Audit 356487

Finding 2023-001 – Education Stabilization Fund – AL No.’s 84.425D & 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Criteria: Grantees must provide reasonable assurance that federal awards are expended only for allowable activities and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context: Control deficiencies related to disbursements were noted as a result of the testing of internal controls over payroll. Specifically, a sample of payroll disbursements charged to the major program were tested in order to determine if adequate internal controls were in place. As a result of the testing of payroll disbursements charged to the programs, the employees tested were found to not have adequately approved and or documented employee payroll rate agreements. Cause: Appointment letters for some staff tested could not be located. I believe this is due not to non-compliance but turnover within the office and not being able to locate paper files. Effect or Potential Effect: Due to the significant deficiencies and noncompliance in internal controls noted above, there is a risk of inappropriate rate of pay and/or wages being paid. Identification as a Repeat Finding: 2022-001 Questioned Costs: Questioned costs could not be determined. Recommendation: The Town of Bellingham should improve the internal controls over Activities Allowed/Allowable Costs by ensuring employee’s payroll rate agreements are approved by an appropriate level of management and in a timely manner. Managements Response: The Director of Finance will ensure that all employees paid have an approved and documented pay rate or salary from either an appointment letter, School Committee salary worksheet, and/or Collective Bargaining Agreement.

Finding 2023-002 – COVID 19 – Coronavirus State and Local Fiscal Recovery Fund - AL No. 21.027 U.S. Department of Treasury Other Matters Related to Internal Control over Compliance of the Major Program Condition: Upon review of the Town of Bellingham’s report filed with the U.S. Department of Treasury it was noted that the reports did not agree with the Town’s accounting ledgers. Criteria: Per the U.S. Department of Treasury the Town was required to submit an accurate annual Recovery Plan Performance Report. Context: The annual report submitted to the U.S. Department of Treasury reported expenditures that did not agree with the general ledger. Effect: The Town of Bellingham was not in compliance with the U.S. Department of Treasury reporting requirements. Questioned Costs: N/A Cause: During this time period, the Grant Administrator compiled manually created records to support reporting requirements. Those manual records were not properly reconciled with the General Ledger reports prior to submission to the required agencies. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: The Town of Bellingham should complete and submit all required annual reporting by the due date designated by the Federal Agency and ensure that it agrees with grant activity for time period reported. Managements Response: The Town has trained the Grants Administrator on procedures to reconcile General Ledger reports with manually created project-based records. The Town is also implementing a procedure whereby the CFO signs each required report before submitting.

Finding 2023-001 – Education Stabilization Fund – AL No.’s 84.425D & 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Criteria: Grantees must provide reasonable assurance that federal awards are expended only for allowable activities and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context: Control deficiencies related to disbursements were noted as a result of the testing of internal controls over payroll. Specifically, a sample of payroll disbursements charged to the major program were tested in order to determine if adequate internal controls were in place. As a result of the testing of payroll disbursements charged to the programs, the employees tested were found to not have adequately approved and or documented employee payroll rate agreements. Cause: Appointment letters for some staff tested could not be located. I believe this is due not to non-compliance but turnover within the office and not being able to locate paper files. Effect or Potential Effect: Due to the significant deficiencies and noncompliance in internal controls noted above, there is a risk of inappropriate rate of pay and/or wages being paid. Identification as a Repeat Finding: 2022-001 Questioned Costs: Questioned costs could not be determined. Recommendation: The Town of Bellingham should improve the internal controls over Activities Allowed/Allowable Costs by ensuring employee’s payroll rate agreements are approved by an appropriate level of management and in a timely manner. Managements Response: The Director of Finance will ensure that all employees paid have an approved and documented pay rate or salary from either an appointment letter, School Committee salary worksheet, and/or Collective Bargaining Agreement.

