Federal Agency: U.S. Department of Education
Federal Program Name: Special Education Cluster
Assistance Listing Number: 84,027, 84.173
Federal Award Identification Number: N/A
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and the Massachusetts Department of Early Education and Care
Pass-Through Number(s): 240-585359-2022-0131, 240-744100-2023-0131, 252-610784-2022-0131, 262-585362-2022-0131, 262-744101-2023-0131, 264-610783-2022-0131
Award Period: July 1, 2021 – June 30, 2023
Compliance Requirement: Allowable Costs / Cost Principles
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Material Noncompliance (Modified Opinion)
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:
Three (3) of nine (9) payroll transactions in our statistically valid sample were not supported with documentation of level of effort for the grant.
Questioned costs:
• Known: $13,438
• Likely: $96,278
Cause:
Procedures were not in place to ensure that supporting payroll records accurately reflected the time and effort charged to the program.
Effect:
Noncompliance with federal compliance requirements occurred.
Repeat Finding:
No.
Recommendation:
We recommend procedures be implemented to ensure that records supporting the distribution of employee time and effort accurately reflect the charges to the grant program.
Views of responsible officials:
Hingham Public Schools has circulated training guides and templates to grant writers on the requirement to have time and effort reporting completed in a timely manner for staff assigned to specific grants. Grant accounting associates have also been provided with the training material to ensure that there is an additional review of time and effort reports as part of the grant accounting, review and finalization process.
Federal Agency: U.S. Department of Education
Federal Program Name: Special Education Cluster
Assistance Listing Number: 84.027, 84.173
Federal Award Identification Number: N/A
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and the Massachusetts Department of Early Education and Care
Pass-Through Number(s): 240-585359-2022-0131, 240-744100-2023-0131, 252-610784-2022-0131, 262-585362-2022-0131, 262-744101-2023-0131, 264-610783-2022-0131
Award Period: July 1, 2021 – June 30, 2023
Compliance Requirement: Procurement, Suspension and Debarment
Type of Finding: Significant Deficiency in Internal Control Over Compliance, 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:
Procedures were not in place to ensure three (3) of five (5) vendors selected for testing in our statistically valid sample and paid from the grant award were not suspended or debarred. Upon further testing, it was determined none of the vendors were suspended or debarred.
Questioned costs:
None
Cause:
Procedures were not in place to ensure vendors are not suspended or debarred.
Effect:
Federal funds could be expended to suspended or debarred vendors and subject to disallowance.
Repeat Finding:
No.
Recommendation:
We recommend the Town enhance procedures and controls to ensure verifications of suspension and debarment statuses are obtained from vendors prior to executing transactions with these vendors.
Views of responsible officials:
Management has updated procedures to ensure vendors are not suspended or debarred and has shared and reviewed this information with staff to ensure that the procedure is carefully followed.
Federal Agency: U.S. Department of Education
Federal Program Name: ESSER I
Assistance Listing Number: 84.425D
Federal Award Identification Number: N/A
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education
Pass-Through Number(s): 113-397270-2021-0131
Award Period: July 1, 2021 – June 30, 2023
Compliance Requirement: Allowable Costs / Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance, 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:
Ten (10) of ten (10) payroll transactions in our statistically valid sample were supported by records which accurately reflected the work performed. However, such records did not include documented evidence of review and approval which would provide reasonable assurance that the charges were accurate, allowable, and properly allocated.
Questioned costs:
Below the reportable limit
Cause:
Procedures were not in place to ensure the payroll records were supported by the Town’s internal controls.
Effect:
Federal funds could be expended for unallowable activities and subject to disallowance.
Repeat Finding:
Yes, 2022-002
Recommendation:
We recommend procedures be implemented to ensure that the records supporting payroll charges to the federal grant program include documented evidence of review and approval.
Views of responsible officials:
The Hingham Public School's general weekly payroll is approved on a weekly basis by Management. In the case of our summer programs a similar control has been put in place by Management to ensure all payroll records are approved before processing.
