Prior Year Finding: No Federal Agency: U.S. Department Commerce Federal Program: Economic Development Cluster City Department: Mayor’s Office of Workforce Development (OWD) Assistance Listing Number: 11.307 Federal Award Number and Year: ED22HDQ3070112 (9/1/2022 – 9/1/2026) ED22HDQ3070112 (7/2/2024 – 9/1/2026) Compliance Requirement: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements. On March 8, 2025, FSRS.gov was retired, and all subaward reporting data and functionality transitioned to SAM.gov after that date. The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. §§ 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.) Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The OWD did not report subaward information in accordance with FFATA requirements. Context: The OWD informed auditors that no subawards were reported. Therefore, a sample was unavailable for testing. Cause: The OWD does not have procedures or controls regarding subaward reporting in accordance with FFATA requirements. Effect: Subawards were not reported in accordance with FFATA requirements. Questioned costs: None noted. Recommendation: We recommend the OWD develop procedures and internal controls to ensure that all required subawards are reported timely and accurately to SAM.gov no later than the end of the month following the month of issuance of each subaward. Views of responsible officials: Management agrees with the finding.
Prior Year Finding: No Federal Agency: Department of Housing and Urban Development Federal Program: Housing Opportunities for Persons with Aids City Department: Mayor’s Office of Housing (MOH) Assistance Listing Number: 14.241 Federal Award Number and Year: MAH21-F001 (8/6/2021-8/6/2024) MAH22-F001 (8/22/2022-8/22/2025) MAH23-F001 (7/13/2023-7/13/2026) MAH24-F001 (9/9/2024-9/9/2027) Compliance Requirement: Special Tests and Provisions – Housing Quality Standards Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: Per 24 CFR sections 574.310(b)(1)-(2), the following standards apply for all housing for which HOPWA funds are used under § 574.300(b)(3), (4), (5), and (8). 1) State and local requirements. Each recipient of assistance under this part must provide safe and sanitary housing that is in compliance with all applicable State and local housing codes, licensing requirements, and any other requirements in the jurisdiction in which the housing is located regarding the condition of the structure and the operation of the housing. 2) HUD housing standards. Except for such variations as are proposed by the grantee and approved by HUD, the housing must meet the standards for HUD housing in 24 CFR 5.703, except that: i. As applied to HOPWA, “HUD housing” in 24 CFR 5.703 means the units eligible persons occupy or will occupy, systems equipment that directly services those units, items and components within the primary and secondary means of egress from those units' doors to the public way, and common features related to the residential use of the building (e.g., the laundry room, community room, mail room). ii. Housing that continues to meet the HOPWA housing quality standards that applied when the eligible person(s) moved into that housing shall not be required to meet new or different standards under 24 CFR 5.703. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: MOH did not perform required housing quality inspections. Context: For seven of nine housing units selected for testing, MOH did not perform the required housing quality inspections. Cause: MOH’s procedures and internal controls were not sufficient to ensure that all required housing quality inspections were performed. Effect: Not performing the required housing quality inspections may result in the City providing support for housing units that do not meet housing quality standards. Questioned costs: Undetermined. Recommendation: We recommend MOH review and enhance internal controls and procedures to ensure that required inspections are performed timely. Views of responsible officials: Management agrees with the finding.
Prior Year Finding: No Federal Agency: Department of Education Federal Program: English Language Acquisition State Grants City Department: Boston Public Schools (BPS) Assistance Listing Number: 84.365 Federal Award Number and Year: S365A220021 (7/1/2022) S365A230021 (7/1/2023) S365A240021 (7/1/2024) Pass-through Agency: Massachusetts Department of Elementary and Secondary Education Pass-through Identifying Number and Year: 180-719236-2023-0035 (10/4/2022-9/30/2024) 180-000547-2024-0035 (9/12/2023-9/30/2025) 180-000547-2025-0035 (9/13/2024-9/30/2026) Compliance Requirement: Allowable Costs/Cost Principles – Time and Effort Reporting Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: 2 CFR Section 200.430 (8)(i) Standards for Documentation of Personnel Expenses states that: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: i. Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ii. Be incorporated into the official records of the non-Federal entity; iii. Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; iv. Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; v. Comply with the established accounting policies and practices of the non-Federal entity; vi. Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: BPS did not have evidence of time and effort certifications. Context: For eight of forty transactions tested, no documentation related to time and effort certifications was maintained by BPS. Cause: BPS controls were not sufficient to ensure that time and effort reporting was performed and documented, in accordance with federal requirements. Effect: There is an increased risk of charging unallowed costs to the program. Questioned costs: $21,174 Recommendation: We recommend BPS should enhance procedures, implement proper controls, and perform additional training over time and effort reporting. BPS should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Documentation should be readily available for audit. Views of responsible officials: Management agrees with the finding.