Finding 2023-001 – Education Stabilization Fund – AL No.’s 84.425D & 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Criteria: Grantees must provide reasonable assurance that federal awards are expended only for allowable activities and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context: Control deficiencies related to disbursements were noted as a result of the testing of internal controls over payroll. Specifically, a sample of payroll disbursements charged to the major program were tested in order to determine if adequate internal controls were in place. As a result of the testing of payroll disbursements charged to the programs, the employees tested were found to not have adequately approved and or documented employee payroll rate agreements. Cause: Appointment letters for some staff tested could not be located. I believe this is due not to non-compliance but turnover within the office and not being able to locate paper files. Effect or Potential Effect: Due to the significant deficiencies and noncompliance in internal controls noted above, there is a risk of inappropriate rate of pay and/or wages being paid. Identification as a Repeat Finding: 2022-001 Questioned Costs: Questioned costs could not be determined. Recommendation: The Town of Bellingham should improve the internal controls over Activities Allowed/Allowable Costs by ensuring employee’s payroll rate agreements are approved by an appropriate level of management and in a timely manner. Managements Response: The Director of Finance will ensure that all employees paid have an approved and documented pay rate or salary from either an appointment letter, School Committee salary worksheet, and/or Collective Bargaining Agreement.

Finding 2023-004 – Education Stabilization Fund – AL No.’s 84.425D & 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Criteria: Where employees work solely or partially on a single Federal program or cost objective, their salaries or wages must be supported by periodic certification that the employee worked on these programs for the period covered by the programs. The certifications should be prepared at least semi-annually, and should be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee. Condition: During our test of controls over compliance with time and effort certifications the Town was not able to provide evidence that the required certifications of time and effort for employees whose time was spent either completely or partially spent on these programs was performed as required by Uniform Guidance. Questioned Costs: Unknown Context: During our test of payroll transactions of the major program (Education Stabilization Fund) it was noted that the time and effort certification for employees tested were not completed. Effect: The Town was not in compliance with the time and effort certification requirements. Cause: Time and Effort Certifications were issued semi-annually. However, in some circumstances staff had terminated employment and letters were not issued outside of the school setting. Identification as a Repeat Finding: 2022-004 Recommendation: We recommend the Town of Bellingham follow procedures to ensure that semi-annual certifications and/or monthly certifications are prepared and signed by either the employees and/or supervisory official having first-hand knowledge of the work performed by the employees in a timely manner in order to comply with the time and effort certification requirement. Management Response: We have amended our process for issuing Time and Effort Certifications. We are now emailing them and if they are returned, we will re-issue to their home address with a self-addressed stamped envelope. In some circumstances such as committee work, we will have the staff sign an acknowledgement at the time of the meeting(s).

Finding 2023-002 – COVID 19 – Coronavirus State and Local Fiscal Recovery Fund - AL No. 21.027 U.S. Department of Treasury Other Matters Related to Internal Control over Compliance of the Major Program Condition: Upon review of the Town of Bellingham’s report filed with the U.S. Department of Treasury it was noted that the reports did not agree with the Town’s accounting ledgers. Criteria: Per the U.S. Department of Treasury the Town was required to submit an accurate annual Recovery Plan Performance Report. Context: The annual report submitted to the U.S. Department of Treasury reported expenditures that did not agree with the general ledger. Effect: The Town of Bellingham was not in compliance with the U.S. Department of Treasury reporting requirements. Questioned Costs: N/A Cause: During this time period, the Grant Administrator compiled manually created records to support reporting requirements. Those manual records were not properly reconciled with the General Ledger reports prior to submission to the required agencies. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: The Town of Bellingham should complete and submit all required annual reporting by the due date designated by the Federal Agency and ensure that it agrees with grant activity for time period reported. Managements Response: The Town has trained the Grants Administrator on procedures to reconcile General Ledger reports with manually created project-based records. The Town is also implementing a procedure whereby the CFO signs each required report before submitting.

