FAC Explorer

Audit 35709

FY End
2022-06-30
Total Expended
$8.76M
Findings
2
Programs
9
Organization: County of Bristol, Masaachusetts (MA)
Year: 2022 Accepted: 2023-03-30
Auditor: Lynch Marini & Associates INC

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
34376 2022-002 Significant Deficiency - M
610818 2022-002 Significant Deficiency - M

Programs

ALN Program Spent Major Findings
21.027 Coronavirus State and Local Fiscal Recovery Funds $7.06M Yes 1
21.019 Coronavirus Relief Fund $734,726 - 0
10.555 National School Lunch Program $242,436 - 0
84.425 Education Stabilization Fund $65,288 - 0
84.048 Career and Technical Education -- Basic Grants to States $60,000 - 0
84.367 Improving Teacher Quality State Grants $8,492 - 0
84.027 Special Education_grants to States $5,269 - 0
84.010 Title I Grants to Local Educational Agencies $1,356 - 0
84.424 Student Support and Academic Enrichment Program $373 - 0

Contacts

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

Notes to SEFA

Title: Cash and Non-cash Assistance Accounting Policies: Accounting policies and financial reporting practices permitted for municipalities in Massachusetts are prescribed by the Uniform Municipal Accounting System (UMAS) promulgated by the Commonwealth of Massachusetts Department of Revenue. Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The information included in the Schedule may not fully agree with other federal award reports the County submits to federal awarding or pass-through entities. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The County received non-cash assistance related to the Child Nutrition cluster (National School Lunch- Assistance listing #10.555), for the year ended June 30, 2022.Cash assistance expenditures represent federal reimbursement for meals during the year.Non-cash assistance represent food commodities received under a state distribution formula and are valued at federally published wholesale prices for purposes of this schedule. Such commodities are not recorded in the financial records, although memorandum records are maintained.
Title: COVID-19 pandemic related funding Accounting Policies: Accounting policies and financial reporting practices permitted for municipalities in Massachusetts are prescribed by the Uniform Municipal Accounting System (UMAS) promulgated by the Commonwealth of Massachusetts Department of Revenue. Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The information included in the Schedule may not fully agree with other federal award reports the County submits to federal awarding or pass-through entities. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. Programs identified in the accompanying Schedule of Expenditures of Federal Awards which have been funded pursuant to federal legislation as a result of the coronavirus pandemic have been specifically indicated with the prefix- COVID-19.
Title: Subrecipient pass-through awards Accounting Policies: Accounting policies and financial reporting practices permitted for municipalities in Massachusetts are prescribed by the Uniform Municipal Accounting System (UMAS) promulgated by the Commonwealth of Massachusetts Department of Revenue. Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The information included in the Schedule may not fully agree with other federal award reports the County submits to federal awarding or pass-through entities. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The Countys subrecipients for the year ended June 30, 2022, are associated with amounts paid for eligible program costs of the Countys Coronavirus State and Local Fiscal Recovery Funds Assistance listing #21.027. This is accounted for in the Countys American Rescue Plan Program.The Countys payments to subrecipients as of June 30, 2022, are as follows:Subrecipient Amount Town of Norton $ 2,687,500 Town of Mansfield 1,901,347 Town of Swansea 646,000 Town of Westport 570,000 City of Taunton 543,180 Town of Dighton 273,720 Town of Freetown 135,000 Town of Easton 131,400 City of New Bedford 58,650 Total $ 6,946,797

