Finding 2024-006 – Special Education Cluster – AL No. 84.027 Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Condition: Upon review of the Assabet Valley Regional Technical High School’s final expense report filed with the Massachusetts Department of Elementary and Secondary Education it was noted that the reports did not agree with the School’s accounting ledgers. Criteria: Massachusetts Department of Education and Secondary Education Requires: • Final expenditure reports are required to be filed within 60 days of the grant period ending date and agree with accounting ledgers. Context: The Final expense report for the FY 2023 Special Education PL94-142 reported that the grant was fully spent, however the grant was not fully spent per the School’s general ledger. Effect: Assabet Valley Regional Technical High School was not in compliance with the Final Expenditure Reporting requirement as set forth by the Massachusetts Department of Education and Secondary Education as it did not agree to the Schools general ledgers. Questioned Costs: N/A Cause: In June 2023 Assabet’s staff member handling grants retired. They only came in once a week to help with grants until new staff could be hired. In October of 2023 our current grant manager was hired and had very limited training on grants before the retiree quit fully in January 2024. Due to this, training in Edgrants was extremely limited and the FY23 grants mentioned where not handled correctly. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Assabet Valley Regional Technical High School follow procedures to ensure that the Final Expenditure Reports are in agreement with the School’s general ledger. Managements Response: In June 2023 Assabet’s staff member handling grants retired. They only came in once a week to help with grants until new staff could be hired. In October of 2023 our current grant manager was hired and had very limited training on grants before the retiree quit fully in January 2024. Due to this, training in Edgrants was extremely limited and the FY23 grants mentioned where not handled correctly. All grants since FY24/25 in Gem$ have been managed correctly with processing the FER (no longer FR-1) within the 60 days of the grant period. This will be an ongoing every year for all Federal and State Grants. FER’s will be completed once the grant is fully spent according to our general ledger.
Finding 2024-004 – Special Education Cluster – AL No. 84.027 Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Criteria: 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 the applicable cost principles. Management of the School 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. 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: Control deficiencies related to disbursements were noted as a result of the testing of internal controls over payroll. Specifically, a sample of payroll disbursements charged to the major program were tested in order to determine if adequate internal controls were in place. As a result of the testing of payroll disbursements charged to the program, the employees tested were for pay periods outside the period of performance and were found to not have time and effort certifications for the pay periods tested. Cause: We did not have a full-time payroll staff member or a grant manager. Context: During our test of payroll transactions charged to the Special Education Cluster it was noted that Payroll transactions were charged to the FY 24 Special Education PL94-142 grant were for services prior to the grant start date of 8/28/23 in the amount of $24,196.32. Additionally the same payroll transactions were not supported with Time and Effort certifications for payroll charged to the FY 24 Special Education PL94-142. Effect or Potential Effect: Due to the material weakness and noncompliance in internal controls noted above, there is a risk of unallowable expenditures being charged to the federal grant. Identification as a Repeat Finding: This is not a repeat finding. Questioned Costs: Total questioned costs for the payroll charged to the grant that was outside the period of performance and not supported with Time and Effort certifications totaled $24,196.32. Recommendation: The Assabet Valley Regional Technical High School should improve the internal controls over Allowable Costs by ensuring employee’s payroll charged to the federal grant is within the period of performance and supported with Time and Effort certifications. Managements Response: In June 2023 Assabet’s staff member handling grants retired. They only came in once a week to help with grants until new staff could be hired. In October of 2023 our current grant manager was hired and had very limited training on grants before the retiree quit fully in January 2024. Also at the same time we had no trained payroll staff to verify the salaries where paid out of the correct account line. We are double checking that the staff is paid correctly and not before a grant begins or ends. Also all staff will have signed a time and effort sheet for any pay periods they are paid out of grants.
Finding 2024-005 – Special Education Cluster – AL No. 84.027 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 there are expenditures charged to the Special Education Cluster for expenses that are unallowable costs. Criteria: Costs charged to the major programs should meet the requirements as set forth by Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles). Context: During our test of expenditures and review of the general ledger against the Special Education Cluster as it is related to compliance it was noted that the FY 23 Special Education PL94-142 grant had two invoices charged to the grant for promotional items (mugs, shirts, totes, jackets, etc.…) to the budget line as classroom supplies. The FY 2024 Special Education IEP 274 grant had an expense whose supporting documentation was a quote as the invoice was not received. Effect: Assabet Valley RTHS 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: Questioned costs for one of the invoices charged to the FY 23 Special Education PL94-142 was for 72 porcelain mugs was $292.46. Questioned costs for the other invoice charged to the FY 23 Special Education PL94-142 grant was for shirts, totes, jackets, apron, and windbreakers was $1,320.99. Questioned costs for the FY 2024 Special Education IEP 274 grant whose supporting documentation was a quote was $7,950.00. Cause: I glanced at the invoice quickly not paying attention as I normally would due to it was the end of the year and we were closing out the grant, also our former sped director had approved the purchase. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Assabet Valley RTHS 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: All requests for purchases will be double/triple checked. Before paying an invoice items will be checked again that they match the grant requested requirements and laws.
