Audit 350527

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of Allowable Costs/Cost Principles. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Payroll systems must be based on records that accurately reflect the work performed and supported by a system of internal controls that provides reasonable assurance that charges are accurate; allowable and reasonable; and properly allocated. Condition: Internal controls were not in place to ensure time and effort documentation was consistently tracked and supported. Questioned costs: $3,084 Context: For 4 of 40 payroll transactions tested, we identified the City did not maintain documentation of time and effort supporting the charges to the program. Cause: Procedures are not in place to maintain the required supporting documentation for the salaries charged to the grant. Effect: The salary charges are subject to disallowance and are considered questioned costs. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-002. Recommendation: We recommend management implement procedures to ensure that salaries charged to the grant are appropriate and are supported by the required time and effort support and that a consistent policy is applied. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of Allowable Costs/Cost Principles. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Payroll systems must be based on records that accurately reflect the work performed and supported by a system of internal controls that provides reasonable assurance that charges are accurate; allowable and reasonable; and properly allocated. Condition: Internal controls were not in place to ensure time and effort documentation was consistently tracked and supported. Questioned costs: $3,084 Context: For 4 of 40 payroll transactions tested, we identified the City did not maintain documentation of time and effort supporting the charges to the program. Cause: Procedures are not in place to maintain the required supporting documentation for the salaries charged to the grant. Effect: The salary charges are subject to disallowance and are considered questioned costs. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-002. Recommendation: We recommend management implement procedures to ensure that salaries charged to the grant are appropriate and are supported by the required time and effort support and that a consistent policy is applied. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of Allowable Costs/Cost Principles. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Payroll systems must be based on records that accurately reflect the work performed and supported by a system of internal controls that provides reasonable assurance that charges are accurate; allowable and reasonable; and properly allocated. Condition: Internal controls were not in place to ensure time and effort documentation was consistently tracked and supported. Questioned costs: $3,084 Context: For 4 of 40 payroll transactions tested, we identified the City did not maintain documentation of time and effort supporting the charges to the program. Cause: Procedures are not in place to maintain the required supporting documentation for the salaries charged to the grant. Effect: The salary charges are subject to disallowance and are considered questioned costs. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-002. Recommendation: We recommend management implement procedures to ensure that salaries charged to the grant are appropriate and are supported by the required time and effort support and that a consistent policy is applied. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of Allowable Costs/Cost Principles. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Payroll systems must be based on records that accurately reflect the work performed and supported by a system of internal controls that provides reasonable assurance that charges are accurate; allowable and reasonable; and properly allocated. Condition: Internal controls were not in place to ensure time and effort documentation was consistently tracked and supported. Questioned costs: $3,084 Context: For 4 of 40 payroll transactions tested, we identified the City did not maintain documentation of time and effort supporting the charges to the program. Cause: Procedures are not in place to maintain the required supporting documentation for the salaries charged to the grant. Effect: The salary charges are subject to disallowance and are considered questioned costs. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-002. Recommendation: We recommend management implement procedures to ensure that salaries charged to the grant are appropriate and are supported by the required time and effort support and that a consistent policy is applied. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of Allowable Costs/Cost Principles. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Payroll systems must be based on records that accurately reflect the work performed and supported by a system of internal controls that provides reasonable assurance that charges are accurate; allowable and reasonable; and properly allocated. Condition: Internal controls were not in place to ensure time and effort documentation was consistently tracked and supported. Questioned costs: $3,084 Context: For 4 of 40 payroll transactions tested, we identified the City did not maintain documentation of time and effort supporting the charges to the program. Cause: Procedures are not in place to maintain the required supporting documentation for the salaries charged to the grant. Effect: The salary charges are subject to disallowance and are considered questioned costs. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-002. Recommendation: We recommend management implement procedures to ensure that salaries charged to the grant are appropriate and are supported by the required time and effort support and that a consistent policy is applied. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of Allowable Costs/Cost Principles. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Payroll systems must be based on records that accurately reflect the work performed and supported by a system of internal controls that provides reasonable assurance that charges are accurate; allowable and reasonable; and properly allocated. Condition: Internal controls were not in place to ensure time and effort documentation was consistently tracked and supported. Questioned costs: $3,084 Context: For 4 of 40 payroll transactions tested, we identified the City did not maintain documentation of time and effort supporting the charges to the program. Cause: Procedures are not in place to maintain the required supporting documentation for the salaries charged to the grant. Effect: The salary charges are subject to disallowance and are considered questioned costs. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-002. Recommendation: We recommend management implement procedures to ensure that salaries charged to the grant are appropriate and are supported by the required time and effort support and that a consistent policy is applied. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of Allowable Costs/Cost Principles. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Payroll systems must be based on records that accurately reflect the work performed and supported by a system of internal controls that provides reasonable assurance that charges are accurate; allowable and reasonable; and properly allocated. Condition: Internal controls were not in place to ensure time and effort documentation was consistently tracked and supported. Questioned costs: $3,084 Context: For 4 of 40 payroll transactions tested, we identified the City did not maintain documentation of time and effort supporting the charges to the program. Cause: Procedures are not in place to maintain the required supporting documentation for the salaries charged to the grant. Effect: The salary charges are subject to disallowance and are considered questioned costs. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-002. Recommendation: We recommend management implement procedures to ensure that salaries charged to the grant are appropriate and are supported by the required time and effort support and that a consistent policy is applied. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of Allowable Costs/Cost Principles. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Payroll systems must be based on records that accurately reflect the work performed and supported by a system of internal controls that provides reasonable assurance that charges are accurate; allowable and reasonable; and properly allocated. Condition: Internal controls were not in place to ensure time and effort documentation was consistently tracked and supported. Questioned costs: $3,084 Context: For 4 of 40 payroll transactions tested, we identified the City did not maintain documentation of time and effort supporting the charges to the program. Cause: Procedures are not in place to maintain the required supporting documentation for the salaries charged to the grant. Effect: The salary charges are subject to disallowance and are considered questioned costs. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-002. Recommendation: We recommend management implement procedures to ensure that salaries charged to the grant are appropriate and are supported by the required time and effort support and that a consistent policy is applied. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Qualified Opinion) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure proper federal procurement standards were being followed for transactions that were transferred to the federal grant. Questioned costs: $320,294 Context: For 2 instances of the 5 contracts tested, we identified that expenses were transferred to a federal grant and the underlying contracts were not in compliance with federal procurement requirements. Cause: Procedures are not in place to ensure proper federal procurement standards were being met prior to transferring expenses to a federal grant. Effect: Noncompliance with federal procurement compliance requirements. Repeat Finding: No. Recommendation: We recommend management implement procedures to ensure expenses transferred to a federal grant are meeting federal procurement standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Qualified Opinion) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure proper federal procurement standards were being followed for transactions that were transferred to the federal grant. Questioned costs: $320,294 Context: For 2 instances of the 5 contracts tested, we identified that expenses were transferred to a federal grant and the underlying contracts were not in compliance with federal procurement requirements. Cause: Procedures are not in place to ensure proper federal procurement standards were being met prior to transferring expenses to a federal grant. Effect: Noncompliance with federal procurement compliance requirements. Repeat Finding: No. Recommendation: We recommend management implement procedures to ensure expenses transferred to a federal grant are meeting federal procurement standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Qualified Opinion) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure proper federal procurement standards were being followed for transactions that were transferred to the federal grant. Questioned costs: $320,294 Context: For 2 instances of the 5 contracts tested, we identified that expenses were transferred to a federal grant and the underlying contracts were not in compliance with federal procurement requirements. Cause: Procedures are not in place to ensure proper federal procurement standards were being met prior to transferring expenses to a federal grant. Effect: Noncompliance with federal procurement compliance requirements. Repeat Finding: No. Recommendation: We recommend management implement procedures to ensure expenses transferred to a federal grant are meeting federal procurement standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Qualified Opinion) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure proper federal procurement standards were being followed for transactions that were transferred to the federal grant. Questioned costs: $320,294 Context: For 2 instances of the 5 contracts tested, we identified that expenses were transferred to a federal grant and the underlying contracts were not in compliance with federal procurement requirements. Cause: Procedures are not in place to ensure proper federal procurement standards were being met prior to transferring expenses to a federal grant. Effect: Noncompliance with federal procurement compliance requirements. Repeat Finding: No. Recommendation: We recommend management implement procedures to ensure expenses transferred to a federal grant are meeting federal procurement standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Qualified Opinion) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure proper federal procurement standards were being followed for transactions that were transferred to the federal grant. Questioned costs: $320,294 Context: For 2 instances of the 5 contracts tested, we identified that expenses were transferred to a federal grant and the underlying contracts were not in compliance with federal procurement requirements. Cause: Procedures are not in place to ensure proper federal procurement standards were being met prior to transferring expenses to a federal grant. Effect: Noncompliance with federal procurement compliance requirements. Repeat Finding: No. Recommendation: We recommend management implement procedures to ensure expenses transferred to a federal grant are meeting federal procurement standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Qualified Opinion) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure proper federal procurement standards were being followed for transactions that were transferred to the federal grant. Questioned costs: $320,294 Context: For 2 instances of the 5 contracts tested, we identified that expenses were transferred to a federal grant and the underlying contracts were not in compliance with federal procurement requirements. Cause: Procedures are not in place to ensure proper federal procurement standards were being met prior to transferring expenses to a federal grant. Effect: Noncompliance with federal procurement compliance requirements. Repeat Finding: No. Recommendation: We recommend management implement procedures to ensure expenses transferred to a federal grant are meeting federal procurement standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Qualified Opinion) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure proper federal procurement standards were being followed for transactions that were transferred to the federal grant. Questioned costs: $320,294 Context: For 2 instances of the 5 contracts tested, we identified that expenses were transferred to a federal grant and the underlying contracts were not in compliance with federal procurement requirements. Cause: Procedures are not in place to ensure proper federal procurement standards were being met prior to transferring expenses to a federal grant. Effect: Noncompliance with federal procurement compliance requirements. Repeat Finding: No. Recommendation: We recommend management implement procedures to ensure expenses transferred to a federal grant are meeting federal procurement standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Qualified Opinion) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure proper federal procurement standards were being followed for transactions that were transferred to the federal grant. Questioned costs: $320,294 Context: For 2 instances of the 5 contracts tested, we identified that expenses were transferred to a federal grant and the underlying contracts were not in compliance with federal procurement requirements. Cause: Procedures are not in place to ensure proper federal procurement standards were being met prior to transferring expenses to a federal grant. Effect: Noncompliance with federal procurement compliance requirements. Repeat Finding: No. Recommendation: We recommend management implement procedures to ensure expenses transferred to a federal grant are meeting federal procurement standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure suspension and debarment checks were being performed prior to entering into a contract. Questioned costs: None Context: For 1 instance of the 3 contracts tested, a suspension and debarment check was not performed, for 1 instance out if the 3 contracts tested, a suspension and debarment check has not been performed during the current grant year, and for 1 instance, a suspension and debarment check was performed after expenses had already occurred. Cause: Procedures are not in place to ensure all vendors are checked to ensure they are not suspended or debarred prior to entering into a contract with a vendor. In addition, for transactions which are originally not expected to be funded with federal funds and later transferred did not meet federal suspension and debarment standards. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-003. Recommendation: We recommend that management implement procedures to ensure that vendors are checked to ensure that they are not suspended or debarred prior to entering into a contract with a vendor and that expenses transferred to a federal grant have met the federal suspension and debarment standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure suspension and debarment checks were being performed prior to entering into a contract. Questioned costs: None Context: For 1 instance of the 3 contracts tested, a suspension and debarment check was not performed, for 1 instance out if the 3 contracts tested, a suspension and debarment check has not been performed during the current grant year, and for 1 instance, a suspension and debarment check was performed after expenses had already occurred. Cause: Procedures are not in place to ensure all vendors are checked to ensure they are not suspended or debarred prior to entering into a contract with a vendor. In addition, for transactions which are originally not expected to be funded with federal funds and later transferred did not meet federal suspension and debarment standards. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-003. Recommendation: We recommend that management implement procedures to ensure that vendors are checked to ensure that they are not suspended or debarred prior to entering into a contract with a vendor and that expenses transferred to a federal grant have met the federal suspension and debarment standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure suspension and debarment checks were being performed prior to entering into a contract. Questioned costs: None Context: For 1 instance of the 3 contracts tested, a suspension and debarment check was not performed, for 1 instance out if the 3 contracts tested, a suspension and debarment check has not been performed during the current grant year, and for 1 instance, a suspension and debarment check was performed after expenses had already occurred. Cause: Procedures are not in place to ensure all vendors are checked to ensure they are not suspended or debarred prior to entering into a contract with a vendor. In addition, for transactions which are originally not expected to be funded with federal funds and later transferred did not meet federal suspension and debarment standards. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-003. Recommendation: We recommend that management implement procedures to ensure that vendors are checked to ensure that they are not suspended or debarred prior to entering into a contract with a vendor and that expenses transferred to a federal grant have met the federal suspension and debarment standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure suspension and debarment checks were being performed prior to entering into a contract. Questioned costs: None Context: For 1 instance of the 3 contracts tested, a suspension and debarment check was not performed, for 1 instance out if the 3 contracts tested, a suspension and debarment check has not been performed during the current grant year, and for 1 instance, a suspension and debarment check was performed after expenses had already occurred. Cause: Procedures are not in place to ensure all vendors are checked to ensure they are not suspended or debarred prior to entering into a contract with a vendor. In addition, for transactions which are originally not expected to be funded with federal funds and later transferred did not meet federal suspension and debarment standards. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-003. Recommendation: We recommend that management implement procedures to ensure that vendors are checked to ensure that they are not suspended or debarred prior to entering into a contract with a vendor and that expenses transferred to a federal grant have met the federal suspension and debarment standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure suspension and debarment checks were being performed prior to entering into a contract. Questioned costs: None Context: For 1 instance of the 3 contracts tested, a suspension and debarment check was not performed, for 1 instance out if the 3 contracts tested, a suspension and debarment check has not been performed during the current grant year, and for 1 instance, a suspension and debarment check was performed after expenses had already occurred. Cause: Procedures are not in place to ensure all vendors are checked to ensure they are not suspended or debarred prior to entering into a contract with a vendor. In addition, for transactions which are originally not expected to be funded with federal funds and later transferred did not meet federal suspension and debarment standards. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-003. Recommendation: We recommend that management implement procedures to ensure that vendors are checked to ensure that they are not suspended or debarred prior to entering into a contract with a vendor and that expenses transferred to a federal grant have met the federal suspension and debarment standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure suspension and debarment checks were being performed prior to entering into a contract. Questioned costs: None Context: For 1 instance of the 3 contracts tested, a suspension and debarment check was not performed, for 1 instance out if the 3 contracts tested, a suspension and debarment check has not been performed during the current grant year, and for 1 instance, a suspension and debarment check was performed after expenses had already occurred. Cause: Procedures are not in place to ensure all vendors are checked to ensure they are not suspended or debarred prior to entering into a contract with a vendor. In addition, for transactions which are originally not expected to be funded with federal funds and later transferred did not meet federal suspension and debarment standards. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-003. Recommendation: We recommend that management implement procedures to ensure that vendors are checked to ensure that they are not suspended or debarred prior to entering into a contract with a vendor and that expenses transferred to a federal grant have met the federal suspension and debarment standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure suspension and debarment checks were being performed prior to entering into a contract. Questioned costs: None Context: For 1 instance of the 3 contracts tested, a suspension and debarment check was not performed, for 1 instance out if the 3 contracts tested, a suspension and debarment check has not been performed during the current grant year, and for 1 instance, a suspension and debarment check was performed after expenses had already occurred. Cause: Procedures are not in place to ensure all vendors are checked to ensure they are not suspended or debarred prior to entering into a contract with a vendor. In addition, for transactions which are originally not expected to be funded with federal funds and later transferred did not meet federal suspension and debarment standards. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-003. Recommendation: We recommend that management implement procedures to ensure that vendors are checked to ensure that they are not suspended or debarred prior to entering into a contract with a vendor and that expenses transferred to a federal grant have met the federal suspension and debarment standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure suspension and debarment checks were being performed prior to entering into a contract. Questioned costs: None Context: For 1 instance of the 3 contracts tested, a suspension and debarment check was not performed, for 1 instance out if the 3 contracts tested, a suspension and debarment check has not been performed during the current grant year, and for 1 instance, a suspension and debarment check was performed after expenses had already occurred. Cause: Procedures are not in place to ensure all vendors are checked to ensure they are not suspended or debarred prior to entering into a contract with a vendor. In addition, for transactions which are originally not expected to be funded with federal funds and later transferred did not meet federal suspension and debarment standards. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-003. Recommendation: We recommend that management implement procedures to ensure that vendors are checked to ensure that they are not suspended or debarred prior to entering into a contract with a vendor and that expenses transferred to a federal grant have met the federal suspension and debarment standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of Allowable Costs/Cost Principles. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Payroll systems must be based on records that accurately reflect the work performed and supported by a system of internal controls that provides reasonable assurance that charges are accurate; allowable and reasonable; and properly allocated. Condition: Internal controls were not in place to ensure time and effort documentation was consistently tracked and supported. Questioned costs: $3,084 Context: For 4 of 40 payroll transactions tested, we identified the City did not maintain documentation of time and effort supporting the charges to the program. Cause: Procedures are not in place to maintain the required supporting documentation for the salaries charged to the grant. Effect: The salary charges are subject to disallowance and are considered questioned costs. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-002. Recommendation: We recommend management implement procedures to ensure that salaries charged to the grant are appropriate and are supported by the required time and effort support and that a consistent policy is applied. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of Allowable Costs/Cost Principles. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Payroll systems must be based on records that accurately reflect the work performed and supported by a system of internal controls that provides reasonable assurance that charges are accurate; allowable and reasonable; and properly allocated. Condition: Internal controls were not in place to ensure time and effort documentation was consistently tracked and supported. Questioned costs: $3,084 Context: For 4 of 40 payroll transactions tested, we identified the City did not maintain documentation of time and effort supporting the charges to the program. Cause: Procedures are not in place to maintain the required supporting documentation for the salaries charged to the grant. Effect: The salary charges are subject to disallowance and are considered questioned costs. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-002. Recommendation: We recommend management implement procedures to ensure that salaries charged to the grant are appropriate and are supported by the required time and effort support and that a consistent policy is applied. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of Allowable Costs/Cost Principles. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Payroll systems must be based on records that accurately reflect the work performed and supported by a system of internal controls that provides reasonable assurance that charges are accurate; allowable and reasonable; and properly allocated. Condition: Internal controls were not in place to ensure time and effort documentation was consistently tracked and supported. Questioned costs: $3,084 Context: For 4 of 40 payroll transactions tested, we identified the City did not maintain documentation of time and effort supporting the charges to the program. Cause: Procedures are not in place to maintain the required supporting documentation for the salaries charged to the grant. Effect: The salary charges are subject to disallowance and are considered questioned costs. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-002. Recommendation: We recommend management implement procedures to ensure that salaries charged to the grant are appropriate and are supported by the required time and effort support and that a consistent policy is applied. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of Allowable Costs/Cost Principles. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Payroll systems must be based on records that accurately reflect the work performed and supported by a system of internal controls that provides reasonable assurance that charges are accurate; allowable and reasonable; and properly allocated. Condition: Internal controls were not in place to ensure time and effort documentation was consistently tracked and supported. Questioned costs: $3,084 Context: For 4 of 40 payroll transactions tested, we identified the City did not maintain documentation of time and effort supporting the charges to the program. Cause: Procedures are not in place to maintain the required supporting documentation for the salaries charged to the grant. Effect: The salary charges are subject to disallowance and are considered questioned costs. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-002. Recommendation: We recommend management implement procedures to ensure that salaries charged to the grant are appropriate and are supported by the required time and effort support and that a consistent policy is applied. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of Allowable Costs/Cost Principles. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Payroll systems must be based on records that accurately reflect the work performed and supported by a system of internal controls that provides reasonable assurance that charges are accurate; allowable and reasonable; and properly allocated. Condition: Internal controls were not in place to ensure time and effort documentation was consistently tracked and supported. Questioned costs: $3,084 Context: For 4 of 40 payroll transactions tested, we identified the City did not maintain documentation of time and effort supporting the charges to the program. Cause: Procedures are not in place to maintain the required supporting documentation for the salaries charged to the grant. Effect: The salary charges are subject to disallowance and are considered questioned costs. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-002. Recommendation: We recommend management implement procedures to ensure that salaries charged to the grant are appropriate and are supported by the required time and effort support and that a consistent policy is applied. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of Allowable Costs/Cost Principles. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Payroll systems must be based on records that accurately reflect the work performed and supported by a system of internal controls that provides reasonable assurance that charges are accurate; allowable and reasonable; and properly allocated. Condition: Internal controls were not in place to ensure time and effort documentation was consistently tracked and supported. Questioned costs: $3,084 Context: For 4 of 40 payroll transactions tested, we identified the City did not maintain documentation of time and effort supporting the charges to the program. Cause: Procedures are not in place to maintain the required supporting documentation for the salaries charged to the grant. Effect: The salary charges are subject to disallowance and are considered questioned costs. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-002. Recommendation: We recommend management implement procedures to ensure that salaries charged to the grant are appropriate and are supported by the required time and effort support and that a consistent policy is applied. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of Allowable Costs/Cost Principles. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Payroll systems must be based on records that accurately reflect the work performed and supported by a system of internal controls that provides reasonable assurance that charges are accurate; allowable and reasonable; and properly allocated. Condition: Internal controls were not in place to ensure time and effort documentation was consistently tracked and supported. Questioned costs: $3,084 Context: For 4 of 40 payroll transactions tested, we identified the City did not maintain documentation of time and effort supporting the charges to the program. Cause: Procedures are not in place to maintain the required supporting documentation for the salaries charged to the grant. Effect: The salary charges are subject to disallowance and are considered questioned costs. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-002. Recommendation: We recommend management implement procedures to ensure that salaries charged to the grant are appropriate and are supported by the required time and effort support and that a consistent policy is applied. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of Allowable Costs/Cost Principles. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Payroll systems must be based on records that accurately reflect the work performed and supported by a system of internal controls that provides reasonable assurance that charges are accurate; allowable and reasonable; and properly allocated. Condition: Internal controls were not in place to ensure time and effort documentation was consistently tracked and supported. Questioned costs: $3,084 Context: For 4 of 40 payroll transactions tested, we identified the City did not maintain documentation of time and effort supporting the charges to the program. Cause: Procedures are not in place to maintain the required supporting documentation for the salaries charged to the grant. Effect: The salary charges are subject to disallowance and are considered questioned costs. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-002. Recommendation: We recommend management implement procedures to ensure that salaries charged to the grant are appropriate and are supported by the required time and effort support and that a consistent policy is applied. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Qualified Opinion) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure proper federal procurement standards were being followed for transactions that were transferred to the federal grant. Questioned costs: $320,294 Context: For 2 instances of the 5 contracts tested, we identified that expenses were transferred to a federal grant and the underlying contracts were not in compliance with federal procurement requirements. Cause: Procedures are not in place to ensure proper federal procurement standards were being met prior to transferring expenses to a federal grant. Effect: Noncompliance with federal procurement compliance requirements. Repeat Finding: No. Recommendation: We recommend management implement procedures to ensure expenses transferred to a federal grant are meeting federal procurement standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Qualified Opinion) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure proper federal procurement standards were being followed for transactions that were transferred to the federal grant. Questioned costs: $320,294 Context: For 2 instances of the 5 contracts tested, we identified that expenses were transferred to a federal grant and the underlying contracts were not in compliance with federal procurement requirements. Cause: Procedures are not in place to ensure proper federal procurement standards were being met prior to transferring expenses to a federal grant. Effect: Noncompliance with federal procurement compliance requirements. Repeat Finding: No. Recommendation: We recommend management implement procedures to ensure expenses transferred to a federal grant are meeting federal procurement standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Qualified Opinion) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure proper federal procurement standards were being followed for transactions that were transferred to the federal grant. Questioned costs: $320,294 Context: For 2 instances of the 5 contracts tested, we identified that expenses were transferred to a federal grant and the underlying contracts were not in compliance with federal procurement requirements. Cause: Procedures are not in place to ensure proper federal procurement standards were being met prior to transferring expenses to a federal grant. Effect: Noncompliance with federal procurement compliance requirements. Repeat Finding: No. Recommendation: We recommend management implement procedures to ensure expenses transferred to a federal grant are meeting federal procurement standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Qualified Opinion) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure proper federal procurement standards were being followed for transactions that were transferred to the federal grant. Questioned costs: $320,294 Context: For 2 instances of the 5 contracts tested, we identified that expenses were transferred to a federal grant and the underlying contracts were not in compliance with federal procurement requirements. Cause: Procedures are not in place to ensure proper federal procurement standards were being met prior to transferring expenses to a federal grant. Effect: Noncompliance with federal procurement compliance requirements. Repeat Finding: No. Recommendation: We recommend management implement procedures to ensure expenses transferred to a federal grant are meeting federal procurement standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Qualified Opinion) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure proper federal procurement standards were being followed for transactions that were transferred to the