Finding 2023-003 – COVID 19 – Coronavirus State and Local Fiscal Recovery Fund - AL No. 21.027 U.S. Department of Treasury Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. As governmental subrecipients of states they are also required to use the same state procurement policies and procedures for federal funds as for non‐federal funds, the Town is required to follow Massachusetts General Laws, Chapter (MGL) 30(b). MGL 30(b) requires the solicitation of three written or oral quotes for procurements of supplies between $10,000 and $49,999 and sealed bids or proposals for procurements of supplies $50,000 and over. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. However, A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context: During fiscal year 2023, the Town did not comply with the required procurement policies and procedures in place as it related to one of the expenses charged to the major program. As the expense tested was for engineering services that would have been exempt under Massachusetts General Laws, Chapter (MGL) 30(b) (State Procurement Requirement), under federal statutes and procurement requirements for engineering services identified in 2 CFR Part 200, the Town would have been required to go out to bid for the services. Questioned Costs: $413,477.78. Cause: The noncompliance occurred because the organization mistakenly relied on Massachusetts Chapter 30B exemptions, which govern state and local procurements, and did not recognize the need to comply with the more stringent federal procurement requirements for federal fund usage. Staff members were not sufficiently aware of the specific requirements under 2 CFR Part 200 and the precedence of federal procurement regulations over state law in this context. Effect or Potential Effect: There is risk that amounts charged to the federal awards major program may not be in accordance with procurement, suspension, and debarment principles. Identification as a Repeat Finding: N/A Recommendation: The Town of Bellingham should address the nocompliance and material weakness in internal controls noted above in order to ensure that procurements are conducted in accordance with federal and state requirements. Management Response: We acknowledge the audit finding regarding our reliance on Massachusetts Chapter 30B exemptions for procurement involving federal funds. We understand that federal procurement regulations under 2 CFR Part 200 take precedence over state law and that we failed fully to comply with federal requirements for competitive bidding, sole-source justification, and documentation. We are committed to addressing this issue by reviewing our procurement policies to clearly differentiate between state and federal requirements, ensuring that federal standards govern all procurement involving federal funds. We will provide additional training to staff, implement stronger documentation procedures, and review past procurement to ensure full compliance moving forward.

Finding 2023-001 – Education Stabilization Fund – AL No.’s 84.425D & 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Criteria: Grantees must provide reasonable assurance that federal awards are expended only for allowable activities and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context: Control deficiencies related to disbursements were noted as a result of the testing of internal controls over payroll. Specifically, a sample of payroll disbursements charged to the major program were tested in order to determine if adequate internal controls were in place. As a result of the testing of payroll disbursements charged to the programs, the employees tested were found to not have adequately approved and or documented employee payroll rate agreements. Cause: Appointment letters for some staff tested could not be located. I believe this is due not to non-compliance but turnover within the office and not being able to locate paper files. Effect or Potential Effect: Due to the significant deficiencies and noncompliance in internal controls noted above, there is a risk of inappropriate rate of pay and/or wages being paid. Identification as a Repeat Finding: 2022-001 Questioned Costs: Questioned costs could not be determined. Recommendation: The Town of Bellingham should improve the internal controls over Activities Allowed/Allowable Costs by ensuring employee’s payroll rate agreements are approved by an appropriate level of management and in a timely manner. Managements Response: The Director of Finance will ensure that all employees paid have an approved and documented pay rate or salary from either an appointment letter, School Committee salary worksheet, and/or Collective Bargaining Agreement.

Finding 2023-002 – COVID 19 – Coronavirus State and Local Fiscal Recovery Fund - AL No. 21.027 U.S. Department of Treasury Other Matters Related to Internal Control over Compliance of the Major Program Condition: Upon review of the Town of Bellingham’s report filed with the U.S. Department of Treasury it was noted that the reports did not agree with the Town’s accounting ledgers. Criteria: Per the U.S. Department of Treasury the Town was required to submit an accurate annual Recovery Plan Performance Report. Context: The annual report submitted to the U.S. Department of Treasury reported expenditures that did not agree with the general ledger. Effect: The Town of Bellingham was not in compliance with the U.S. Department of Treasury reporting requirements. Questioned Costs: N/A Cause: During this time period, the Grant Administrator compiled manually created records to support reporting requirements. Those manual records were not properly reconciled with the General Ledger reports prior to submission to the required agencies. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: The Town of Bellingham should complete and submit all required annual reporting by the due date designated by the Federal Agency and ensure that it agrees with grant activity for time period reported. Managements Response: The Town has trained the Grants Administrator on procedures to reconcile General Ledger reports with manually created project-based records. The Town is also implementing a procedure whereby the CFO signs each required report before submitting.

