Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Material Noncompliance (Qualified Opinion)
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained.
Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality.
Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval.
Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained.
Effect: The salaries charged are subject to disallowance and are considered questioned costs.
Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Material Noncompliance (Qualified Opinion)
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained.
Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality.
Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval.
Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained.
Effect: The salaries charged are subject to disallowance and are considered questioned costs.
Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Material Noncompliance (Qualified Opinion)
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained.
Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality.
Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval.
Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained.
Effect: The salaries charged are subject to disallowance and are considered questioned costs.
Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Material Noncompliance (Qualified Opinion)
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained.
Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality.
Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval.
Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained.
Effect: The salaries charged are subject to disallowance and are considered questioned costs.
Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Material Noncompliance (Qualified Opinion)
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained.
Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality.
Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval.
Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained.
Effect: The salaries charged are subject to disallowance and are considered questioned costs.
Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Material Noncompliance (Qualified Opinion)
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained.
Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality.
Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval.
Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained.
Effect: The salaries charged are subject to disallowance and are considered questioned costs.
Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Material Noncompliance (Qualified Opinion)
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained.
Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality.
Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval.
Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained.
Effect: The salaries charged are subject to disallowance and are considered questioned costs.
Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Material Noncompliance (Qualified Opinion)
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained.
Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality.
Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval.
Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained.
Effect: The salaries charged are subject to disallowance and are considered questioned costs.
Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Material Noncompliance (Qualified Opinion)
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained.
Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality.
Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval.
Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained.
Effect: The salaries charged are subject to disallowance and are considered questioned costs.
Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Material Noncompliance (Qualified Opinion)
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained.
Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality.
Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval.
Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained.
Effect: The salaries charged are subject to disallowance and are considered questioned costs.
Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: The District charged costs to the program which were not properly approved.
Questioned Costs: None.
Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment.
Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment.
Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs.
Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: The District charged costs to the program which were not properly approved.
Questioned Costs: None.
Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment.
Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment.
Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs.
Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: The District charged costs to the program which were not properly approved.
Questioned Costs: None.
Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment.
Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment.
Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs.
Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: The District charged costs to the program which were not properly approved.
Questioned Costs: None.
Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment.
Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment.
Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs.
Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: The District charged costs to the program which were not properly approved.
Questioned Costs: None.
Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment.
Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment.
Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs.
Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: The District charged costs to the program which were not properly approved.
Questioned Costs: None.
Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment.
Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment.
Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs.
Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: The District charged costs to the program which were not properly approved.
Questioned Costs: None.
Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment.
Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment.
Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs.
Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: The District charged costs to the program which were not properly approved.
Questioned Costs: None.
Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment.
Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment.
Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs.
Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: The District charged costs to the program which were not properly approved.
Questioned Costs: None.
Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment.
Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment.
Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs.
Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: The District charged costs to the program which were not properly approved.
Questioned Costs: None.
Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment.
Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment.
Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs.
Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
• Other Matters
Compliance Requirement: Period of Performance
Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance.
Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance.
Questioned Costs: Under the reportable limit
Context: For 1 of the 4 transactions tested was outside the period of performance.
Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance.
Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs.
Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001.
Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
• Other Matters
Compliance Requirement: Period of Performance
Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance.
Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance.
Questioned Costs: Under the reportable limit
Context: For 1 of the 4 transactions tested was outside the period of performance.
Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance.
Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs.
Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001.
Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
• Other Matters
Compliance Requirement: Period of Performance
Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance.
Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance.
Questioned Costs: Under the reportable limit
Context: For 1 of the 4 transactions tested was outside the period of performance.
Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance.
Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs.
Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001.
Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
• Other Matters
Compliance Requirement: Period of Performance
Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance.
Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance.
Questioned Costs: Under the reportable limit
Context: For 1 of the 4 transactions tested was outside the period of performance.
Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance.
Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs.
Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001.
Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
• Other Matters
Compliance Requirement: Period of Performance
Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance.
Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance.
Questioned Costs: Under the reportable limit
Context: For 1 of the 4 transactions tested was outside the period of performance.
Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance.
Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs.
Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001.
Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
• Other Matters
Compliance Requirement: Period of Performance
Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance.
Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance.
Questioned Costs: Under the reportable limit
Context: For 1 of the 4 transactions tested was outside the period of performance.
Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance.
Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs.
Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001.
Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
• Other Matters
Compliance Requirement: Period of Performance
Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance.
Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance.
Questioned Costs: Under the reportable limit
Context: For 1 of the 4 transactions tested was outside the period of performance.
Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance.
Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs.
Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001.
Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
• Other Matters
Compliance Requirement: Period of Performance
Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance.
Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance.
Questioned Costs: Under the reportable limit
Context: For 1 of the 4 transactions tested was outside the period of performance.
Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance.
Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs.
Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001.
Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
• Other Matters
Compliance Requirement: Period of Performance
Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance.
Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance.
Questioned Costs: Under the reportable limit
Context: For 1 of the 4 transactions tested was outside the period of performance.
Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance.
Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs.
Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001.
Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
• Other Matters
Compliance Requirement: Period of Performance
Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance.
Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance.
Questioned Costs: Under the reportable limit
Context: For 1 of the 4 transactions tested was outside the period of performance.
Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance.
Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs.
Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001.
Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: United State Department of Agriculture
Federal Program: Child Nutrition Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): 12-338-1
Assistance Listing Numbers: 10.553, 10.555
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
• Other Matters
Compliance Requirement: Procurement, Suspension & Debarment
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 Town should have internal controls designed to ensure compliance with those provisions.
Condition: The District was unable to provide documentation that procurement occurred in compliance with federal requirements. In addition, the District did not maintain supporting documentation that vendors were not suspended or debarred.
Questioned Costs: None
Context: 3 of the 5 contracts tested did not contain the history of the procurement transaction to support it was in compliance with federal requirements. In addition, documentation to support the vendors were not suspended or debarred were maintained for any of the 5 contracts tested
Cause: The District did not maintain supporting documentation to support procurement and suspension and debarment compliance.
Effect: Noncompliance with federal procurement, suspension, and debarment compliance requirements.
Recommendation: We recommend the District implement controls that ensure adherence to the procurement and suspension and debarment requirements of the Uniform Guidance.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: United State Department of Agriculture
Federal Program: Child Nutrition Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): 12-338-1
Assistance Listing Numbers: 10.553, 10.555
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
• Other Matters
Compliance Requirement: Procurement, Suspension & Debarment
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 Town should have internal controls designed to ensure compliance with those provisions.
Condition: The District was unable to provide documentation that procurement occurred in compliance with federal requirements. In addition, the District did not maintain supporting documentation that vendors were not suspended or debarred.
Questioned Costs: None
Context: 3 of the 5 contracts tested did not contain the history of the procurement transaction to support it was in compliance with federal requirements. In addition, documentation to support the vendors were not suspended or debarred were maintained for any of the 5 contracts tested
Cause: The District did not maintain supporting documentation to support procurement and suspension and debarment compliance.
Effect: Noncompliance with federal procurement, suspension, and debarment compliance requirements.
Recommendation: We recommend the District implement controls that ensure adherence to the procurement and suspension and debarment requirements of the Uniform Guidance.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: United State Department of Agriculture
Federal Program: Child Nutrition Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): 12-338-1
Assistance Listing Numbers: 10.553, 10.555
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
• Other Matters
Compliance Requirement: Procurement, Suspension & Debarment
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 Town should have internal controls designed to ensure compliance with those provisions.
Condition: The District was unable to provide documentation that procurement occurred in compliance with federal requirements. In addition, the District did not maintain supporting documentation that vendors were not suspended or debarred.
Questioned Costs: None
Context: 3 of the 5 contracts tested did not contain the history of the procurement transaction to support it was in compliance with federal requirements. In addition, documentation to support the vendors were not suspended or debarred were maintained for any of the 5 contracts tested
Cause: The District did not maintain supporting documentation to support procurement and suspension and debarment compliance.
Effect: Noncompliance with federal procurement, suspension, and debarment compliance requirements.
Recommendation: We recommend the District implement controls that ensure adherence to the procurement and suspension and debarment requirements of the Uniform Guidance.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Material Noncompliance (Qualified Opinion)
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained.
Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality.
Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval.
Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained.
Effect: The salaries charged are subject to disallowance and are considered questioned costs.
Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Material Noncompliance (Qualified Opinion)
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained.
Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality.
Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval.
Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained.
Effect: The salaries charged are subject to disallowance and are considered questioned costs.
Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Material Noncompliance (Qualified Opinion)
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained.
Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality.
Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval.
Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained.
Effect: The salaries charged are subject to disallowance and are considered questioned costs.
Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Material Noncompliance (Qualified Opinion)
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained.
Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality.
Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval.
Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained.
Effect: The salaries charged are subject to disallowance and are considered questioned costs.
Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Material Noncompliance (Qualified Opinion)
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained.
Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality.
Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval.
Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained.
Effect: The salaries charged are subject to disallowance and are considered questioned costs.
Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Material Noncompliance (Qualified Opinion)
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained.
Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality.
Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval.
Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained.
Effect: The salaries charged are subject to disallowance and are considered questioned costs.
Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Material Noncompliance (Qualified Opinion)
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained.
Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality.
Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval.
Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained.
Effect: The salaries charged are subject to disallowance and are considered questioned costs.
Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Material Noncompliance (Qualified Opinion)
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained.
Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality.
Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval.
Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained.
Effect: The salaries charged are subject to disallowance and are considered questioned costs.
Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Material Noncompliance (Qualified Opinion)
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained.
Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality.
Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval.
Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained.
Effect: The salaries charged are subject to disallowance and are considered questioned costs.
Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Material Noncompliance (Qualified Opinion)
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: We identified that the District’s internal controls were not designed to ensure proper documentation of the time charged to the grant is maintained.
Questioned Costs: $85,252. These identified costs along with the projection of additionally likely questioned costs over the unsampled population resulted in likely questioned costs exceeding program materiality.
Context: 20 of the 40 transactions tested, no documentation of time and effort was provided. In addition, 15 of 40 transactions, the documentation of time and effort lacked appropriate approval.
Cause: Procedures were not in place to ensure the proper documentation of the time and effort for related payroll charged to the was grant were maintained.
Effect: The salaries charged are subject to disallowance and are considered questioned costs.
Recommendation: We recommend management review their policies and procedures in place to ensure salaries charged to the grants are appropriate and necessary supporting documentation of time and effort is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: The District charged costs to the program which were not properly approved.
Questioned Costs: None.
Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment.
Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment.
Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs.
Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: The District charged costs to the program which were not properly approved.
Questioned Costs: None.
Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment.
Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment.
Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs.
Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: The District charged costs to the program which were not properly approved.
Questioned Costs: None.
Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment.
Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment.
Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs.
Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: The District charged costs to the program which were not properly approved.
Questioned Costs: None.
Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment.
Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment.
Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs.
Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: The District charged costs to the program which were not properly approved.
Questioned Costs: None.
Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment.
Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment.
Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs.
Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: The District charged costs to the program which were not properly approved.
Questioned Costs: None.
Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment.
Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment.
Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs.
Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: The District charged costs to the program which were not properly approved.
Questioned Costs: None.
Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment.
Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment.
Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs.
Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: The District charged costs to the program which were not properly approved.
Questioned Costs: None.
Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment.
Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment.
Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs.
Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: The District charged costs to the program which were not properly approved.
Questioned Costs: None.
Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment.
Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment.
Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs.
Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or specific requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR Part 200.403 (g) states that costs must be adequately documented to be allowable under federal awards.
Condition: The District charged costs to the program which were not properly approved.
Questioned Costs: None.
Context: For 2 of 40 transactions selected for testing, the District was unable to provide documentation of supervisory review and approval prior to issuance of payment.
Cause: The District’s procedures were not sufficient to ensure that payments were reviewed and approved prior to issuance of payment.
Effect: Unallowable costs could be charged to the program if disbursements are not reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs.
Recommendation: We recommend the District reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
• Other Matters
Compliance Requirement: Period of Performance
Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance.
Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance.
Questioned Costs: Under the reportable limit
Context: For 1 of the 4 transactions tested was outside the period of performance.
Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance.
Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs.
Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001.
Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
• Other Matters
Compliance Requirement: Period of Performance
Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance.
Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance.
Questioned Costs: Under the reportable limit
Context: For 1 of the 4 transactions tested was outside the period of performance.
Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance.
Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs.
Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001.
Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
• Other Matters
Compliance Requirement: Period of Performance
Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance.
Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance.
Questioned Costs: Under the reportable limit
Context: For 1 of the 4 transactions tested was outside the period of performance.
Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance.
Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs.
Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001.
Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
• Other Matters
Compliance Requirement: Period of Performance
Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance.
Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance.
Questioned Costs: Under the reportable limit
Context: For 1 of the 4 transactions tested was outside the period of performance.
Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance.
Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs.
Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001.
Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
• Other Matters
Compliance Requirement: Period of Performance
Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance.
Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance.
Questioned Costs: Under the reportable limit
Context: For 1 of the 4 transactions tested was outside the period of performance.
Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance.
Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs.
Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001.
Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
• Other Matters
Compliance Requirement: Period of Performance
Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance.
Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance.
Questioned Costs: Under the reportable limit
Context: For 1 of the 4 transactions tested was outside the period of performance.
Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance.
Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs.
Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001.
Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
• Other Matters
Compliance Requirement: Period of Performance
Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance.
Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance.
Questioned Costs: Under the reportable limit
Context: For 1 of the 4 transactions tested was outside the period of performance.
Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance.
Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs.
Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001.
Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
• Other Matters
Compliance Requirement: Period of Performance
Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance.
Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance.
Questioned Costs: Under the reportable limit
Context: For 1 of the 4 transactions tested was outside the period of performance.
Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance.
Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs.
Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001.
Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
• Other Matters
Compliance Requirement: Period of Performance
Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance.
Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance.
Questioned Costs: Under the reportable limit
Context: For 1 of the 4 transactions tested was outside the period of performance.
Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance.
Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs.
Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001.
Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education
Federal Program: Special Education Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards
Assistance Listing Numbers: 84.027, 84.173
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
• Other Matters
Compliance Requirement: Period of Performance
Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance.
Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance.
Questioned Costs: Under the reportable limit
Context: For 1 of the 4 transactions tested was outside the period of performance.
Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance.
Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs.
Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001.
Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: United State Department of Agriculture
Federal Program: Child Nutrition Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): 12-338-1
Assistance Listing Numbers: 10.553, 10.555
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
• Other Matters
Compliance Requirement: Procurement, Suspension & Debarment
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 Town should have internal controls designed to ensure compliance with those provisions.
Condition: The District was unable to provide documentation that procurement occurred in compliance with federal requirements. In addition, the District did not maintain supporting documentation that vendors were not suspended or debarred.
Questioned Costs: None
Context: 3 of the 5 contracts tested did not contain the history of the procurement transaction to support it was in compliance with federal requirements. In addition, documentation to support the vendors were not suspended or debarred were maintained for any of the 5 contracts tested
Cause: The District did not maintain supporting documentation to support procurement and suspension and debarment compliance.
Effect: Noncompliance with federal procurement, suspension, and debarment compliance requirements.
Recommendation: We recommend the District implement controls that ensure adherence to the procurement and suspension and debarment requirements of the Uniform Guidance.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: United State Department of Agriculture
Federal Program: Child Nutrition Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): 12-338-1
Assistance Listing Numbers: 10.553, 10.555
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
• Other Matters
Compliance Requirement: Procurement, Suspension & Debarment
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 Town should have internal controls designed to ensure compliance with those provisions.
Condition: The District was unable to provide documentation that procurement occurred in compliance with federal requirements. In addition, the District did not maintain supporting documentation that vendors were not suspended or debarred.
Questioned Costs: None
Context: 3 of the 5 contracts tested did not contain the history of the procurement transaction to support it was in compliance with federal requirements. In addition, documentation to support the vendors were not suspended or debarred were maintained for any of the 5 contracts tested
Cause: The District did not maintain supporting documentation to support procurement and suspension and debarment compliance.
Effect: Noncompliance with federal procurement, suspension, and debarment compliance requirements.
Recommendation: We recommend the District implement controls that ensure adherence to the procurement and suspension and debarment requirements of the Uniform Guidance.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: United State Department of Agriculture
Federal Program: Child Nutrition Cluster
Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education
Pass-Through Number(s): 12-338-1
Assistance Listing Numbers: 10.553, 10.555
Type of Finding:
• Significant Deficiency in Internal Control Over Compliance
• Other Matters
Compliance Requirement: Procurement, Suspension & Debarment
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 Town should have internal controls designed to ensure compliance with those provisions.
Condition: The District was unable to provide documentation that procurement occurred in compliance with federal requirements. In addition, the District did not maintain supporting documentation that vendors were not suspended or debarred.
Questioned Costs: None
Context: 3 of the 5 contracts tested did not contain the history of the procurement transaction to support it was in compliance with federal requirements. In addition, documentation to support the vendors were not suspended or debarred were maintained for any of the 5 contracts tested
Cause: The District did not maintain supporting documentation to support procurement and suspension and debarment compliance.
Effect: Noncompliance with federal procurement, suspension, and debarment compliance requirements.
Recommendation: We recommend the District implement controls that ensure adherence to the procurement and suspension and debarment requirements of the Uniform Guidance.
Views of responsible officials: There is no disagreement with the audit finding.