Special Education Cluster Special Education Grants to States Federal Assistance Listing No. 84.027 Special Education Preschool Grants Federal Assistance Listing No. 84.173 2024-005: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. However, these forms were not completed for each employee whose salary was charged to the grant. A total of 42 payroll expenditures amounting to $206,066, were selected for testing and could not be substantiated through time and effort reports or any similar internal control process. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Effect: The City has not complied with the federal and state time and effort reporting requirements, which could result in improper spending of grant funding. Questioned Costs: Total payroll costs charged to the grant of $1,517,318, are questioned costs. Repeat Finding: This matter was reported as a finding in the previous year as finding 2023-002. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials: See Corrective Action Plan.
Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 2024-006: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Title I grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. However, these forms were not completed for each employee whose salary was charged to the grant. A total of 52 payroll expenditures amounting to $137,766, were selected for testing and could not be substantiated through time and effort reports or any similar internal control process. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Effect: The City has not complied with the federal and state time and effort reporting requirements, which could result in improper spending of grant funding. Questioned Costs: Total payroll costs charged to the grant of $738,305 are questioned costs. Repeat Finding: This matter was reported as a finding in the previous year as finding 2023-003. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines, and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials: See Corrective Action Plan.
Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 2024-007: Eligibility of Schools and Allocations to Schools Compliance Requirement: Eligibility Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must determine which schools or school attendance areas are eligible to participate in the program. When determining eligibility, grantees must select a poverty measure from among one of the allowable data sources. Grantees must serve eligible schools or attendance areas in rank order according to their percentage of poverty. Grantees must also provide equitable services to eligible private school students and homeless students prior to allocating funds to eligible public schools using similar allowable data sources. Condition: The City was required to determine which schools or school attendance areas, including private school students and homeless students, were eligible to participate in the grant program. The City was also required to ensure that eligible schools or school attendance areas were served in rank order in accordance with their percentage of poverty. Supporting documentation that would demonstrate the City’s compliance with determinations of eligibility was not available upon request and was not provided in a timely manner. Context: The City did not provide documentation that would demonstrate the compliance of its eligibility determinations or allocations to schools in a timely manner. Cause: Management has not established guidelines and procedures to ensure that documentation regarding eligibility determinations and allocations is retained and filed in an organized manner that is made readily available for inspection during the audit. Effect: The City has not complied with the grant requirements, which could result in improper spending of grant funding.. Questioned Costs: None reported. Repeat finding: This matter was reported as a finding in the previous year as finding 2023-004. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all documentation regarding eligibility determinations and allocations to schools. The documentation should be filed in an organized manner and should be readily available for inspection during the audit. Views of Responsible Officials: See Corrective Action Plan. U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education
Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2024-008: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Education Stabilization Fund grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. However, these forms were not completed for each employee whose salary was charged to the grant. A total of 38 payroll expenditures amounting to $250,328, were selected for testing and could not be substantiated through time and effort reports or any similar internal control process. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Effect: The City has not complied with the federal and state time and effort reporting requirements, which could result in improper spending of grant funding. Questioned Costs: Total payroll costs charged to the grant of $1,833,922 are questioned costs. Repeat Finding: This matter was reported as a finding in the previous year as finding 2023-006. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials: See Corrective Action Plan.
Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425D, 84.425U and 84.425W 2024-009: Reporting to the State Compliance Requirement: Reporting Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Grantees must comply with reporting requirements established by the Massachusetts Department of Elementary and Secondary Education, the City’s Pass-Through Grantor (State). In order for the State to comply with federal reporting requirements, the City is required to submit complete and accurate “Recipient Data Collection Forms” to the State. Condition: The City was unable to provide copies of the Recipient Data Collection Forms submitted to the State. Context: The City did not maintain sufficient documentation to demonstrate compliance with grant reporting requirements. Cause: Management has not established guidelines and procedures to ensure and demonstrate that required reporting is completed, retained, and available for inspection during the audit. Effect: The City has not complied with the grant requirements, which may jeopardize current or future funding from granting agencies. Questioned Costs: None reported. Repeat finding: This matter was reported as finding in the previous year as finding 2023-008. Recommendation: The City should implement internal control procedures to ensure compliance with all grant requirements including the completion and retention of all required reports. The documentation should be filed in an organized manner and made readily available for inspection during the audit. Views of Responsible Officials: See Corrective Action Plan.