Audit 369308

2024-001 U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster – ALN 10.553, 10.555 & 10.559 Significant Deficiency in Internal Controls Over Compliance Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: The District utilized prices that were competitively procured by French River Collaborative, of which it is a member, and did not obtain individual contracts with the five vendors. Additionally, the District only obtained one of the four required suspension and debarment certifications. Cause: The District did not follow federal award policies and procedures for contract management and suspension and debarment verification when procuring school lunch goods and services. Effect: The District might not obtain the proper negotiated rates that were part of the competitive procurement. The District is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. It was determined that none of the three vendors were suspended or debarred from federal awards. Questioned Costs: None Repeat Finding from Prior Year: Yes; Finding 2023-001 Recommendation: The District should obtain individual contracts with vendors that were competitively procured by the Collaborative and require those vendors to attest on suspension and debarment certifications, for all applicable purchases of goods and services. Views of Responsible Official: Management agrees with the finding.

2024-002 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education COVID-19 – Education Stabilization Fund – ALN 84.425 Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Two final financial reports due during the prior fiscal years were not submitted. Cause: A lack of formal reconciliation and review process for grants. Effect: The District is not in compliance with reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Yes; Finding 2023-003. Recommendation: The District should implement procedures to verify that reports are completed and submitted to the oversight agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.

2024-003 U.S. Department of the Treasury COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - ALN 21.027 Material Weakness in Internal Controls Over Compliance and Compliance Finding Criteria: Per 2 CFR section 200.328 of the Uniform Guidance, each recipient must report program outlays and program income on a cash or accrual basis, as prescribed by the federal awarding agency. The compliance supplement identifies four Key Line Items required to be reported to the federal awarding agency which include (1) current period obligation, (2) cumulative obligation, (3) current period expenditure and (4) cumulative expenditure. An obligation is an order placed for property and services and entering into contracts, subawards, and similar transactions that require payment. Condition: As of the March 31, 2024, reporting date, the Town’s Project and Expenditure report had reported cumulative expenditures that were understated by approximately $148,000 and cumulative obligations were overstated by approximately $3,505,000. Additionally, the Project and Expenditure report for the period ending March 31, 2024, was not filed until March 25, 2025. Cause: The Town did not reconcile the Project and Expenditure report with the Town’s general ledger before submitting. Additionally, the Town had a lack of formal review process to make sure the report was filed in a timely manner. Effect: The Town did not properly report grant expenditures and obligations in the Project and Expenditure report that was filed nearly eleven months after the deadline. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The Town should implement procedures to reconcile the financial information in the Project and Expenditure reports to the Town’s general ledger and contract files within a timely manner of reporting deadline. Views of Responsible Official: Management agrees with the finding.

2024-004 U.S. Department of the Treasury COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - ALN 21.027 Significant Deficiency in Internal Controls Over Compliance and Compliance Finding Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Suspension and debarment compliance was not verified for five vendors. Cause: Lack of formal federal procurement policies and procedures and resulted in required suspension and debarment checks not being performed. Effect: The Town is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. It was determined that none of the five vendors were suspended or debarred from federal awards. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The Town should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred. Views of Responsible Official: Management agrees with the finding.

2024-005 U.S. Department of the Treasury COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - ALN 21.027 Significant Deficiency in Internal Controls Over Compliance Criteria: The Uniform Guidance required written policies regarding cash management, determination of allowable costs, employee travel, procurement and subrecipient monitoring. Condition: The Town did not have formal written policies that covered all federal award criteria, including determination of allowable costs, suspension and debarment and subrecipient monitoring. Cause: Incomplete documentation of policies and procedures. Effect: The Town is not in compliance with the Uniform Guidance requirements. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The Town should implement procedures to document all federal awards policies required by the Uniform Guidance. Views of Responsible Official: Management agrees with the finding.