state data submissions in October, March and June that there is sufficient documentation to support all students who have withdrawn from their school. During our testing of 14 public high schools in which BPS is responsible for reporting graduation data, 6 school leaders did not submit their school’s certification for the data submission timeframe selected. Additionally, we noted 2 schools where the school leader provided a certification; however, their certification was not submitted prior to the state’s data submission. Lastly, we noted that for 2 of 60 students removed from their respective cohorts in the Student Information Management System (SIMS) selected for testing, the City of Boston Public Schools (BPS) could not provide any official written documentation that the student emigrated to another country, is deceased, or is enrolled in another school or in an education program that culminates in the award of a regular high school diploma. Cause This appears to be due to an insufficient system for collecting school leader’s certifications prior to state submission and insufficient review of supporting documentation before removal of students from the adjusted cohort graduation rate. Effect BPS is potentially misstating the number of students in the adjusted cohorts used by the Commonwealth of Massachusetts to determine the 4-year adjusted cohort graduation rate. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation BPS management should re-enforce their policy and the requirements with staff related to the removal of students from the adjusted cohorts used to determine the 4-year adjusted cohort graduation rate. In addition,BPS management should re-enforce their policies and procedures to obtain and monitor official written documentation of student transfers that is required to remove students from their respective cohort. View of Responsible Officials from the Auditee While all school leaders have not completed the certification form, BPS central office staff conduct reviews of all withdrawal documentation prior to state reporting submissions. For any student found to not have sufficient documentation in that testing, central office staff reach out to school leaders to alert them to the issue and instruct them to upload sufficient documentation. If that documentation is not uploaded by a certain date, the withdrawal codes for those students are changed to reflect a dropout status. In this year’s sample of 60 students, BPS was able to produce documentation for 58 students, a marked improvement from previous year’s samples.

Finding number: 2024-008 Federal agency: U.S. Department of Education Pass-through agency: Commonwealth Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies ALN #: 84.010 Award number: Various Award year: Various Finding: Internal Control over Assessment System Security Prior Year Finding: Yes; 2023-010 Type of Finding: Significant Deficiency Criteria SEAs, in consultation with LEAs, are required to establish and maintain an assessment system that is valid, reliable, and consistent with relevant professional and technical standards. Within their assessment system, SEAs must have policies and procedures to maintain test security and ensure that LEAs implement those policies and procedures (Title I, Section 1111(b)(2)(B)(iii) of the ESEA (20 USC 6311(b)(2)(B)(iii). Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition Each year schools who administer the Massachusetts Comprehensive Assessment System (MCAS) test are required to review and sign the Superintendent’s Assurance of Proper MCAS Test Administration form (Assurance Form), attesting their school will meet all the requirements and test administration protocols as outlined by the City of Boston Public Schools (BPS) and the Massachusetts Department of Secondary Education. During our testing of 16 schools in which BPS is responsible for administering the MCAS test, the form for one school were not obtained. Cause This appears to be due to an insufficient system for collecting and retaining school leader’s certifications ensuring they will meet all requirements and test administration protocols.Effect Schools are potentially not following all requirements and protocols related to the administration of the MCAS test and therefore not maintaining an assessment system that is valid, reliable and consistent with professional technical standards. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation BPS management should re-enforce their policy and the requirements to obtain and monitor official written documentation of school’s compliance with the administration of the MCAS test. View of Responsible Officials from the Auditee In addition to the superintendent’s assurance form, staff from the Office of Data and Accountability conduct announced and unannounced visits to schools during MCAS testing. These visits include observations of testing locations and test material storage, as well as support when questions arise. Observation notes are stored centrally.

