2024-001 COVID-19 Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027
Federal Award Identification Number: Not Available.
Award Period: March 3, 2021 through December 31, 2024
Compliance Requirement: Suspension and Debarment
Criteria or Specific Requirement: The United States Code of Federal Regulations (CFR) Title 2 Part 200.214 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition and Context: For one vendor in our audit sample of eight, documentation was not provided to support that the City verified the vendor was not debarred or suspended from participation in Federal assistance programs or activities for the fiscal year ended June 30, 2024.
Questioned Costs: None. The vendor was not suspended or debarred.
Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities.
Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities.
Repeat Finding: No.
Recommendation: We recommend procedures be strengthened to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities prior to entering into a transaction.
Views of Responsible Officials: Management agrees with the finding.
2024-002 Child Nutrition Cluster, ALN’s 10.553 & 10.555
Federal Award Identification Number (FAIN) and Year: 2024; FAIN not available.
Pass-through Agency: Massachusetts Department of Elementary and Secondary Education
Pass-through Identifying Number: 09-207
Award Period: July 1, 2023 through June 30, 2024
Compliance Requirement: Reporting
Criteria or Specific Requirement: School food authorities and sponsors must submit monthly claims for reimbursement of meals served to eligible students within sixty (60) days following the last day of the month covered by the claim in accordance with CFR Title 7, sections 210.8, 220.11, 215.10, and 225.15(c). Each month’s claim for reimbursement and all data used in the claims review process must be maintained on file, and failure to maintain such records may be grounds for denial of reimbursement for meals served during the period covered by the records in question.
Condition and Context: For six (6) of twenty-eight (28) claims for reimbursement selected in our statistically valid audit sample, the meal counts within the data used in the claims review process did not agree with the corresponding meal counts identified within the monthly claims for reimbursement submitted to the State.
Upon further review, it was determined that the September 2023 claim for reimbursement submitted to the State was inaccurately prepared for all 23 schools for which meals were claimed for reimbursement.
Questioned Costs: $284,295; which represents the difference in reimbursements claimed versus eligible reimbursements supported by the claims data.
Cause: Internal controls implemented over the review and submission of monthly claims for reimbursement were not operating effectively.
Effect: Noncompliance with the federal program occurred as the City claimed reimbursements for unsupported meal counts.
Repeat Finding: No.
Recommendation: We recommend the review and approval process over monthly claims for reimbursement be strengthened to ensure discrepancies between the claim for reimbursement and underlying data are detected and corrected timely.
Views of Responsible Officials: Management agrees with the finding.
2024-003 HOME Investment Partnerships, ALN 14.239
Federal Award Identification Number and Year: MC-DC250213, 2022-2030
Award Period: September 16, 2022 through September 1, 2030
Compliance Requirement: Subrecipient Monitoring
Criteria or Specific Requirement: CFR Title 2 section 200.332(a) states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes, amongst other required information, the subrecipients’ unique entity number (UEI). When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward.
Condition and Context: For three (3) of five (5) subrecipients out of five in our audit sample, the subrecipients’ UEI’s were not included in the subaward document.
Questioned Costs: None.
Cause: Procedures were not implemented to ensure subrecipient UEI's were accurate and properly included in the subaward documents.
Effect: Noncompliance with federal requirements occurred.
Repeat Finding: No.
Recommendation: We recommend procedures be strengthened to ensure accurate UEI's are obtained and included within subaward documents.
Views of Responsible Officials: Management agrees with the finding.
2024-004 Community Development Block Grants, ALN 14.218
Federal Award Identification Number and Year: B-23-MC-25-0019, 2024
Award Period: July 1, 2023 through June 30, 2024
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or Specific Requirement: (CFR) Title 2 Part 200.430 indicates charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Such records must also reasonably reflect the total activity for which the employee is compensated by the non-Federal entity.
Condition and Context: For one of forty payroll disbursements in our sample, evidence of management's review of time and effort was not provided.
Questioned Costs: None.
Cause: Procedures were not implemented effectively to ensure all attestations of time and effort were reviewed and approved by supervising officials.
Effect: While time and effort dedicated to cost objectives was documented for the instance in questions, the risk of noncompliance with federal program requirements is present due to the lack of approval from the payroll documentation.
Repeat Finding: No.
Recommendation: We recommend procedures be strengthened to ensure management's review and approval of time and effort attestation is present on supporting documentation maintained for payroll costs.
Views of Responsible Officials: Management agrees with the finding.
2024-005 Community Development Block Grants, ALN 14.218
Federal Award Identification Number and Year: B-23-MC-25-0019, 2024
Award Period: July 1, 2023 through June 30, 2024
Compliance Requirement: Reporting
Criteria or Specific Requirement: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000.
Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Such internal control encompasses compliance with reporting requirements of the federal award.
Condition and Context: For one of three subawards tested in our statistically valid sample, the City did not provide documentation supporting the reporting of the subaward to FSRS in accordance with FFATA requirements.
For both of the two PR29 CDBG Cash on Hand Quarterly Reports tested in our statistically valid sample, the City improperly calculated the beginning cash on hand at $0.00.
Questioned Costs: None.
Cause: Procedures were not implemented effectively to ensure the required reports were completed and submitted in accordance with the terms and conditions of the federal award.
Effect: Noncompliance occurred as these reports were not completed and processed in accordance with federal award requirements.
Repeat Finding: No.
Recommendation: We recommend procedures be strengthened to ensure federally required reports are completed and processed in accordance with the requirements of the federal awards.
Views of Responsible Officials: Management agrees with the finding.