Finding Details

Finding 2022-002
Finding No. 2022-002 Program: U.S. DEPARTMENT OF TREASURY CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS (CSLFRF) ? ASSISTANCE LISTING # 21.027; SLFRP4044 Criteria: The Uniform Guidance requires grantees to design and implement formalized internal control policies and procedures which address the compliance requirements associated with all federal programs administered by the grantee. Condition and context: The County has worked with other counties and third parties in establishing of procedures, and electronic portals to streamline the administration of the program. The County enters into a written agreement with each community identifying the community as a subrecipient of the County. Currently, the County agreement requires subrecipients to provide copies of audit reports and certification that funds have been used in compliance with applicable laws. Additionally, the County has contracted with two third-party consultants to assist in the initial examination of eligibility of submitted applications in accordance with US Treasury?s program guidelines and additional compliance requirement monitoring. The County?s first expenditures associated with the program began in January 2022. For the fiscal year ended June 30, 2022, the County expended approximately $7.2 million under the program, of which $6.9 million represented advancement of funds to subrecipients on approved projects and $272,000 represented reimbursement on determined eligible costs. Based upon our discussions with County personnel, while responsibilities and due diligence regarding the County?s overall responsibilities related to the program are evident, more enhanced, and formalized internal control policies and procedures which more clearly detail and document the processes (inclusive of subrecipient monitoring) have yet to be completely designed, documented and implemented by the County. Cause: Due to the nature of the award, initial incomplete and changing guidance related thereto, and the importance to provide fiscal relief, the County has worked to implement procedures which provide needed funding to communities for pandemic and other eligible costs in a timely manner. Accordingly, all aspects of the program administration, inclusive of subrecipient monitoring has not been completely implemented. Effect or potential effect: Delay in the development and implementation of a robust subrecipient monitoring program could lead to funds being utilized for unallowed costs which are not detected in a timely manner. Questioned costs: None. Perspective Information: As indicated, this is the first year associated with the program. This is the first year associated with this finding. Auditor?s recommendation: We recommend the County formalize internal control policies and procedures, inclusive of a robust subrecipient monitoring program., While the use of third-party consultants may be useful in the administration of a program of this size and nature, it is important to ensure the processes and documentation thereof, ensure the oversight and actions taken by the County are fully documented throughout the process. Moreover, the County should ensure that implemented policies and procedures ensure that all documentation is ultimately maintained by the County. The Uniform Guidance continues to highlight the importance and requirement for grantees to maintain internal control policies and procedures surrounding the compliance and administration of federal grants, focusing on clearly defining the key components (control environment, risk assessment, control activities, information and communication, monitoring). We recommend the County review and update current policies and procedures manuals to ensure all federal programs? internal control over compliance and central monitoring and reporting thereof is being met. Views of responsible officials: The County implemented a plan associated with the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) to distribute funds to subrecipient communities located in Bristol County. The first expenditures associated with the program began in January 2022. Due to initial incomplete and change in guidance related to the CSLFRF, the County attempted to implement procedures associated with the program. Those procedures changed as the guidance changed. Now that the Final Rules of the CSLFRF have been determined, the County has developed a formalized internal control policy and procedures, including a robust subrecipient monitoring program. The procedures include control environment, risk assessment, control activities, and information and communication monitoring. As part of the procedure, the County insures that all documentation associated with subrecipient grants are maintained by the County. Attached hereto is the current subrecipient policies and procedures.
Finding 2022-002
Finding No. 2022-002 Program: U.S. DEPARTMENT OF TREASURY CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS (CSLFRF) ? ASSISTANCE LISTING # 21.027; SLFRP4044 Criteria: The Uniform Guidance requires grantees to design and implement formalized internal control policies and procedures which address the compliance requirements associated with all federal programs administered by the grantee. Condition and context: The County has worked with other counties and third parties in establishing of procedures, and electronic portals to streamline the administration of the program. The County enters into a written agreement with each community identifying the community as a subrecipient of the County. Currently, the County agreement requires subrecipients to provide copies of audit reports and certification that funds have been used in compliance with applicable laws. Additionally, the County has contracted with two third-party consultants to assist in the initial examination of eligibility of submitted applications in accordance with US Treasury?s program guidelines and additional compliance requirement monitoring. The County?s first expenditures associated with the program began in January 2022. For the fiscal year ended June 30, 2022, the County expended approximately $7.2 million under the program, of which $6.9 million represented advancement of funds to subrecipients on approved projects and $272,000 represented reimbursement on determined eligible costs. Based upon our discussions with County personnel, while responsibilities and due diligence regarding the County?s overall responsibilities related to the program are evident, more enhanced, and formalized internal control policies and procedures which more clearly detail and document the processes (inclusive of subrecipient monitoring) have yet to be completely designed, documented and implemented by the County. Cause: Due to the nature of the award, initial incomplete and changing guidance related thereto, and the importance to provide fiscal relief, the County has worked to implement procedures which provide needed funding to communities for pandemic and other eligible costs in a timely manner. Accordingly, all aspects of the program administration, inclusive of subrecipient monitoring has not been completely implemented. Effect or potential effect: Delay in the development and implementation of a robust subrecipient monitoring program could lead to funds being utilized for unallowed costs which are not detected in a timely manner. Questioned costs: None. Perspective Information: As indicated, this is the first year associated with the program. This is the first year associated with this finding. Auditor?s recommendation: We recommend the County formalize internal control policies and procedures, inclusive of a robust subrecipient monitoring program., While the use of third-party consultants may be useful in the administration of a program of this size and nature, it is important to ensure the processes and documentation thereof, ensure the oversight and actions taken by the County are fully documented throughout the process. Moreover, the County should ensure that implemented policies and procedures ensure that all documentation is ultimately maintained by the County. The Uniform Guidance continues to highlight the importance and requirement for grantees to maintain internal control policies and procedures surrounding the compliance and administration of federal grants, focusing on clearly defining the key components (control environment, risk assessment, control activities, information and communication, monitoring). We recommend the County review and update current policies and procedures manuals to ensure all federal programs? internal control over compliance and central monitoring and reporting thereof is being met. Views of responsible officials: The County implemented a plan associated with the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) to distribute funds to subrecipient communities located in Bristol County. The first expenditures associated with the program began in January 2022. Due to initial incomplete and change in guidance related to the CSLFRF, the County attempted to implement procedures associated with the program. Those procedures changed as the guidance changed. Now that the Final Rules of the CSLFRF have been determined, the County has developed a formalized internal control policy and procedures, including a robust subrecipient monitoring program. The procedures include control environment, risk assessment, control activities, and information and communication monitoring. As part of the procedure, the County insures that all documentation associated with subrecipient grants are maintained by the County. Attached hereto is the current subrecipient policies and procedures.