Finding number: 2024-009 Federal agency: U.S. Department of Education Pass-through agency: Commonwealth Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies; Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants); and Student Support and Academic Enrichment Program ALN #: 84.010; 84.367; 84.424 Award number: Various Award year: Various Finding: Internal Control over Participation of Private School Children Prior Year Finding: Yes; 2023-008 Type of Finding: Significant Deficiency Criteria For programs funded under Title I, Part A (Assistance Listing 84.010), an LEA, after timely and meaningful consultation with private school officials, must provide equitable services to eligible private school children, their teachers, and their families. Eligible private school children are those who reside in a participating public school attendance area and have educational needs under Section 1115(c) of the ESEA (20 USC 6315(c). The amount of funds an LEA makes available for equitable services under Title I, Part A must be equal to the proportion of funds generated by private school children from low-income families who reside in participating public school attendance areas. An LEA must determine the proportional share available for services for eligible private school children based on the total amount of Title I funds received prior to any expenditures or transfers of funds within the program, such as reservations for administration, parental involvement, and district-wide activities (20 USC 6320(a)(4)(A). LEAs determine the proportional share by multiplying the proportion of children from low-income families who attend private schools and live in participating Title I attendance areas by the LEA’s total Title I allocation (including any funds transferred into Title I). For more information, see Title I, Part A of the ESEA: Providing Equitable Services to Eligible Private School Children, Teachers, and Families (October 7, 2019) (https://oese.ed.gov/files/2020/07/equitable-services-guidance100419.pdf). For programs under Title VIII of the ESEA (Assistance Listing 84.011, 84.365, 84.367, and 84.424), an agency, consortium, or entity receiving financial assistance under an applicable program must provide eligible private school children and their teachers or other education personnel with equitable services or other benefits under the program. Before an agency, consortium, or entity makes any decision that affects the opportunity of eligible private school children, teachers, and other educational personnel to participate, the agency, consortium, or entity must engage in timely and meaningful consultation with private school officials. Expenditures for services and benefits to eligible private school children and their teachers andother education personnel must be equal on a per-pupil basis to the expenditures for participating public school children and their teachers and other educational personnel, taking into account the number and education needs of the children, teachers and other education personnel to be services (Section 8501 of ESEA (20 USC 7881); 34 CFR sections 299.6 through 299.9). The control of funds used to provide equitable services to eligible private school students, teachers and other educational personnel, and families, and title to materials, equipment, and property purchased with those funds must be in a public agency and the public agency must administer the funds, materials, equipment, and property. The provision of equitable services must be by employees of a public agency or through a contract by the public agency with an individual, association, agency, or organization that is independent of the private school. The contract must be under the control of the public agency (Sections 1117(d), and 8501(d) of ESEA (20 USC 6320(d), and 7881(d); section 18005(b) of the CARES Act; 34 CFR sections 76.661, 200.64(b)(3), 200.67, and 299.9). Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition ALN 84.010: As part of the City of Boston Public School’s (BPS) policy over compliance with private school funding, we noted the data on children from low-income families who reside in the participating Title I public school attendance area and attend the private school is provided by the private school officials, which is then inputted and calculated by BPS on their Title I application. We were able to verify that the amount of funds available for equitable services for BPS was determined by multiplying the proportion of private school children from low-income families residing in participating public school attendance areas by the LEA’s total Title I, Part A allocation. However, we were unable to confirm completeness and accuracy of the eligible private school children counts used in the calculation as BPS did not retain the correspondence from the schools to support the data ultimately included in their calculation. ALN 84.367 and ALN 84.424: As part of BPS’ policy over compliance with private school funding, we noted the private school student count is provided by the private school officials, which is then inputted and calculated by BPS on their Title II and Title IV applications. We were able to verify that the amount of funds available for equitable services for BPS are equal on a per-pupil basis. However, we were unable to confirm completeness and accuracy of the eligible private school children counts used in the calculation as BPS did not retain the correspondence from the schools to support the data ultimately included in their calculation.Cause This appears to be due to an insufficient system in place to ensure retention of all supporting documentation related to compliance with providing equitable services for eligible private school children. Effect BPS is potentially using inaccurate or incomplete data when calculating the amount of funds available for equitable services for eligible private school children. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation When utilizing data provided by private school officials to determine the eligible private school child count, we recommend BPS retain copies of their correspondence to ensure completeness and accuracy of the calculation. View of Responsible Officials from the Auditee BPS requests that private schools wishing to participate in receiving Title funds submit detailed student eligibility information, and which is saved to an internal drive, with other supporting documentation pertaining to equitable services compliance. This adjustment to record keeping practice has been instituted beginning with the FY25 grant application cycle.