Finding 2023-001 – Education Stabilization Fund – AL No.’s 84.425D & 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Criteria: Grantees must provide reasonable assurance that federal awards are expended only for allowable activities and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context: Control deficiencies related to disbursements were noted as a result of the testing of internal controls over payroll. Specifically, a sample of payroll disbursements charged to the major program were tested in order to determine if adequate internal controls were in place. As a result of the testing of payroll disbursements charged to the programs, the employees tested were found to not have adequately approved and or documented employee payroll rate agreements. Cause: Appointment letters for some staff tested could not be located. I believe this is due not to non-compliance but turnover within the office and not being able to locate paper files. Effect or Potential Effect: Due to the significant deficiencies and noncompliance in internal controls noted above, there is a risk of inappropriate rate of pay and/or wages being paid. Identification as a Repeat Finding: 2022-001 Questioned Costs: Questioned costs could not be determined. Recommendation: The Town of Bellingham should improve the internal controls over Activities Allowed/Allowable Costs by ensuring employee’s payroll rate agreements are approved by an appropriate level of management and in a timely manner. Managements Response: The Director of Finance will ensure that all employees paid have an approved and documented pay rate or salary from either an appointment letter, School Committee salary worksheet, and/or Collective Bargaining Agreement.

Finding 2023-001 – Education Stabilization Fund – AL No.’s 84.425D & 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Criteria: Grantees must provide reasonable assurance that federal awards are expended only for allowable activities and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context: Control deficiencies related to disbursements were noted as a result of the testing of internal controls over payroll. Specifically, a sample of payroll disbursements charged to the major program were tested in order to determine if adequate internal controls were in place. As a result of the testing of payroll disbursements charged to the programs, the employees tested were found to not have adequately approved and or documented employee payroll rate agreements. Cause: Appointment letters for some staff tested could not be located. I believe this is due not to non-compliance but turnover within the office and not being able to locate paper files. Effect or Potential Effect: Due to the significant deficiencies and noncompliance in internal controls noted above, there is a risk of inappropriate rate of pay and/or wages being paid. Identification as a Repeat Finding: 2022-001 Questioned Costs: Questioned costs could not be determined. Recommendation: The Town of Bellingham should improve the internal controls over Activities Allowed/Allowable Costs by ensuring employee’s payroll rate agreements are approved by an appropriate level of management and in a timely manner. Managements Response: The Director of Finance will ensure that all employees paid have an approved and documented pay rate or salary from either an appointment letter, School Committee salary worksheet, and/or Collective Bargaining Agreement.

Finding 2023-004 – Education Stabilization Fund – AL No.’s 84.425D & 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Criteria: Where employees work solely or partially on a single Federal program or cost objective, their salaries or wages must be supported by periodic certification that the employee worked on these programs for the period covered by the programs. The certifications should be prepared at least semi-annually, and should be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee. Condition: During our test of controls over compliance with time and effort certifications the Town was not able to provide evidence that the required certifications of time and effort for employees whose time was spent either completely or partially spent on these programs was performed as required by Uniform Guidance. Questioned Costs: Unknown Context: During our test of payroll transactions of the major program (Education Stabilization Fund) it was noted that the time and effort certification for employees tested were not completed. Effect: The Town was not in compliance with the time and effort certification requirements. Cause: Time and Effort Certifications were issued semi-annually. However, in some circumstances staff had terminated employment and letters were not issued outside of the school setting. Identification as a Repeat Finding: 2022-004 Recommendation: We recommend the Town of Bellingham follow procedures to ensure that semi-annual certifications and/or monthly certifications are prepared and signed by either the employees and/or supervisory official having first-hand knowledge of the work performed by the employees in a timely manner in order to comply with the time and effort certification requirement. Management Response: We have amended our process for issuing Time and Effort Certifications. We are now emailing them and if they are returned, we will re-issue to their home address with a self-addressed stamped envelope. In some circumstances such as committee work, we will have the staff sign an acknowledgement at the time of the meeting(s).