Prior Year Finding: No Federal Agency: Department of Education Federal Program: English Language Acquisition State Grants City Department: Boston Public Schools (BPS) Assistance Listing Number: 84.365 Federal Award Number and Year: S365A240021 (7/1/2024) Pass-through Agency: Massachusetts Department of Elementary and Secondary Education Pass-through Identifying Number and Year: 180-000547-2025-0035 (9/13/2024-9/30/2026) Compliance Requirement: Period of Performance, Allowable Costs/Cost Principles Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal 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 awardingagency or pass-through entity made the federal award that were authorized by the federal awardingagency 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. 2 CFR Section 200.430 (8)(i) Standards for Documentation of Personnel Expenses states that: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: i. Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ii. Be incorporated into the official records of the non-Federal entity; iii. Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; iv. Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; v. Comply with the established accounting policies and practices of the non-Federal entity; vi. Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: BPS charged costs to the federal grant before the grant’s allowable period of performance. BPS also did not have evidence of timely supervisory review and approval of employee time summary reports. Context: For five of eight transactions tested during the beginning of the period of performance for the FY 2025 award, costs were incurred prior to the period of performance start date. The period of performance start date was September 13, 2024 and the expenditures were incurred on August 26, 2024. For eight of eight transactions tested during the beginning of the period of performance for the FY 2025 award, the payroll department time summary report was not signed and approved timely by the Department head. The department time summary reports were signed and approved subsequent to selection by auditors, approximately sixteen months after the end of the pay period. Cause: BPS’ procedures and internal controls were not operating effectively to ensure that expenditures were charged to the correct grant year. BPS’ controls were not sufficient to ensure that time and effort reporting was performed and documented in a timely manner, in accordance with federal requirements. Effect: Costs could be deemed unallowable by the awarding agency if funds are expended prior to the allowable period of performance. There is an increased risk of charging unallowed costs to the program. Questioned costs: Below the reportable threshold. Recommendation: We recommend BPS review and enhance its procedures and internal controls to ensure it charges expenditures to the program that are incurred within an award’s allowable period of performance. BPS should enhance procedures, implement proper controls, and perform additional training over time and effort reporting. BPS should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Documentation should be readily available for audit. Views of responsible officials: Management agrees with the finding.
Prior Year Finding: No Federal Agency: Department of Education Federal Program: English Language Acquisition State Grants City Department: Boston Public Schools (BPS) Assistance Listing Number: 84.365 Federal Award Number and Year: S365A220021 (7/1/2022) S365A230021 (7/1/2023) S365A240021 (7/1/2024) Pass-through Agency: Massachusetts Department of Elementary and Secondary Education Pass-through Identifying Number and Year: 180-719236-2023-0035 (10/4/2022-9/30/2024) 180-000547-2024-0035 (9/12/2023-9/30/2025) 180-000547-2025-0035 (9/13/2024-9/30/2026) Compliance Requirement: Special Tests and Provisions – Participation of Private School Children Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance: For programs under Title VIII of the ESEA (Assistance Listing 84.011, 84.365, 84.367, and 84.424), an agency, consortium, or entity receiving financial assistance under an applicable program must provide eligible private school children and their teachers or other education personnel with equitable services or other benefits under the program. Before an agency, consortium, or entity makes any decision that affects the opportunity of eligible private school children, teachers, and other educational personnel to participate, the agency, consortium, or entity must engage in timely and meaningful consultation with private school officials. Expenditures for services and benefits to eligible private school children and their teachers and other education personnel must be equal on a per-pupil basis to the expenditures for participating public school children and their teachers and other educational personnel, taking into account the number and education needs of the children, teachers and other education personnel to be services (Section 8501 of ESEA (20 USC 7881); 34 CFR sections 299.6 through 299.9). The control of funds used to provide equitable services to eligible private school students, teachers and other educational personnel, and families, and title to materials, equipment, and property purchased with those funds must be in a public agency and the public agency must administer the funds, materials, equipment, and property. The provision of equitable services must be by employees of a public agency or through a contract by the public agency with an individual, association, agency, or organization that is independent of the private school. The contract must be under the control of the public agency (Sections 1117(d), and 8501(d) of ESEA (20 USC 6320(d), and 7881(d); section 18005(b) of the CARES Act; 34 CFR sections 76.661, 200.64(b)(3), 200.67, and 299.9). Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: BPS did not retain the correspondence with private schools to support the student counts reported in their enrollment calculation. Context: For five of five private schools selected for testing, BPS was unable to provide documentation to support the student counts for private school children. Cause: BPS’ procedures and internal controls were not sufficient to ensure that all supporting documentation relating to compliance with providing equitable services for eligible private school children is maintained. Effect: BPS is potentially using inaccurate or incomplete data when calculating the amount of funds available for equitable services for eligible private school children. Questioned costs: Undetermined. Recommendation: We recommend BPS review and enhance internal controls and procedures to ensure that they retain copies of correspondence with private schools to ensure completeness and accuracy of the calculation. Views of responsible officials: Management agrees with the finding.