Finding number: 2024-009 Federal agency: U.S. Department of Education Pass-through agency: Commonwealth Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies; Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants); and Student Support and Academic Enrichment Program ALN #: 84.010; 84.367; 84.424 Award number: Various Award year: Various Finding: Internal Control over Participation of Private School Children Prior Year Finding: Yes; 2023-008 Type of Finding: Significant Deficiency Criteria For programs funded under Title I, Part A (Assistance Listing 84.010), an LEA, after timely and meaningful consultation with private school officials, must provide equitable services to eligible private school children, their teachers, and their families. Eligible private school children are those who reside in a participating public school attendance area and have educational needs under Section 1115(c) of the ESEA (20 USC 6315(c). The amount of funds an LEA makes available for equitable services under Title I, Part A must be equal to the proportion of funds generated by private school children from low-income families who reside in participating public school attendance areas. An LEA must determine the proportional share available for services for eligible private school children based on the total amount of Title I funds received prior to any expenditures or transfers of funds within the program, such as reservations for administration, parental involvement, and district-wide activities (20 USC 6320(a)(4)(A). LEAs determine the proportional share by multiplying the proportion of children from low-income families who attend private schools and live in participating Title I attendance areas by the LEA’s total Title I allocation (including any funds transferred into Title I). For more information, see Title I, Part A of the ESEA: Providing Equitable Services to Eligible Private School Children, Teachers, and Families (October 7, 2019) (https://oese.ed.gov/files/2020/07/equitable-services-guidance100419.pdf). For programs under Title VIII of the ESEA (Assistance Listing 84.011, 84.365, 84.367, and 84.424), an agency, consortium, or entity receiving financial assistance under an applicable program must provide eligible private school children and their teachers or other education personnel with equitable services or other benefits under the program. Before an agency, consortium, or entity makes any decision that affects the opportunity of eligible private school children, teachers, and other educational personnel to participate, the agency, consortium, or entity must engage in timely and meaningful consultation with private school officials. Expenditures for services and benefits to eligible private school children and their teachers andother education personnel must be equal on a per-pupil basis to the expenditures for participating public school children and their teachers and other educational personnel, taking into account the number and education needs of the children, teachers and other education personnel to be services (Section 8501 of ESEA (20 USC 7881); 34 CFR sections 299.6 through 299.9). The control of funds used to provide equitable services to eligible private school students, teachers and other educational personnel, and families, and title to materials, equipment, and property purchased with those funds must be in a public agency and the public agency must administer the funds, materials, equipment, and property. The provision of equitable services must be by employees of a public agency or through a contract by the public agency with an individual, association, agency, or organization that is independent of the private school. The contract must be under the control of the public agency (Sections 1117(d), and 8501(d) of ESEA (20 USC 6320(d), and 7881(d); section 18005(b) of the CARES Act; 34 CFR sections 76.661, 200.64(b)(3), 200.67, and 299.9). Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition ALN 84.010: As part of the City of Boston Public School’s (BPS) policy over compliance with private school funding, we noted the data on children from low-income families who reside in the participating Title I public school attendance area and attend the private school is provided by the private school officials, which is then inputted and calculated by BPS on their Title I application. We were able to verify that the amount of funds available for equitable services for BPS was determined by multiplying the proportion of private school children from low-income families residing in participating public school attendance areas by the LEA’s total Title I, Part A allocation. However, we were unable to confirm completeness and accuracy of the eligible private school children counts used in the calculation as BPS did not retain the correspondence from the schools to support the data ultimately included in their calculation. ALN 84.367 and ALN 84.424: As part of BPS’ policy over compliance with private school funding, we noted the private school student count is provided by the private school officials, which is then inputted and calculated by BPS on their Title II and Title IV applications. We were able to verify that the amount of funds available for equitable services for BPS are equal on a per-pupil basis. However, we were unable to confirm completeness and accuracy of the eligible private school children counts used in the calculation as BPS did not retain the correspondence from the schools to support the data ultimately included in their calculation.Cause This appears to be due to an insufficient system in place to ensure retention of all supporting documentation related to compliance with providing equitable services for eligible private school children. Effect BPS is potentially using inaccurate or incomplete data when calculating the amount of funds available for equitable services for eligible private school children. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation When utilizing data provided by private school officials to determine the eligible private school child count, we recommend BPS retain copies of their correspondence to ensure completeness and accuracy of the calculation. View of Responsible Officials from the Auditee BPS requests that private schools wishing to participate in receiving Title funds submit detailed student eligibility information, and which is saved to an internal drive, with other supporting documentation pertaining to equitable services compliance. This adjustment to record keeping practice has been instituted beginning with the FY25 grant application cycle.