Finding 2023-002 – COVID 19 – Coronavirus State and Local Fiscal Recovery Fund - AL No. 21.027 U.S. Department of Treasury Other Matters Related to Internal Control over Compliance of the Major Program Condition: Upon review of the Town of Bellingham’s report filed with the U.S. Department of Treasury it was noted that the reports did not agree with the Town’s accounting ledgers. Criteria: Per the U.S. Department of Treasury the Town was required to submit an accurate annual Recovery Plan Performance Report. Context: The annual report submitted to the U.S. Department of Treasury reported expenditures that did not agree with the general ledger. Effect: The Town of Bellingham was not in compliance with the U.S. Department of Treasury reporting requirements. Questioned Costs: N/A Cause: During this time period, the Grant Administrator compiled manually created records to support reporting requirements. Those manual records were not properly reconciled with the General Ledger reports prior to submission to the required agencies. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: The Town of Bellingham should complete and submit all required annual reporting by the due date designated by the Federal Agency and ensure that it agrees with grant activity for time period reported. Managements Response: The Town has trained the Grants Administrator on procedures to reconcile General Ledger reports with manually created project-based records. The Town is also implementing a procedure whereby the CFO signs each required report before submitting.

Finding 2023-003 – COVID 19 – Coronavirus State and Local Fiscal Recovery Fund - AL No. 21.027 U.S. Department of Treasury Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. As governmental subrecipients of states they are also required to use the same state procurement policies and procedures for federal funds as for non‐federal funds, the Town is required to follow Massachusetts General Laws, Chapter (MGL) 30(b). MGL 30(b) requires the solicitation of three written or oral quotes for procurements of supplies between $10,000 and $49,999 and sealed bids or proposals for procurements of supplies $50,000 and over. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. However, A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context: During fiscal year 2023, the Town did not comply with the required procurement policies and procedures in place as it related to one of the expenses charged to the major program. As the expense tested was for engineering services that would have been exempt under Massachusetts General Laws, Chapter (MGL) 30(b) (State Procurement Requirement), under federal statutes and procurement requirements for engineering services identified in 2 CFR Part 200, the Town would have been required to go out to bid for the services. Questioned Costs: $413,477.78. Cause: The noncompliance occurred because the organization mistakenly relied on Massachusetts Chapter 30B exemptions, which govern state and local procurements, and did not recognize the need to comply with the more stringent federal procurement requirements for federal fund usage. Staff members were not sufficiently aware of the specific requirements under 2 CFR Part 200 and the precedence of federal procurement regulations over state law in this context. Effect or Potential Effect: There is risk that amounts charged to the federal awards major program may not be in accordance with procurement, suspension, and debarment principles. Identification as a Repeat Finding: N/A Recommendation: The Town of Bellingham should address the nocompliance and material weakness in internal controls noted above in order to ensure that procurements are conducted in accordance with federal and state requirements. Management Response: We acknowledge the audit finding regarding our reliance on Massachusetts Chapter 30B exemptions for procurement involving federal funds. We understand that federal procurement regulations under 2 CFR Part 200 take precedence over state law and that we failed fully to comply with federal requirements for competitive bidding, sole-source justification, and documentation. We are committed to addressing this issue by reviewing our procurement policies to clearly differentiate between state and federal requirements, ensuring that federal standards govern all procurement involving federal funds. We will provide additional training to staff, implement stronger documentation procedures, and review past procurement to ensure full compliance moving forward.