federal grant. Questioned costs: $320,294 Context: For 2 instances of the 5 contracts tested, we identified that expenses were transferred to a federal grant and the underlying contracts were not in compliance with federal procurement requirements. Cause: Procedures are not in place to ensure proper federal procurement standards were being met prior to transferring expenses to a federal grant. Effect: Noncompliance with federal procurement compliance requirements. Repeat Finding: No. Recommendation: We recommend management implement procedures to ensure expenses transferred to a federal grant are meeting federal procurement standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Qualified Opinion) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure proper federal procurement standards were being followed for transactions that were transferred to the federal grant. Questioned costs: $320,294 Context: For 2 instances of the 5 contracts tested, we identified that expenses were transferred to a federal grant and the underlying contracts were not in compliance with federal procurement requirements. Cause: Procedures are not in place to ensure proper federal procurement standards were being met prior to transferring expenses to a federal grant. Effect: Noncompliance with federal procurement compliance requirements. Repeat Finding: No. Recommendation: We recommend management implement procedures to ensure expenses transferred to a federal grant are meeting federal procurement standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Qualified Opinion) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure proper federal procurement standards were being followed for transactions that were transferred to the federal grant. Questioned costs: $320,294 Context: For 2 instances of the 5 contracts tested, we identified that expenses were transferred to a federal grant and the underlying contracts were not in compliance with federal procurement requirements. Cause: Procedures are not in place to ensure proper federal procurement standards were being met prior to transferring expenses to a federal grant. Effect: Noncompliance with federal procurement compliance requirements. Repeat Finding: No. Recommendation: We recommend management implement procedures to ensure expenses transferred to a federal grant are meeting federal procurement standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Qualified Opinion) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure proper federal procurement standards were being followed for transactions that were transferred to the federal grant. Questioned costs: $320,294 Context: For 2 instances of the 5 contracts tested, we identified that expenses were transferred to a federal grant and the underlying contracts were not in compliance with federal procurement requirements. Cause: Procedures are not in place to ensure proper federal procurement standards were being met prior to transferring expenses to a federal grant. Effect: Noncompliance with federal procurement compliance requirements. Repeat Finding: No. Recommendation: We recommend management implement procedures to ensure expenses transferred to a federal grant are meeting federal procurement standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure suspension and debarment checks were being performed prior to entering into a contract. Questioned costs: None Context: For 1 instance of the 3 contracts tested, a suspension and debarment check was not performed, for 1 instance out if the 3 contracts tested, a suspension and debarment check has not been performed during the current grant year, and for 1 instance, a suspension and debarment check was performed after expenses had already occurred. Cause: Procedures are not in place to ensure all vendors are checked to ensure they are not suspended or debarred prior to entering into a contract with a vendor. In addition, for transactions which are originally not expected to be funded with federal funds and later transferred did not meet federal suspension and debarment standards. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-003. Recommendation: We recommend that management implement procedures to ensure that vendors are checked to ensure that they are not suspended or debarred prior to entering into a contract with a vendor and that expenses transferred to a federal grant have met the federal suspension and debarment standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure suspension and debarment checks were being performed prior to entering into a contract. Questioned costs: None Context: For 1 instance of the 3 contracts tested, a suspension and debarment check was not performed, for 1 instance out if the 3 contracts tested, a suspension and debarment check has not been performed during the current grant year, and for 1 instance, a suspension and debarment check was performed after expenses had already occurred. Cause: Procedures are not in place to ensure all vendors are checked to ensure they are not suspended or debarred prior to entering into a contract with a vendor. In addition, for transactions which are originally not expected to be funded with federal funds and later transferred did not meet federal suspension and debarment standards. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-003. Recommendation: We recommend that management implement procedures to ensure that vendors are checked to ensure that they are not suspended or debarred prior to entering into a contract with a vendor and that expenses transferred to a federal grant have met the federal suspension and debarment standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure suspension and debarment checks were being performed prior to entering into a contract. Questioned costs: None Context: For 1 instance of the 3 contracts tested, a suspension and debarment check was not performed, for 1 instance out if the 3 contracts tested, a suspension and debarment check has not been performed during the current grant year, and for 1 instance, a suspension and debarment check was performed after expenses had already occurred. Cause: Procedures are not in place to ensure all vendors are checked to ensure they are not suspended or debarred prior to entering into a contract with a vendor. In addition, for transactions which are originally not expected to be funded with federal funds and later transferred did not meet federal suspension and debarment standards. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-003. Recommendation: We recommend that management implement procedures to ensure that vendors are checked to ensure that they are not suspended or debarred prior to entering into a contract with a vendor and that expenses transferred to a federal grant have met the federal suspension and debarment standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure suspension and debarment checks were being performed prior to entering into a contract. Questioned costs: None Context: For 1 instance of the 3 contracts tested, a suspension and debarment check was not performed, for 1 instance out if the 3 contracts tested, a suspension and debarment check has not been performed during the current grant year, and for 1 instance, a suspension and debarment check was performed after expenses had already occurred. Cause: Procedures are not in place to ensure all vendors are checked to ensure they are not suspended or debarred prior to entering into a contract with a vendor. In addition, for transactions which are originally not expected to be funded with federal funds and later transferred did not meet federal suspension and debarment standards. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-003. Recommendation: We recommend that management implement procedures to ensure that vendors are checked to ensure that they are not suspended or debarred prior to entering into a contract with a vendor and that expenses transferred to a federal grant have met the federal suspension and debarment standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure suspension and debarment checks were being performed prior to entering into a contract. Questioned costs: None Context: For 1 instance of the 3 contracts tested, a suspension and debarment check was not performed, for 1 instance out if the 3 contracts tested, a suspension and debarment check has not been performed during the current grant year, and for 1 instance, a suspension and debarment check was performed after expenses had already occurred. Cause: Procedures are not in place to ensure all vendors are checked to ensure they are not suspended or debarred prior to entering into a contract with a vendor. In addition, for transactions which are originally not expected to be funded with federal funds and later transferred did not meet federal suspension and debarment standards. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-003. Recommendation: We recommend that management implement procedures to ensure that vendors are checked to ensure that they are not suspended or debarred prior to entering into a contract with a vendor and that expenses transferred to a federal grant have met the federal suspension and debarment standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure suspension and debarment checks were being performed prior to entering into a contract. Questioned costs: None Context: For 1 instance of the 3 contracts tested, a suspension and debarment check was not performed, for 1 instance out if the 3 contracts tested, a suspension and debarment check has not been performed during the current grant year, and for 1 instance, a suspension and debarment check was performed after expenses had already occurred. Cause: Procedures are not in place to ensure all vendors are checked to ensure they are not suspended or debarred prior to entering into a contract with a vendor. In addition, for transactions which are originally not expected to be funded with federal funds and later transferred did not meet federal suspension and debarment standards. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-003. Recommendation: We recommend that management implement procedures to ensure that vendors are checked to ensure that they are not suspended or debarred prior to entering into a contract with a vendor and that expenses transferred to a federal grant have met the federal suspension and debarment standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure suspension and debarment checks were being performed prior to entering into a contract. Questioned costs: None Context: For 1 instance of the 3 contracts tested, a suspension and debarment check was not performed, for 1 instance out if the 3 contracts tested, a suspension and debarment check has not been performed during the current grant year, and for 1 instance, a suspension and debarment check was performed after expenses had already occurred. Cause: Procedures are not in place to ensure all vendors are checked to ensure they are not suspended or debarred prior to entering into a contract with a vendor. In addition, for transactions which are originally not expected to be funded with federal funds and later transferred did not meet federal suspension and debarment standards. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-003. Recommendation: We recommend that management implement procedures to ensure that vendors are checked to ensure that they are not suspended or debarred prior to entering into a contract with a vendor and that expenses transferred to a federal grant have met the federal suspension and debarment standards. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308, 252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and 264-547238-2022-0308 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls were not in place to ensure suspension and debarment checks were being performed prior to entering into a contract. Questioned costs: None Context: For 1 instance of the 3 contracts tested, a suspension and debarment check was not performed, for 1 instance out if the 3 contracts tested, a suspension and debarment check has not been performed during the current grant year, and for 1 instance, a suspension and debarment check was performed after expenses had already occurred. Cause: Procedures are not in place to ensure all vendors are checked to ensure they are not suspended or debarred prior to entering into a contract with a vendor. In addition, for transactions which are originally not expected to be funded with federal funds and later transferred did not meet federal suspension and debarment standards. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-003. Recommendation: We recommend that management implement procedures to ensure that vendors are checked to ensure that they are not suspended or debarred prior to entering into a contract with a vendor and that expenses transferred to a federal grant have met the federal suspension and debarment standards. Views of responsible officials: There is no disagreement with the audit finding.