Finding number: 2024-009 Federal agency: U.S. Department of Education Pass-through agency: Commonwealth Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies; Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants); and Student Support and Academic Enrichment Program ALN #: 84.010; 84.367; 84.424 Award number: Various Award year: Various Finding: Internal Control over Participation of Private School Children Prior Year Finding: Yes; 2023-008 Type of Finding: Significant Deficiency Criteria For programs funded under Title I, Part A (Assistance Listing 84.010), an LEA, after timely and meaningful consultation with private school officials, must provide equitable services to eligible private school children, their teachers, and their families. Eligible private school children are those who reside in a participating public school attendance area and have educational needs under Section 1115(c) of the ESEA (20 USC 6315(c). The amount of funds an LEA makes available for equitable services under Title I, Part A must be equal to the proportion of funds generated by private school children from low-income families who reside in participating public school attendance areas. An LEA must determine the proportional share available for services for eligible private school children based on the total amount of Title I funds received prior to any expenditures or transfers of funds within the program, such as reservations for administration, parental involvement, and district-wide activities (20 USC 6320(a)(4)(A). LEAs determine the proportional share by multiplying the proportion of children from low-income families who attend private schools and live in participating Title I attendance areas by the LEA’s total Title I allocation (including any funds transferred into Title I). For more information, see Title I, Part A of the ESEA: Providing Equitable Services to Eligible Private School Children, Teachers, and Families (October 7, 2019) (https://oese.ed.gov/files/2020/07/equitable-services-guidance100419.pdf). For programs under Title VIII of the ESEA (Assistance Listing 84.011, 84.365, 84.367, and 84.424), an agency, consortium, or entity receiving financial assistance under an applicable program must provide eligible private school children and their teachers or other education personnel with equitable services or other benefits under the program. Before an agency, consortium, or entity makes any decision that affects the opportunity of eligible private school children, teachers, and other educational personnel to participate, the agency, consortium, or entity must engage in timely and meaningful consultation with private school officials. Expenditures for services and benefits to eligible private school children and their teachers andother education personnel must be equal on a per-pupil basis to the expenditures for participating public school children and their teachers and other educational personnel, taking into account the number and education needs of the children, teachers and other education personnel to be services (Section 8501 of ESEA (20 USC 7881); 34 CFR sections 299.6 through 299.9). The control of funds used to provide equitable services to eligible private school students, teachers and other educational personnel, and families, and title to materials, equipment, and property purchased with those funds must be in a public agency and the public agency must administer the funds, materials, equipment, and property. The provision of equitable services must be by employees of a public agency or through a contract by the public agency with an individual, association, agency, or organization that is independent of the private school. The contract must be under the control of the public agency (Sections 1117(d), and 8501(d) of ESEA (20 USC 6320(d), and 7881(d); section 18005(b) of the CARES Act; 34 CFR sections 76.661, 200.64(b)(3), 200.67, and 299.9). Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition ALN 84.010: As part of the City of Boston Public School’s (BPS) policy over compliance with private school funding, we noted the data on children from low-income families who reside in the participating Title I public school attendance area and attend the private school is provided by the private school officials, which is then inputted and calculated by BPS on their Title I application. We were able to verify that the amount of funds available for equitable services for BPS was determined by multiplying the proportion of private school children from low-income families residing in participating public school attendance areas by the LEA’s total Title I, Part A allocation. However, we were unable to confirm completeness and accuracy of the eligible private school children counts used in the calculation as BPS did not retain the correspondence from the schools to support the data ultimately included in their calculation. ALN 84.367 and ALN 84.424: As part of BPS’ policy over compliance with private school funding, we noted the private school student count is provided by the private school officials, which is then inputted and calculated by BPS on their Title II and Title IV applications. We were able to verify that the amount of funds available for equitable services for BPS are equal on a per-pupil basis. However, we were unable to confirm completeness and accuracy of the eligible private school children counts used in the calculation as BPS did not retain the correspondence from the schools to support the data ultimately included in their calculation.Cause This appears to be due to an insufficient system in place to ensure retention of all supporting documentation related to compliance with providing equitable services for eligible private school children. Effect BPS is potentially using inaccurate or incomplete data when calculating the amount of funds available for equitable services for eligible private school children. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation When utilizing data provided by private school officials to determine the eligible private school child count, we recommend BPS retain copies of their correspondence to ensure completeness and accuracy of the calculation. View of Responsible Officials from the Auditee BPS requests that private schools wishing to participate in receiving Title funds submit detailed student eligibility information, and which is saved to an internal drive, with other supporting documentation pertaining to equitable services compliance. This adjustment to record keeping practice has been instituted beginning with the FY25 grant application cycle.

Finding number: 2024-010 Federal agency: U.S. Department of Education Pass-through agency: Commonwealth Department of Elementary and Secondary Education Program: Special Education (IDEA) Cluster ALN #: 84.027; 84.173 Award number: 240-714716-2023-0035; 0240-000558-2024-0035 Award year: October 3, 2022 to September 30, 2024; October 2, 2023 to September 30, 2025 Finding: Internal Control and Compliance over Payroll Costs Prior Year Finding: Yes; 2023-011 Type of Finding: Significant Deficiency and Noncompliance Criteria In accordance with 2 CFR 200.430(i)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both Federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that thenon-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of allowable costs associated with payroll charges, we noted that the City of Boston Public Schools (BPS) documents time and attendance of employees on daily timesheets signed by the employee, and that these timesheets are approved by the Department Head/Supervisor on a Department Time Summary Report (DTSR). However, for our sample of 60 payroll transactions charged to the program, 4 DTSR’s were not approved. Additionally, although the DTSR was approved, the transactions were not supported by a completed timesheet for an additional 3 selections. Cause This appears to be due to an insufficient system for collecting, filing and maintaining supporting documentation for payroll transactions charged to Federal programs. Effect Insufficient review of payroll documentation increases the risk of inaccurate payroll costs being allocated to a grant award. Additionally, BPS is not in compliance with 2 CFR 200.430(i)(1) regarding documentation in support of salaries and wages charge to the federal program. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: Questioned costs of $13,149, for unsupported payroll charges Recommendation We recommend that BPS re-enforce its policies and procedures to ensure their review of payroll charges and records are retained and documented to ensure that all payroll costs charged to the federal program are supported by documentation as required by 2 CFR 200.430(i)(1). View of Responsible Officials from the Auditee BPS will add additional guidance around timesheet retention to the trainings for new timekeepers and at the annual payroll training held every August. Additionally, BPS is exploring electronic timesheets, with a pilot focusing on staff that work at multiple sites.