Finding 2024-007 – Education Stabilization Fund – ESSER III AL No. 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Condition: During our test of controls over compliance it was noted that there was an expenditure charged to the Education Stabilization Fund – ESSER III for services outside of the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education. Criteria: The Period of Performance for the Education Stabilization Fund – ESSER III was October 4, 2021 through September 30, 2024. Context: During our test of expenditures and review of the general ledger against the Education Stabilization Fund – ESSER III grant as it is related to compliance it was noted that the School paid in full a four year lease from 3/1/23 to 2/28/27 and charged 10/1/23 to 2/28/27 to the Education Stabilization Fund – ESSER III grant in the amount of $190,869 and thus the period from 10/1/24 to 2/28/27 would be outside the period of performance and thus would not be an allowable cost. Unallowable costs for this period was $52,426. Effect: Assabet Valley RTHS was not in compliance with the period of performance requirement as set forth by the Massachusetts Department of Elementary and Secondary Education. Questioned Costs: Questioned cost charged to the Education Stabilization Fund – ESSER III grant whose service period was beyond the grant end date of September 30, 2024 was in the amount of $52,426. Cause: Grant should have been amended. Identification as a Repeat Finding: 2023-003 Recommendation: We recommend the Assabet Valley RTHS follow procedures to ensure that expenditures charged to the grant is within the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education. Managements Response: Grant has since been corrected and funds where moved to the correct account in our general ledger. Assabet staff is aware that leases cannot be past or before a grants end/start date.
Finding 2024-008 – Education Stabilization Fund – ESSER III AL No. 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Condition: Upon review of the Assabet Valley Regional Technical High School’s final expense report filed with the Massachusetts Department of Elementary and Secondary Education it was noted that the report did not agree with the School’s general ledgers and final amended budget. Criteria: Massachusetts Department of Education and Secondary Education Requires: • Final expenditure reports are required to be filed within 60 days of the grant period ending date and general ledgers. Context: The Final expense report for the ESSER III grant does not agree with the general ledger actual expenses and the final amended budget for ESSER III. Effect: Assabet Valley Regional Technical High School was not in compliance with the Final Expenditure Reporting requirement as set forth by the Massachusetts Department of Education and Secondary Education. Questioned Costs: N/A Cause: In June 2023 Assabet’s staff member handling grants retired. They only came in once a week to help with grants until new staff could be hired. In October of 2023 our current grant manager was hired and had very limited training on grants before the retiree quit fully in January 2024. Due to this, training in Edgrants was extremely limited and the FY23 grants mentioned where not handled correctly. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Assabet Valley Regional Technical High School follow procedures to ensure that the Final Expenditure Report is in agreement with the School’s general ledger total expenses. Managements Response: In June 2023 Assabet’s staff member handling grants retired. They only came in once a week to help with grants until new staff could be hired. In October of 2023 our current grant manager was hired and had very limited training on grants before the retiree quit fully in January 2024. Due to this, training in Edgrants was extremely limited and the FY23 grants mentioned where not handled correctly. Esser III had been amended multiple times, by the time the FR-1 was completed the grant manager quickly went through not realizing it had to match funds and wasn’t automatically changed. Since that time Esser III has been amended and the FR-1 has been competed fully.
