Audit 393804

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Federal Award Identification Number: H027A240103 Pass-Through Agency: New Hampshire Department of Education Pass-Through Number(s): 20230519, 20241089, 20250423 Award Period: July 1, 2024 – June 30, 2025 Compliance Requirement: Allowable Costs / Cost Principles Type of Finding: • Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.430 indicates charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Such records must also reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Condition and Context: For three (3) of twenty-two (22) payroll transactions tested, time and effort certifications were not completed in a timely manner. Questioned costs: None Cause: Procedures were not in place to ensure that time and effort certifications were completed in a timely manner for all applicable transactions. Effect: Noncompliance with federal requirements occurred. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to ensure that time and effort certifications are completed in a timely manner. Views of responsible officials: Management agrees with the finding.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Federal Award Identification Number: H027A240103 Pass-Through Agency: New Hampshire Department of Education Pass-Through Number(s): 20230519, 20241089, 20250423 Award Period: July 1, 2024 – June 30, 2025 Compliance Requirement: Period of Performance Type of Finding: • Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: A nonfederal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition and Context: Two (2) of eight (8) transactions tested were incurred outside of the period of performance. Questioned costs: Below the reportable threshold. Cause: Procedures were not in place to ensure that expenditures charged to the grant program were incurred within the period of performance in the grant award for all applicable transactions. Effect: Noncompliance with federal requirements occurred. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to ensure that charges to the grant program are incurred within the period of performance included in the grant award. Views of responsible officials: Management agrees with the finding.

Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Assistance Listing Number: 21.027 Federal Award Identification Number: SLFRP1134 Pass-Through Agency: New Hampshire Governor’s Office for Emergency Relief and Recovery Pass-Through Number(s): Unknown Award Period: July 1, 2024 – June 30, 2025 Compliance Requirement: Period of Performance Type of Finding: • Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: A nonfederal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). Specifically regarding SLFRF, recipients must obligate program funds by December 31, 2024. Condition and Context: A portion of the City’s SLFRF expenditures related to revenue loss were spent on the provision of government services. As part of the audit of the SLFRF grant, the City provided us with an initial list of expenditures related to revenue loss. We identified that some of the expenditures were not obligated by December 31, 2024. Subsequently, in accordance with question 17.19 of the U.S. Department of Treasury’s Frequently Asked Questions dated April 29, 2025, the City re-allocated some of the expenditures related to revenue loss. The re-allocated expenditures met period of performance requirements (i.e., they were all obligated by December 31, 2024). Questioned costs: None Cause: Procedures were not in place to ensure that all expenditures initially charged to the grant program were obligated by December 31, 2024 (subsequently corrected as identified above). Effect: Noncompliance with federal requirements initially occurred (subsequently corrected as identified above). Repeat Finding: No. Recommendation: We recommend procedures be strengthened to ensure that charges to the grant program are obligated and/or incurred within the period of performance. Views of responsible officials: Management agrees with the finding.

Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Assistance Listing Number: 21.027 Federal Award Identification Number: SLFRP1134 Pass-Through Agency: New Hampshire Governor’s Office for Emergency Relief and Recovery Pass-Through Number(s): Unknown Award Period: July 1, 2024 – June 30, 2025 Compliance Requirement: Suspension and Debarment Type of Finding: • Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.214 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For one (1) of five (5) vendors tested, documentation was not provided to support that the City verified the vendor was not suspended or debarred from participation in federal assistant programs or activities. Questioned costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in federal programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ suspension or debarment status could cause federal grant funds to be expended to vendors that are excluded from participation in federal assistance programs or activities. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to ensure that documentation of verification of vendors’ suspension and debarment status is obtained prior to executing transactions. Views of responsible officials: Management agrees with the finding.