Finding number: 2024-010 Federal agency: U.S. Department of Education Pass-through agency: Commonwealth Department of Elementary and Secondary Education Program: Special Education (IDEA) Cluster ALN #: 84.027; 84.173 Award number: 240-714716-2023-0035; 0240-000558-2024-0035 Award year: October 3, 2022 to September 30, 2024; October 2, 2023 to September 30, 2025 Finding: Internal Control and Compliance over Payroll Costs Prior Year Finding: Yes; 2023-011 Type of Finding: Significant Deficiency and Noncompliance Criteria In accordance with 2 CFR 200.430(i)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both Federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that thenon-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of allowable costs associated with payroll charges, we noted that the City of Boston Public Schools (BPS) documents time and attendance of employees on daily timesheets signed by the employee, and that these timesheets are approved by the Department Head/Supervisor on a Department Time Summary Report (DTSR). However, for our sample of 60 payroll transactions charged to the program, 4 DTSR’s were not approved. Additionally, although the DTSR was approved, the transactions were not supported by a completed timesheet for an additional 3 selections. Cause This appears to be due to an insufficient system for collecting, filing and maintaining supporting documentation for payroll transactions charged to Federal programs. Effect Insufficient review of payroll documentation increases the risk of inaccurate payroll costs being allocated to a grant award. Additionally, BPS is not in compliance with 2 CFR 200.430(i)(1) regarding documentation in support of salaries and wages charge to the federal program. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: Questioned costs of $13,149, for unsupported payroll charges Recommendation We recommend that BPS re-enforce its policies and procedures to ensure their review of payroll charges and records are retained and documented to ensure that all payroll costs charged to the federal program are supported by documentation as required by 2 CFR 200.430(i)(1). View of Responsible Officials from the Auditee BPS will add additional guidance around timesheet retention to the trainings for new timekeepers and at the annual payroll training held every August. Additionally, BPS is exploring electronic timesheets, with a pilot focusing on staff that work at multiple sites.

Finding number: 2024-011 Federal agency: U.S. Department of Education Pass-through agency: Commonwealth Department of Elementary and Secondary Education Program: Student Support and Academic Enrichment Program ALN #: 84.424 Award number: 0309-000548-2024-0035 Award year: September 12, 2023 to September 30, 2025 Finding: Internal Control and Compliance over Period of Performance Prior Year Finding: No Type of Finding: Material Weakness and Material Noncompliance Criteria Period of Performance A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308, 200.309, and 200.403(h). A period of performance may contain one or more budget periods. LEAs and SEAs must obligate funds during the 27 months, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. This maximum period includes a 15-month period of initial availability plus a 12-month period for carryover. Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of period of performance associated with those expenditures charged to grant awards which began during fiscal year 2024 and cost transfers, we noted noncompliance for 2 expenditures out of a sample of 4. Per review of the underlying vendor invoices, the service period for these expenditures started prior to the award start date of September 12, 2023.Cause This appears to be due to an insufficient review of invoices to ensure the underlying services performed by vendors are within the grant awards outlined grant period. Effect Insufficient review of vendor invoices increases the risk of costs being charged to a grant award outside its approved budget period. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: $1,250,864 Recommendation We recommend that the Boston Public Schools (BPS) re-enforce its policies and procedures to ensure their review of expenditures charged to the award also includes a detailed review of the underlying vendor service period. View of Responsible Officials from the Auditee BPS will take a multi-step approach to ensuring accuracy of spending to the grant award period: 1. Reinforce our existing practice of ensuring that period of service is reflected on Purchase Orders, which it was for the PO’s in question. 2. Working with major suppliers to ensure they understand the grant funded nature of their program and the eligible dates of service, which are outlined on the Purchase Order 3. Review / Update training for our Accounts Payable team on ensuring that the period of service on an invoice matches the period of service on the Purchase Order 4. Review / Update training for our State & Federal Grants, Programs, and Compliance teams to ensure that expenses are reviewed before the end of the grant period to ensure compliance with federal regulations.

