Finding 2024-003 – Education Stabilization Fund – AL No.’s 84.425U & 84.425W Special Education Cluster – AL No.’s 84.027 & 84.173 Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Programs Criteria: Where employees work solely or partially on a single Federal program or cost objective, their salaries or wages must be supported by periodic certification that the employee worked on these programs for the period covered by the programs. The certifications should be prepared at least semi-annually, and should be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee. Condition: During our test of controls over compliance with time and effort certifications the Town was not able to provide evidence that the required certifications of time and effort for those employees whose time was spent either completely or partially spent on these programs was performed as required by Uniform Guidance. Questioned Costs: Unknown Context: During our test of payroll transactions of the major programs (Education Stabilization Fund and Special Education Cluster) it was noted that the time and effort certifications for the employees tested were not singed by the supervisory official. Effect: The Town was not in compliance with the time and effort certification requirements. Cause: The District has made great efforts to ensure time and effort certification compliance. While the District is having the Supervisor execute and approve timesheets for payment, the Supervisor’s signature was omitted from the Time & Effort Certification. The District is issuing Time & Effort Certifications to all employees working and being paid from a Federal grant semi-annually, including sending Certified Mail, Return Receipt documentation to former employees. Identification as a Repeat Finding: 2023-004 Recommendation: We recommend the Town of Bellingham follow procedures to ensure that semi-annual certifications and/or monthly certifications are prepared and signed by either the employees and/or supervisory official having first-hand knowledge of the work performed by the employees in a timely manner in order to comply with the time and effort certification requirement. Management Response: The District will incorporate the Supervisor’s signature to all Time & Effort Certifications immediately upon this finding, January 1, 2026.
Finding 2024-003 – Education Stabilization Fund – AL No.’s 84.425U & 84.425W Special Education Cluster – AL No.’s 84.027 & 84.173 Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Programs Criteria: Where employees work solely or partially on a single Federal program or cost objective, their salaries or wages must be supported by periodic certification that the employee worked on these programs for the period covered by the programs. The certifications should be prepared at least semi-annually, and should be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee. Condition: During our test of controls over compliance with time and effort certifications the Town was not able to provide evidence that the required certifications of time and effort for those employees whose time was spent either completely or partially spent on these programs was performed as required by Uniform Guidance. Questioned Costs: Unknown Context: During our test of payroll transactions of the major programs (Education Stabilization Fund and Special Education Cluster) it was noted that the time and effort certifications for the employees tested were not singed by the supervisory official. Effect: The Town was not in compliance with the time and effort certification requirements. Cause: The District has made great efforts to ensure time and effort certification compliance. While the District is having the Supervisor execute and approve timesheets for payment, the Supervisor’s signature was omitted from the Time & Effort Certification. The District is issuing Time & Effort Certifications to all employees working and being paid from a Federal grant semi-annually, including sending Certified Mail, Return Receipt documentation to former employees. Identification as a Repeat Finding: 2023-004 Recommendation: We recommend the Town of Bellingham follow procedures to ensure that semi-annual certifications and/or monthly certifications are prepared and signed by either the employees and/or supervisory official having first-hand knowledge of the work performed by the employees in a timely manner in order to comply with the time and effort certification requirement. Management Response: The District will incorporate the Supervisor’s signature to all Time & Effort Certifications immediately upon this finding, January 1, 2026.
Finding 2024-003 – Education Stabilization Fund – AL No.’s 84.425U & 84.425W Special Education Cluster – AL No.’s 84.027 & 84.173 Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Programs Criteria: Where employees work solely or partially on a single Federal program or cost objective, their salaries or wages must be supported by periodic certification that the employee worked on these programs for the period covered by the programs. The certifications should be prepared at least semi-annually, and should be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee. Condition: During our test of controls over compliance with time and effort certifications the Town was not able to provide evidence that the required certifications of time and effort for those employees whose time was spent either completely or partially spent on these programs was performed as required by Uniform Guidance. Questioned Costs: Unknown Context: During our test of payroll transactions of the major programs (Education Stabilization Fund and Special Education Cluster) it was noted that the time and effort certifications for the employees tested were not singed by the supervisory official. Effect: The Town was not in compliance with the time and effort certification requirements. Cause: The District has made great efforts to ensure time and effort certification compliance. While the District is having the Supervisor execute and approve timesheets for payment, the Supervisor’s signature was omitted from the Time & Effort Certification. The District is issuing Time & Effort Certifications to all employees working and being paid from a Federal grant semi-annually, including sending Certified Mail, Return Receipt documentation to former employees. Identification as a Repeat Finding: 2023-004 Recommendation: We recommend the Town of Bellingham follow procedures to ensure that semi-annual certifications and/or monthly certifications are prepared and signed by either the employees and/or supervisory official having first-hand knowledge of the work performed by the employees in a timely manner in order to comply with the time and effort certification requirement. Management Response: The District will incorporate the Supervisor’s signature to all Time & Effort Certifications immediately upon this finding, January 1, 2026.
