2025-004 Maintain Approved Rate Support for Employee Pay Rates and Time and Effort Support Federal Program(s) Information Federal Agency: U.S. Department of Education Pass-Through Entity: Massachusetts Department of Elementary and Secondary Education Award Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Award Year: 2025 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Type of Finding Compliance Internal Control over Compliance – Significant Deficiency 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 the applicable cost principles. Per 2 CFR 200.430, compensation for personal services must be supported by records that accurately reflect the work performed and be based on approved pay rates consistent with established payroll and personnel policies. Documentation supporting payroll costs charged to Federal awards must be properly authorized and maintained. Condition and Context As part of the testing of twenty-five employees charged to the Child Nutrition Cluster, adequate time and effort documentation supporting the allocation of payroll costs charged to the program for four employees was not provided. Cause Weakness in the design and implementation of internal controls in that payroll costs lacked sufficient supporting documentation to demonstrate costs charged to the program were based on actual work performed. Effect or Potential Effect Due to the weakness in internal controls noted above, there is a risk that amounts charged to federal awards may not be allowable or in accordance with applicable cost principles. Questioned Costs - Not determinable. Identification as a Repeat Finding - This is not a repeat finding. Recommendation The City should implement formal procedures to ensure all employee pay rates are supported by approved and retained documentation and implement controls to ensure time and effort reporting is prepared, reviewed, and maintained. View of Responsible Officials Management’s corrective action plan is included at the end of this report after the Summary Schedule of Prior Year Findings.
2025-002 Improve Procurement Procedures Federal Program(s) Information Federal Agency: U.S. Department of Education Pass-Through Entity: Massachusetts Department of Elementary and Secondary Education Award Name: Special Education Grants to States Assistance Listing Number: 84.027 Award Year: 2024, 2025 Compliance Requirement: Procurement Type of Finding Compliance Internal Control over Compliance – Material Weakness Criteria or Specific Requirement OMB’s Uniform Administrative Requirement, Cost Principles, and Audit Requirements for Federal Awards (UG) requires that grant recipients follow procurement procedures for the acquisition of property or services under a federal award. Management is also responsible for establishing and maintaining effective internal controls 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. In addition, per Uniform Guidance (2 CFR § 200.327 and 2 CFR Part 200, Appendix II), all contracts made by non-federal entities under federal awards must contain specific provisions as applicable, such as those for the Byrd Anti-Lobbying Amendment and others. These provisions are required to ensure compliance with federal program requirements for procurement. Condition and Context A sample of procurement transactions were tested in order to determine if appropriate procedures were performed in line with Uniform Guidance procurement requirements. As a result of our testing, it was determined that one of our four selections for services paid for by the Special Education Cluster grants did not follow UG procurement procedures and instead relied on state exemptions. In addition, two of our four selections did not contain the required Byrd Anti-Lobbying Amendment contract provision for contracts in excess of $100,0000. Cause The City’s procurement processes did not include sufficient controls to ensure that all federally required contract provisions were incorporated into every contract funded with federal awards and that the more restrictive procurement policies were followed. Effect or Potential Effect Due to the weaknesses in internal control noted above, there is a risk that procurements may be awarded to vendors in a manner that is not consistent with federal procurement requirements. Lack of inclusion of all required federal contract provisions increases the risk of noncompliance with Uniform Guidance and could lead to disputes or enforcement issues if regulatory or compliance matters arise. Questioned Costs Known questioned costs for the vendor not appropriately procured are as follows. No questioned costs were reported as it relates to the missing contract provision as the requirement is administrative in nature. AL Number(s) Name of Federal Program or Cluster Questioned Costs 84.027 Special Education Grants to States $384,018 Identification as a Repeat Finding This is a repeat of finding 2024-002 in the prior year. Recommendation The City should address the weaknesses in internal controls noted above in order to ensure that federal procurements are conducted in accordance with federal and state requirements. In addition, the City should enhance its procurement procedures to ensure all contracts funded by federal awards include every provision required by Appendix II to 2 CFR Part 200 as applicable. Regular review of contract templates and procurement checklists should be implemented to support compliance. View of Responsible Officials Management’s corrective action plan is included at the end of this report after the Summary Schedule of Prior Year Findings.