Finding number: 2024-012 Federal agency: U.S. Department of Homeland Security Pass-through agency: N/A – Direct Funding Program: Staffing for Adequate Fire and Emergency Response (SAFER) ALN #: 97.083 Award number: EMW-2020-FF-00996 Award year: February 27, 2022 to February 26, 2025 Finding: Internal Control over Financial Reporting and Performance Reporting Prior Year Finding: Yes; 2023-015 and 2023-016 Type of Finding: Significant Deficiency Criteria Financial Reporting Per the Department of Homeland Security (DHS) Notice of Funding Opportunity (NOFO) for Fiscal Year 2020 Staffing for Adequate Fire and Emergency Response (SAFER) Grant Program, recipients of the SAFER Program grants are required to submit an FFR (SF-425) on a semi-annual basis. The FFR is to be submitted using the online FEMA GO based on the calendar year beginning with the period after the start of the period of performance. Grant recipients are required to submit an FFR throughout the entire period of performance of the grant. Reports are due: 1. No later than July 30 (for the period January 1 – June 30) 2. No later than January 30 (for the period July 1 – December 31) 3. Within 120 days after the end of the period of performance Performance Reporting Per the Department of Homeland Security (DHS) Notice of Funding Opportunity (NOFO) for Fiscal Year 2020 Staffing for Adequate Fire and Emergency Response (SAFER) Grant Program and the Federal Emergency Management Agency (FEMA) Grant Programs Directorate Information Bulletin No. 471, the recipient is responsible for completing and submitting a Programmatic Performance Report (PPR) using FEMA GO. For those awards which began in prior year, the PPR is due every six months based on the calendar year until the period of performance ends, and no later than 30 days after the six-month period end.Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition Financial Reporting During our testing of both semi-annual Federal Financial SF-425 (SF-425) reports, we were unable to verify approval of the SF-425 for reporting period ending 12/31/2023 by the Deputy Commissioner of the Boston Fire Department prior to submission. Performance Reporting Additionally, during our testing over both required semi-annual performance progress reports (PPRs) for fiscal year 2023, we noted the semi-annual PPR covering July 1, 2023 to December 31, 2023 was filed 65 days late on April 5, 2024. Additionally, we noted the semi-annual PPR covering January 1, 2024 to June 30, 2024 was filed one day late on August 1, 2024. Cause Financial Reporting This appears to be due to lack of a formal documented review over the semi-annual SF-425 reports. Progress Reporting This appears to be due to inadequate program detail to ensure complete and accurate information for reporting at the time of the submission deadlines. Effect Financial Reporting The Boston Fire Department (BFD) does not have effective internal controls over the Federal award to ensure the completeness and accuracy of the semi-annual SF-425 Financial Report. Performance Reporting The BFD has an insufficient process in place to ensure completeness and accuracy of the period expenditures and the timely filing of the semi-annual PPRs. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs NoneRecommendation We recommend that the BFD re-enforce control procedures to ensure that the SF-425 Financial Reports formal review and approval is documented. Additionally, we recommend that the BPD implement control procedures to ensure that the PPRs are filed timely and reviewed against supporting schedules to ensure completeness and accuracy of each report prior to submission. View of Responsible Officials from the Auditee BFD has taken considerable steps to incorporate and implement proper control procedures surrounding all grant related matters, i.e. programmatic and financial reporting and oversight. In August 2023, the department hired a Financial Grants Manager with more than ten years of experience working in municipal government with grants to ensure proper financial oversight is established and enforced. In February 2024, the department hired a Programmatic Grants Manager to ensure and implement proper policies and procedures regarding programmatic aspects of the department’s external funds. The department has acquired licenses for Airtable, an online platform for creating and sharing relational databases. It combines the features of a database and a spreadsheet, allowing users to store, organize, and collaborate on information about anything. This platform allows the department to track upcoming reporting deadlines, maintain information regarding grant related purchases, etc. The Programmatic and Financial Grants Manager have been reviewing all currently funded grants, to include SAFER, to ensure that the general ledger postings accurately reflect allowable costs so that when reports are filed the information reported in FEMA GO is accurate and complete. The Department projected that timely and accurate filing will be in effect no later than in January 2025 in order to complete the semi-annual reports due for the period ending December 31, 2024. The department had a high success rate in ensuring timely completion, approval and submission of financial reports for the most recently reporting period.