Audit 411572

Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency 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, dated, 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 Special Education Grants to States it was noted that in one instance the time and effort certification was not dated, therefore we could not determine the timing that the time and effort certification was completed. During our test of payroll transactions of the FY 2025 Special Education Grants to States grants it was noted that in one instance a time and effort certification was not completed and in 4 instances the time and effort certifications were not dated, therefore we could not determine the timing that the time and effort certification was completed. Effect: The Assabet Valley Regional Technical High School was not in compliance with the time and effort certification requirements. Cause: Inadequate review of the time and effort certifications. Identification as a Repeat Finding: 2024-002 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: The Business Office will thoroughly review the time and effort submissions and ensure all the necessary information such as dates have been provided.

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 expenses. Specifically, a sample of journal entries charged to the major program were tested in order to determine if adequate internal controls were in place. As a result of the testing the journal entries charged to the program, it was noted that expenses where outside the period of performance. Cause: The grant’s effective date was later than it has been historically. The payroll office should have coded the employees’ salaries to the budget, rather than the grant for that first pay period. Context: During our review of journal entries posted to the major program it was noted that a journal entry posted to the FY 2025 Special Education Grants to States grant included an expense that was outside the period of performance as it was for expenses as of 8/28/24 and that grant start date was 9/9/24. The FY 2023 Special Education Grants to States grant included an expense that was outside the period of performance as it was for an expense whose service period was 1/1/25 – 12/31/25 and grant end date was 9/30/24. Effect or Potential Effect: Due to the noncompliance and material weakness in internal controls noted above, there is a risk of unallowable expenditures being charged to the federal grant. Identification as a Repeat Finding: 2024-004 Questioned Costs: Total questioned costs for the expenses charged to the grant that were outside the period of performance was for FY 2025 Special Education Grants to States was $2,499.10 and FY 2023 Special Education Grants to States was $3,612.98. 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: Proper coding procedures were reviewed with Payroll and Business Office staff. They have been instructed to not charge any salaries to a grant until after the start date.

Finding 2025-003 – 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 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). 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. 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 grant had an invoice charged to the grant for promotional clothing to the budget line as classroom supplies. The FY 2024 Special Education IEP grant had an expense that was not part of the approved grant agreement with the pass through entity. The FY 2025 Special Education IEP grant had 2 expenses that were not part of the approved grant agreement with the pass through entity. The FY 2025 Special Education Grants to States grant had five instances where the invoice charged to the grant was not in agreement with the pass through entity’s grant agreement. FY 2025 Special Education Grants to States grant had two expenses whose supporting documentation was a quote as the invoice was not received. Effect: Assabet Valley Regional Technical High School 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: Total questioned costs for the FY 23 Special Education $296.28, FY 2024 Special Education IEP $300.00, FY 2025 Special Education IEP $2,544.00, and FY 2025 Special Education Grants to States $5,862.14. Questioned costs were calculated based on actual invoice costs. Cause: Staff did not properly follow the grant agreement. Staff did not properly review payables to ensure that they were paying for an invoice rather than a quote.. Identification as a Repeat Finding: 2024-005 Recommendation: We recommend the Assabet Valley Regional Technical High School 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: Grant managers and Business Office staff will review purchases for grants to ensure only allowable expenses are paid. The Business Manager will review all warrants for accuracy ensuring invoices and not quotes are paid.

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: The Period of Performance for the Education Stabilization Fund – ESSER III was October 4, 2021 through September 30, 2024. 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. 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 Regional Technical High School 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: Director of Business Operations in FY23 entered into a lease agreement that extended beyond the grant period. Identification as a Repeat Finding: 2024-007 Recommendation: We recommend the Assabet Valley Regional Technical High School 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: On July 1, 2025, the district reclassified the expense to the non-member tuition revolving fund. Grant purchases will be reviewed and approved by the Director of Business Operations. The district will ensure all grant spending is limited to eligible expenses during the eligible time period for the grant. All grant funded purchases will now be checked for time period compliance.