Finding 2024-003 – Career and Technical Education - Perkins CFDA No. 84.048 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 with cash management requirements as it relates to the Career and Technology 2023 AL No. 84.048 we discovered that in multiple instances requests for funds (Form RF-1) related to the grant was not based, as much as possible, on actual expenditures, rather than what is obligated. Criteria: Title 34 of the Code of Federal Regulations Section 80.20: Standards for financial management systems requires the following: (b) The financial management systems of other grantees and subgrantees must meet the following standards: 1) Financial reporting. Accurate, current, and complete disclosure of the financial results of financially assisted activities must be made in accordance with the financial reporting requirements of the grant or subgrant. 2) Accounting records. Grantees and subgrantees must maintain records which adequately identify the source and application of funds provided for financially-assisted activities. These records must contain information pertaining to grant or subgrant awards and authorizations, obligations, unobligated balances, assets, liabilities, outlays or expenditures, and income. State Finance Regulations • Form RF1 for requesting funds through an on-line process has been developed to document the Department's distribution of funds on an "as needed" basis. The requests should be based, as much as possible, on actual expenditures, rather than what is obligated. Unexpended balances should not exceed 10% of funds received to date for any DESE administered grants. It is incumbent upon grant recipients to observe their expenditures closely and submit their RF1 forms within the designated timeframe, usually the last two weeks of the month, for requesting cash advances. Grant recipients may make requests in excess of the allotment schedule but must include a justification explaining the need for additional funds and additional documentation may be required. By submitting a request the grantee certifies that the request is in compliance with the "Cash Management Act" (31CFR part 205) and EDGAR regulations (34 CFR part 80.20 and 80.21), which allow for cash advances provided grantees maintain procedures to minimize the time elapsing between the receipt and disbursement of grant funds. Additionally, the grantee certifies that the obligations incurred under this project for which funds are requested, were made within the period of availability (project duration) stated in the grant award notice. The grant records in support of each request must be in sufficient detail to properly substantiate all claims for payment and expenditures made under the grant. Effect: Cash balances in excess of needs may be earning interest in excess of federal guidelines and would need to be returned. Questioned Costs: None Context: During our test of cash disbursements for the Career and Technology 2023 Final Request for Funds indicated fully spent however the grant was not fully spent as of 10/30/23. The School had to return the drawdown on 10/30/23 which also included additional unspent funds on 1/10/24. Cause: In June 2023 Assabet’s staff member handling grants retired. They only came in once a week to help with grants until new staff could be hired. In October of 2023 our current grant manager was hired and had very limited training on grants before the retiree quit fully in January 2024. Due to this, training in Edgrants was extremely limited and the FY23 grants mentioned where not handled correctly. Identification as a Repeat Finding: This is a not a repeat finding. Recommendation: The grantee’s administrative staff should establish procedures to ensure compliance with the cash management requirements as described in 31 CFR part 205. These procedures should include a thorough review of cash needs based on expenditures incurred as of the date of an anticipated draw down and how quickly those related liabilities are anticipated to be liquidated through the normal warrant (bill) payment process. Management’s Response: Going further no funds will be requested unless they have been expensed.
Finding 2024-001 – Career and Technical Education - Perkins CFDA No. 84.048 Department of Education Massachusetts Department of Elementary and Secondary Education Other Matters Related to Internal Control over Compliance of the Major Program Criteria: Massachusetts Department of Education and Secondary Education Requires: • Final expenditure reports are required to be filed within 60 days of the grant period ending date. Condition: During our test of controls over compliance it was noted that the Student Organization grant, 21st Century grant, & Equitable Access grant final expense reports were not filed within 60 days of the grant period ending as required by Massachusetts Department of Education and Secondary Education. Questioned Costs: None Context: During our test of the Final Expenditure Reports it was noted that the Student Organization, 21st Century grant, & Equitable Access Grant final expense reports were not filed within 60 days of the grant period ending as required by Massachusetts Department of Education and Secondary Education. Effect: Assabet Valley Regional Technical High School was not in compliance with the Final Expenditure Reporting requirement date as set forth by the Massachusetts Department of Education and Secondary Education. Cause: In June 2023 Assabet’s staff member handling grants retired. They only came in once a week to help with grants until new staff could be hired. In October of 2023 our current grant manager was hired and had very limited training on grants before the retiree quit fully in January 2024. Due to this, training in Edgrants was extremely limited and the FY23 grants mentioned where not handled correctly. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Assabet Valley Regional Technical High School follow procedures to ensure that the Final Expenditure Reports are filed within the 60 days of the grant period ending date as required by the Massachusetts Department of Education and Secondary Education. Management’s Response: In June 2023 Assabet’s staff member handling grants retired. They only came in once a week to help with grants until new staff could be hired. In October of 2023 our current grant manager was hired and had very limited training on grants before the retiree quit fully in January 2024. Due to this, training in Edgrants was extremely limited and the FY23 grants mentioned where not handled correctly. All grants since FY24/25 in Gem$ have been managed correctly with processing the FER (no longer FR-1) within the 60 days of the grant period. This will be an ongoing every year for all Federal and State Grants.
Finding 2024-002 – Career and Technical Education - Perkins CFDA No. 84.048 Department of Education Massachusetts Department of Elementary and Secondary Education Other Matters Related to Internal Control over Compliance of the Major Program Criteria: Where employees work solely or partially on a single Federal award or cost objective, their salaries or wages must be supported by periodic certification that the employee worked solely 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 School was not able to provide evidence that required semi-annual certifications of time and effort for those employees whose time was wholly spent on these programs was performed in a timely manner as required by Uniform Guidance. Questioned Costs: None Context: During our test of payroll transactions of the FY 2024 Perkins and FY 23 Perkins grants it was noted that the time and effort certifications were not completed in a timely manner as set forth by Uniform Guidance. Effect: The Assabet Valley Regional Technical High School was not in compliance with the time and effort certification requirements. Cause: Compliance of the past grants were not handled correctly due to employee staffing changes and training. Identification as a Repeat Finding: This is not a repeat finding Recommendation: We recommend the Assabet Valley Regional Technical High School follow procedures to ensure that semi-annual certifications are prepared and signed by either the employees 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: Grants compliance will be strictly enforced per DESE and Federal regulations. This includes payroll, time and effort sheets.