2024-001 COVID-19 Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027
Federal Award Identification Number: Not Available.
Award Period: March 3, 2021 through December 31, 2024
Compliance Requirement: Suspension and Debarment
Criteria or Specific Requirement: The United States Code of Federal Regulations (CFR) Title 2 Part 200.214 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition and Context: For one vendor in our audit sample of eight, documentation was not provided to support that the City verified the vendor was not debarred or suspended from participation in Federal assistance programs or activities for the fiscal year ended June 30, 2024.
Questioned Costs: None. The vendor was not suspended or debarred.
Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities.
Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities.
Repeat Finding: No.
Recommendation: We recommend procedures be strengthened to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities prior to entering into a transaction.
Views of Responsible Officials: Management agrees with the finding.
2024-002 Child Nutrition Cluster, ALN’s 10.553 & 10.555
Federal Award Identification Number (FAIN) and Year: 2024; FAIN not available.
Pass-through Agency: Massachusetts Department of Elementary and Secondary Education
Pass-through Identifying Number: 09-207
Award Period: July 1, 2023 through June 30, 2024
Compliance Requirement: Reporting
Criteria or Specific Requirement: School food authorities and sponsors must submit monthly claims for reimbursement of meals served to eligible students within sixty (60) days following the last day of the month covered by the claim in accordance with CFR Title 7, sections 210.8, 220.11, 215.10, and 225.15(c). Each month’s claim for reimbursement and all data used in the claims review process must be maintained on file, and failure to maintain such records may be grounds for denial of reimbursement for meals served during the period covered by the records in question.
Condition and Context: For six (6) of twenty-eight (28) claims for reimbursement selected in our statistically valid audit sample, the meal counts within the data used in the claims review process did not agree with the corresponding meal counts identified within the monthly claims for reimbursement submitted to the State.
Upon further review, it was determined that the September 2023 claim for reimbursement submitted to the State was inaccurately prepared for all 23 schools for which meals were claimed for reimbursement.
Questioned Costs: $284,295; which represents the difference in reimbursements claimed versus eligible reimbursements supported by the claims data.
Cause: Internal controls implemented over the review and submission of monthly claims for reimbursement were not operating effectively.
Effect: Noncompliance with the federal program occurred as the City claimed reimbursements for unsupported meal counts.
Repeat Finding: No.
Recommendation: We recommend the review and approval process over monthly claims for reimbursement be strengthened to ensure discrepancies between the claim for reimbursement and underlying data are detected and corrected timely.
Views of Responsible Officials: Management agrees with the finding.
2024-003 HOME Investment Partnerships, ALN 14.239
Federal Award Identification Number and Year: MC-DC250213, 2022-2030
Award Period: September 16, 2022 through September 1, 2030
Compliance Requirement: Subrecipient Monitoring
Criteria or Specific Requirement: CFR Title 2 section 200.332(a) states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes, amongst other required information, the subrecipients’ unique entity number (UEI). When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward.
Condition and Context: For three (3) of five (5) subrecipients out of five in our audit sample, the subrecipients’ UEI’s were not included in the subaward document.
Questioned Costs: None.
Cause: Procedures were not implemented to ensure subrecipient UEI's were accurate and properly included in the subaward documents.
Effect: Noncompliance with federal requirements occurred.
Repeat Finding: No.
Recommendation: We recommend procedures be strengthened to ensure accurate UEI's are obtained and included within subaward documents.
Views of Responsible Officials: Management agrees with the finding.
2024-004 Community Development Block Grants, ALN 14.218
Federal Award Identification Number and Year: B-23-MC-25-0019, 2024
Award Period: July 1, 2023 through June 30, 2024
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or Specific Requirement: (CFR) Title 2 Part 200.430 indicates charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Such records must also reasonably reflect the total activity for which the employee is compensated by the non-Federal entity.
Condition and Context: For one of forty payroll disbursements in our sample, evidence of management's review of time and effort was not provided.
Questioned Costs: None.
Cause: Procedures were not implemented effectively to ensure all attestations of time and effort were reviewed and approved by supervising officials.
Effect: While time and effort dedicated to cost objectives was documented for the instance in questions, the risk of noncompliance with federal program requirements is present due to the lack of approval from the payroll documentation.
Repeat Finding: No.
Recommendation: We recommend procedures be strengthened to ensure management's review and approval of time and effort attestation is present on supporting documentation maintained for payroll costs.
Views of Responsible Officials: Management agrees with the finding.
2024-005 Community Development Block Grants, ALN 14.218
Federal Award Identification Number and Year: B-23-MC-25-0019, 2024
Award Period: July 1, 2023 through June 30, 2024
Compliance Requirement: Reporting
Criteria or Specific Requirement: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000.
Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Such internal control encompasses compliance with reporting requirements of the federal award.
Condition and Context: For one of three subawards tested in our statistically valid sample, the City did not provide documentation supporting the reporting of the subaward to FSRS in accordance with FFATA requirements.
For both of the two PR29 CDBG Cash on Hand Quarterly Reports tested in our statistically valid sample, the City improperly calculated the beginning cash on hand at $0.00.
Questioned Costs: None.
Cause: Procedures were not implemented effectively to ensure the required reports were completed and submitted in accordance with the terms and conditions of the federal award.
Effect: Noncompliance occurred as these reports were not completed and processed in accordance with federal award requirements.
Repeat Finding: No.
Recommendation: We recommend procedures be strengthened to ensure federally required reports are completed and processed in accordance with the requirements of the federal awards.
Views of Responsible Officials: Management agrees with the finding.