Federal Agency: U.S. Department of Education
Federal Program Name: Special Education Cluster
Assistance Listing Number: 84,027, 84.173
Federal Award Identification Number: N/A
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and the Massachusetts Department of Early Education and Care
Pass-Through Number(s): 240-585359-2022-0131, 240-744100-2023-0131, 252-610784-2022-0131, 262-585362-2022-0131, 262-744101-2023-0131, 264-610783-2022-0131
Award Period: July 1, 2021 – June 30, 2023
Compliance Requirement: Allowable Costs / Cost Principles
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Material Noncompliance (Modified Opinion)
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:
Three (3) of nine (9) payroll transactions in our statistically valid sample were not supported with documentation of level of effort for the grant.
Questioned costs:
• Known: $13,438
• Likely: $96,278
Cause:
Procedures were not in place to ensure that supporting payroll records accurately reflected the time and effort charged to the program.
Effect:
Noncompliance with federal compliance requirements occurred.
Repeat Finding:
No.
Recommendation:
We recommend procedures be implemented to ensure that records supporting the distribution of employee time and effort accurately reflect the charges to the grant program.
Views of responsible officials:
Hingham Public Schools has circulated training guides and templates to grant writers on the requirement to have time and effort reporting completed in a timely manner for staff assigned to specific grants. Grant accounting associates have also been provided with the training material to ensure that there is an additional review of time and effort reports as part of the grant accounting, review and finalization process.
Federal Agency: U.S. Department of Education
Federal Program Name: Special Education Cluster
Assistance Listing Number: 84.027, 84.173
Federal Award Identification Number: N/A
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and the Massachusetts Department of Early Education and Care
Pass-Through Number(s): 240-585359-2022-0131, 240-744100-2023-0131, 252-610784-2022-0131, 262-585362-2022-0131, 262-744101-2023-0131, 264-610783-2022-0131
Award Period: July 1, 2021 – June 30, 2023
Compliance Requirement: Procurement, Suspension and Debarment
Type of Finding: Significant Deficiency in Internal Control Over Compliance, 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:
Procedures were not in place to ensure three (3) of five (5) vendors selected for testing in our statistically valid sample and paid from the grant award were not suspended or debarred. Upon further testing, it was determined none of the vendors were suspended or debarred.
Questioned costs:
None
Cause:
Procedures were not in place to ensure vendors are not suspended or debarred.
Effect:
Federal funds could be expended to suspended or debarred vendors and subject to disallowance.
Repeat Finding:
No.
Recommendation:
We recommend the Town enhance procedures and controls to ensure verifications of suspension and debarment statuses are obtained from vendors prior to executing transactions with these vendors.
Views of responsible officials:
Management has updated procedures to ensure vendors are not suspended or debarred and has shared and reviewed this information with staff to ensure that the procedure is carefully followed.
Federal Agency: U.S. Department of Education
Federal Program Name: ESSER I
Assistance Listing Number: 84.425D
Federal Award Identification Number: N/A
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education
Pass-Through Number(s): 113-397270-2021-0131
Award Period: July 1, 2021 – June 30, 2023
Compliance Requirement: Allowable Costs / Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance, 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:
Ten (10) of ten (10) payroll transactions in our statistically valid sample were supported by records which accurately reflected the work performed. However, such records did not include documented evidence of review and approval which would provide reasonable assurance that the charges were accurate, allowable, and properly allocated.
Questioned costs:
Below the reportable limit
Cause:
Procedures were not in place to ensure the payroll records were supported by the Town’s internal controls.
Effect:
Federal funds could be expended for unallowable activities and subject to disallowance.
Repeat Finding:
Yes, 2022-002
Recommendation:
We recommend procedures be implemented to ensure that the records supporting payroll charges to the federal grant program include documented evidence of review and approval.
Views of responsible officials:
The Hingham Public School's general weekly payroll is approved on a weekly basis by Management. In the case of our summer programs a similar control has been put in place by Management to ensure all payroll records are approved before processing.