2025-001 Maintain Employee’s Time and Effort Records Federal Program(s) Information Federal Agency: U.S. Department of Education Pass-Through Entity: Massachusetts Department of Elementary and Secondary Education Award Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Award Year: 2023, 2024, 2025 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Federal Agency: U.S. Department of Education Pass-Through Entity: Massachusetts Department of Elementary and Secondary Education Award Name: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010 Award Year: 2024, 2025 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Type of Finding Compliance Internal Control over Compliance – Material Weakness 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 the applicable cost principles. Management of the City 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. The Code of Federal Regulations Section 200.403(g) states that for costs to be allowable under Federal awards, they must be adequately documented and there must be sufficient documentation. Condition and Context As part of the prior year single audit, a material weakness and material noncompliance was identified as it relates to payroll costs in that time and effort certifications were not maintained to support allowability of employee time charged to the programs. Based on discussions with the City and review of employee files, the City confirmed that the time and effort certifications were not maintained for the current fiscal year. Cause Weakness in the design and implementation of internal controls. Effect or Potential Effect Due to the weakness in internal controls noted above, there is a risk that amounts charged to federal awards may not be allowable or in accordance with applicable cost principles. Questioned Costs Due to the condition noted, we were unable to determine if the costs charged to the applicable grants are allowable. AL Number(s) Name of Federal Program or Cluster Questioned Costs 84.027/84.173 Special Education Cluster $3,816,855 84.010 Title I Grants to Local Educational Agencies $6,816,077 Identification as a Repeat Finding This is a repeat of finding 2024-001 in the prior year. Recommendation The City should address the weaknesses in internal controls noted above in order to provide reasonable assurance that federal award transactions are allowable and in accordance with the applicable cost principles. View of Responsible Officials Management’s corrective action plan is included at the end of this report after the Summary Schedule of Prior Year Findings.
2025-003 Improve Controls over Period of Performance Federal Program(s) Information Federal Agency: U.S. Department of Education Pass-Through Entity: Massachusetts Department of Elementary and Secondary Education Award Name: Special Education Grants to States Assistance Listing Number: 84.027 Award Year: 2024 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles, Period of Performance Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement Uniform Guidance (2 CFR § 200.403, 200.309) requires that costs charged to a federal award be allowable, allocable, and incurred within the grant’s period of performance. Expenditures incurred outside of the specified performance period are not allowable charges to the federal program. Condition and Context Of the twenty-five non-payroll transactions tested for the Special Education Cluster, two invoices charged to the 2024 award were incurred and paid outside of the grant’s period of performance. The City established purchase orders for these transactions in September of 2024. Due to staffing changes within the Grants and Special Education Departments, attention shifted to fiscal year 2025 activities under the assumption that all fiscal year 2024 obligations had been processed. Consequently, this encumbrance was inadvertently overlooked, and the final grant report was submitted in January based on the remaining available balance. The unprocessed payment was identified only after the vendor contacted the school regarding the outstanding balance, leading to the recognition that the payment was not timely processed. Cause The City did not have effective internal controls to ensure all obligations were identified, tracked, and paid within the grant’s period of performance, particularly during periods of staff turnover. Effect or Potential Effect Payments for obligations incurred outside the period of performance are unallowable under federal regulations. This increases the risk of unallowable costs being charged to the grant. Questioned Costs Known questioned costs are reported as follows: AL Number(s) Name of Federal Program or Cluster Questioned Costs 84.027 Special Education Grants to States $112,707 Identification as a Repeat Finding This is not a repeat finding. Recommendation The City should strengthen internal controls to ensure all purchase orders and obligations are monitored, documented, and paid within the grant’s period of performance. Additional procedures should be implemented to review unliquidated obligations prior to final grant reporting, especially during periods of staff transitions. View of Responsible Officials Management’s corrective action plan is included at the end of this report after the Summary Schedule of Prior Year Findings.