Finding 2024-003 – Education Stabilization Fund – AL No.’s 84.425U & 84.425W Special Education Cluster – AL No.’s 84.027 & 84.173 Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Programs Criteria: Where employees work solely or partially on a single Federal program or cost objective, their salaries or wages must be supported by periodic certification that the employee worked on these programs for the period covered by the programs. The certifications should be prepared at least semi-annually, and should be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee. Condition: During our test of controls over compliance with time and effort certifications the Town was not able to provide evidence that the required certifications of time and effort for those employees whose time was spent either completely or partially spent on these programs was performed as required by Uniform Guidance. Questioned Costs: Unknown Context: During our test of payroll transactions of the major programs (Education Stabilization Fund and Special Education Cluster) it was noted that the time and effort certifications for the employees tested were not singed by the supervisory official. Effect: The Town was not in compliance with the time and effort certification requirements. Cause: The District has made great efforts to ensure time and effort certification compliance. While the District is having the Supervisor execute and approve timesheets for payment, the Supervisor’s signature was omitted from the Time & Effort Certification. The District is issuing Time & Effort Certifications to all employees working and being paid from a Federal grant semi-annually, including sending Certified Mail, Return Receipt documentation to former employees. Identification as a Repeat Finding: 2023-004 Recommendation: We recommend the Town of Bellingham follow procedures to ensure that semi-annual certifications and/or monthly certifications are prepared and signed by either the employees and/or supervisory official having first-hand knowledge of the work performed by the employees in a timely manner in order to comply with the time and effort certification requirement. Management Response: The District will incorporate the Supervisor’s signature to all Time & Effort Certifications immediately upon this finding, January 1, 2026.
Finding 2024-003 – Education Stabilization Fund – AL No.’s 84.425U & 84.425W Special Education Cluster – AL No.’s 84.027 & 84.173 Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Programs Criteria: Where employees work solely or partially on a single Federal program or cost objective, their salaries or wages must be supported by periodic certification that the employee worked on these programs for the period covered by the programs. The certifications should be prepared at least semi-annually, and should be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee. Condition: During our test of controls over compliance with time and effort certifications the Town was not able to provide evidence that the required certifications of time and effort for those employees whose time was spent either completely or partially spent on these programs was performed as required by Uniform Guidance. Questioned Costs: Unknown Context: During our test of payroll transactions of the major programs (Education Stabilization Fund and Special Education Cluster) it was noted that the time and effort certifications for the employees tested were not singed by the supervisory official. Effect: The Town was not in compliance with the time and effort certification requirements. Cause: The District has made great efforts to ensure time and effort certification compliance. While the District is having the Supervisor execute and approve timesheets for payment, the Supervisor’s signature was omitted from the Time & Effort Certification. The District is issuing Time & Effort Certifications to all employees working and being paid from a Federal grant semi-annually, including sending Certified Mail, Return Receipt documentation to former employees. Identification as a Repeat Finding: 2023-004 Recommendation: We recommend the Town of Bellingham follow procedures to ensure that semi-annual certifications and/or monthly certifications are prepared and signed by either the employees and/or supervisory official having first-hand knowledge of the work performed by the employees in a timely manner in order to comply with the time and effort certification requirement. Management Response: The District will incorporate the Supervisor’s signature to all Time & Effort Certifications immediately upon this finding, January 1, 2026.
Finding 2024-001 – Education Stabilization Fund – AL No.’s 84.425U & 84.425W Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Condition: During our test of controls over compliance it was noted that one expense charged to the 2023 Hi Quality Instructional Materials grant major program was not an allowable expense. Criteria: Costs charged to the 2023 Hi Quality Instructional Materials grant major program should meet the requirements as set forth by Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles). Context: During our review of expenses charged to the 2023 Hi Quality Instructional Materials grant it was noted that one expense that was charged to the grant whose service period was outside the period of performance and thus an unallowable cost. Effect: Town of Bellingham was not in compliance with the allowable costs/ cost principals requirement as set forth by the Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles). Questioned Costs: $2,170.00 Cause: The District utilized the FY2023 Hi Quality Instructional Materials grant to fund subscription(s) that support organizational assessment data results for Social & Emotional learning, with the understanding that the subscription started during the grant's timeframe but did not consider that the subscription would extend beyond the grant period. Identification as a Repeat Finding: N/A Recommendation: We recommend the Town of Bellingham follow procedures to ensure that expenditures charged to the grants are allowable costs as set forth by Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles) Managements Response: The District will not utilize grant funds to support subscriptions that span outside of the grant-funding timeframe.