Prior Year Finding: 2024-009 Federal Agency: Department of Education Federal Program: Student Support and Academic Enrichment City Department: Boston Public Schools (BPS) Assistance Listing Number: 84.424 Federal Award Number and Year: S424A220022 (7/1/2022) S424A230022 (7/1/2023) S424A240022 (7/1/2024) Pass-through Agency: Massachusetts Department of Elementary and Secondary Education Pass-through Identifying Number and Year: 309-719226-2023-0035 (10/4/2022-9/30/2024) 309-000548-2024-0035 (9/12/2023-9/30/2025) 309-000548-2025-0035 (9/13/2024-9/30/2026) Compliance Requirement: Special Tests and Provisions – Participation of Private School Children Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or specific requirement: Compliance: For programs under Title VIII of the ESEA (Assistance Listing 84.011, 84.365, 84.367, and 84.424), an agency, consortium, or entity receiving financial assistance under an applicable program must provide eligible private school children and their teachers or other education personnel with equitable services or other benefits under the program. Before an agency, consortium, or entity makes any decision that affects the opportunity of eligible private school children, teachers, and other educational personnel to participate, the agency, consortium, or entity must engage in timely and meaningful consultation with private school officials. Expenditures for services and benefits to eligible private school children and their teachers and other education personnel must be equal on a per-pupil basis to the expenditures for participating public school children and their teachers and other educational personnel, taking into account the number and education needs of the children, teachers and other education personnel to be services (Section 8501 of ESEA (20 USC 7881); 34 CFR sections 299.6 through 299.9). The control of funds used to provide equitable services to eligible private school students, teachers and other educational personnel, and families, and title to materials, equipment, and property purchased with those funds must be in a public agency and the public agency must administer the funds, materials, equipment, and property. The provision of equitable services must be by employees of a public agency or through a contract by the public agency with an individual, association, agency, or organization that is independent of the private school. The contract must be under the control of the public agency (Sections 1117(d), and 8501(d) of ESEA (20 USC 6320(d), and 7881(d); section 18005(b) of the CARES Act; 34 CFR sections 76.661, 200.64(b)(3), 200.67, and 299.9). Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: BPS did not retain the correspondence with private schools to support the student counts reported in their enrollment calculation. Context: For seven of seven private schools selected for testing, BPS was unable to provide documentation to support the student counts for private school children. Cause: BPS’ procedures and internal controls were not sufficient to ensure that all supporting documentation relating to compliance with providing equitable services for eligible private school children is maintained. Effect: BPS is potentially using inaccurate or incomplete data when calculating the amount of funds available for equitable services for eligible private school children. Questioned costs: Undetermined. Recommendation: We recommend BPS review and enhance internal controls and procedures to ensure that they retain copies of correspondence with private schools to ensure completeness and accuracy of the calculation. Views of responsible officials: Management agrees with the finding.
Prior Year Finding: No Federal Agency: Department of Homeland Security Federal Program: Homeland Security Grant Program (HSGP) City Department: Mayor’s Office of Emergency Management (OEM) Assistance Listing Number: 97.067 Federal Award Number and Year: UASIFFY21 (2/8/2024-6/30/2025) UASIFFY22 (10/26/2022-6/30/2025) UASIFFY23 (10/15/2023-6/30/2026) Pass-Through Agency: Massachusetts Executive Office of Public Safety and Security Pass-Through Identifying Number and Year: BOSTONFFY21UASI (2/8/2024-6/30/2025) BOSTONFFY2022UASI (10/26/2022-6/30/2025) BOSTONFFY23UASI (10/24/2023-6/30/2026) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per 2 CFR section 200.332(a) - Requirements for Pass-Through Entities states, in part, that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: OEM omitted required federal award information from subawards it issued to their subrecipients. Context: For five of five subawards selected for testing, the subaward agreement did not include the federal award identification number and the federal award date for when the Federal agency awarded the funds to the prime recipient. Cause: OEM’s procedures and internal controls were not sufficient to ensure that subawards included all required information in accordance with 2 CFR 200.332. Effect: Noncompliance with subrecipient monitoring requirements occurred. Additionally, excluding required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program information and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Questioned costs: Undetermined. Recommendation: We recommend OEM review and enhance internal controls and procedures to ensure that required information is included in its subawards. Views of responsible officials: Management agrees with the finding.