Finding 2024-003 – Education Stabilization Fund – AL No.’s 84.425U & 84.425W Special Education Cluster – AL No.’s 84.027 & 84.173 Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Programs Criteria: Where employees work solely or partially on a single Federal program or cost objective, their salaries or wages must be supported by periodic certification that the employee worked on these programs for the period covered by the programs. The certifications should be prepared at least semi-annually, and should be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee. Condition: During our test of controls over compliance with time and effort certifications the Town was not able to provide evidence that the required certifications of time and effort for those employees whose time was spent either completely or partially spent on these programs was performed as required by Uniform Guidance. Questioned Costs: Unknown Context: During our test of payroll transactions of the major programs (Education Stabilization Fund and Special Education Cluster) it was noted that the time and effort certifications for the employees tested were not singed by the supervisory official. Effect: The Town was not in compliance with the time and effort certification requirements. Cause: The District has made great efforts to ensure time and effort certification compliance. While the District is having the Supervisor execute and approve timesheets for payment, the Supervisor’s signature was omitted from the Time & Effort Certification. The District is issuing Time & Effort Certifications to all employees working and being paid from a Federal grant semi-annually, including sending Certified Mail, Return Receipt documentation to former employees. Identification as a Repeat Finding: 2023-004 Recommendation: We recommend the Town of Bellingham follow procedures to ensure that semi-annual certifications and/or monthly certifications are prepared and signed by either the employees and/or supervisory official having first-hand knowledge of the work performed by the employees in a timely manner in order to comply with the time and effort certification requirement. Management Response: The District will incorporate the Supervisor’s signature to all Time & Effort Certifications immediately upon this finding, January 1, 2026.
Finding 2024-003 – Education Stabilization Fund – AL No.’s 84.425U & 84.425W Special Education Cluster – AL No.’s 84.027 & 84.173 Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Programs Criteria: Where employees work solely or partially on a single Federal program or cost objective, their salaries or wages must be supported by periodic certification that the employee worked on these programs for the period covered by the programs. The certifications should be prepared at least semi-annually, and should be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee. Condition: During our test of controls over compliance with time and effort certifications the Town was not able to provide evidence that the required certifications of time and effort for those employees whose time was spent either completely or partially spent on these programs was performed as required by Uniform Guidance. Questioned Costs: Unknown Context: During our test of payroll transactions of the major programs (Education Stabilization Fund and Special Education Cluster) it was noted that the time and effort certifications for the employees tested were not singed by the supervisory official. Effect: The Town was not in compliance with the time and effort certification requirements. Cause: The District has made great efforts to ensure time and effort certification compliance. While the District is having the Supervisor execute and approve timesheets for payment, the Supervisor’s signature was omitted from the Time & Effort Certification. The District is issuing Time & Effort Certifications to all employees working and being paid from a Federal grant semi-annually, including sending Certified Mail, Return Receipt documentation to former employees. Identification as a Repeat Finding: 2023-004 Recommendation: We recommend the Town of Bellingham follow procedures to ensure that semi-annual certifications and/or monthly certifications are prepared and signed by either the employees and/or supervisory official having first-hand knowledge of the work performed by the employees in a timely manner in order to comply with the time and effort certification requirement. Management Response: The District will incorporate the Supervisor’s signature to all Time & Effort Certifications immediately upon this finding, January 1, 2026.
Finding 2024-002 – COVID 19 – Coronavirus State and Local Fiscal Recovery Fund - AL No. 21.027 U.S. Department of Treasury Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. As governmental subrecipients of states they are also required to use the same state procurement policies and procedures for federal funds as for non‐federal funds, the Town is required to follow Massachusetts General Laws, Chapter (MGL) 30(b). MGL 30(b) requires the solicitation of three written or oral quotes for procurements of supplies between $10,000 and $49,999 and sealed bids or proposals for procurements of supplies $50,000 and over. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. However, a deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context: During fiscal year 2024, the Town did not comply with the required procurement policies and procedures in place as it related to expenses charged to the major program requiring procurement procedures. One of the expenses tested was for engineering services that would have been exempt under Massachusetts General Laws, Chapter (MGL) 30(b) (State Procurement Requirement), under federal statutes and procurement requirements for engineering services identified in 2 CFR Part 200, the Town would have been required to go out to bid for the services. Questioned Costs: $413,477.78 Cause: The noncompliance occurred because the organization mistakenly relied on Massachusetts Chapter 30B exemptions, which govern state and local procurements, and did not recognize the need to comply with the more stringent federal procurement requirements for federal fund usage. Staff members were not sufficiently aware of the specific requirements under 2 CFR Part 200 and the precedence of federal procurement regulations over state law in this context. Effect or Potential Effect: There is risk that the amounts charged to the federal awards major program may not be in accordance with procurement, suspension, and debarment principles. Identification as a Repeat Finding: 2023-003 Recommendation: The Town of Bellingham should address the nocompliance and material weakness in internal controls noted above in order to ensure that procurements are conducted in accordance with federal and state requirements. Management Response: We acknowledge the audit finding regarding our reliance on Massachusetts Chapter 30B exemptions for procurement involving federal funds. We understand that federal procurement regulations under 2 CFR Part 200 take precedence over state law and that we failed fully to comply with federal requirements for competitive bidding, sole-source justification, and documentation. We are committed to addressing this issue by reviewing our procurement policies to clearly differentiate between state and federal requirements, ensuring that federal standards govern all procurement involving federal funds. We will provide additional training to staff, implement stronger documentation procedures, and review past procurement to ensure full compliance moving forward.