CORRECTIVE ACTION PLAN
Oversight Agency for Audit: U.S. Department of Education
The Nauset Regional School District respectfully submits the following corrective action plan for the year ended
June 30, 2023.
Name and address of independent public accounting firm:
Powers & Sullivan, LLC
Audit period:...
CORRECTIVE ACTION PLAN
Oversight Agency for Audit: U.S. Department of Education
The Nauset Regional School District respectfully submits the following corrective action plan for the year ended
June 30, 2023.
Name and address of independent public accounting firm:
Powers & Sullivan, LLC
Audit period: July 1, 2022 through June 30, 2023
The finding from the June 30, 2023, schedule of findings and questioned costs is discussed below. The finding is
numbered consistently with the number assigned in the schedule.
FINDINGS—FEDERAL AWARD PROGRAMS AUDITS
U.S. DEPARTMENT OF EDUCATION
Passed through the Massachusetts Department of Elementary and Secondary Education
Special Education Cluster
Special Education Grants to States – Federal Assistance Listing Number 84.027
Special Education Preschool Grants – Federal Assistance Listing Number 84.173
COVID-19 Education Stabilization Fund
COVID-19 Education Stabilization Fund – Federal Assistance Listing Numbers, 84.425D and 84.425U.
2023-001: Controls for Monitoring Payroll Charged to the Grants
Compliance Requirement: Allowable Costs/Cost Principles
Type of Finding: Compliance and 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.
Condition: Management has established written guidelines and policies outlining the time and effort reporting
and documentation requirements that department heads must adhere with to ensure compliance with federal
and state time and effort reporting requirements. Such guidelines and policies indicate under what
circumstances semi-annual certifications and personnel activity reports (PARS) or time and effort reports are
required and when this information must be provided to the school business office. These guidelines and
policies were not fully adhered to. Out of a sample of 25 employees selected for testing in relation to the
Special Education Cluster, the District was unable to provide time and effort support for 8 selections. Out of a
sample of 10 employees selected for testing in relation to the COVID-19 Education Stabilization Fund, the
District was unable to provide time and effort support for any of the 10 selections.
Context: Payroll expenditures charged to the programs are required to be supported with documentation
substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates
to time spent accomplishing grant objectives. This supporting documentation should be standardized and
should include all required elements in accordance with Title 2 U.S. Code of Federal Regulations Part 225
Cost Principals for State, Local, and Indian Tribal Governments.
The District did not have an adequate system of internal controls in place to provide sufficient documentation
to demonstrate compliance with federal and state time and effort reporting requirements in accordance with
the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and
Indian Tribal Governments.
Effect: The District has not complied with the federal and state time and effort reporting requirements.
Cause: Lack of procedures in place to ensure compliance with time and effort reporting requirements.
Questioned Costs: Total payroll charged to the Special Education Cluster in 2023 totaled $540,875. Three of
the pay periods were selected for testing, which totaled $63,460 for 25 employees paid out of the grant during
those pay periods. From the pay periods selected for testing, $12,616 could not be substantiated through time
and effort reports or any similar internal control process. Total payroll charged to the COVID-19 Education
Stabilization Fund in 2023 totaled $709,331. 10 employees for three separate pay periods were selected for
testing, which totaled $24,894. From the employees and pay periods selected for testing, $24,894 could not
be substantiated through time and effort reports or any similar control process.
Repeat Finding: This matter was reported as a finding in the previous year as a finding 2022-001.
Recommendation: Management should establish procedures to ensure compliance with District guidelines
and policies regarding time and effort reporting and documentation requirements that department heads must
adhere with to ensure compliance with federal and state time and effort reporting requirements. Such
procedures should indicate under what circumstances semi-annual certifications and personnel activity
reports (PARS) or time and effort reports are required and when this information must be provided to the
school business office. Management should also implement proper training to ensure that the program
managers fully understand the time and effort reporting requirements.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will
establish procedures to ensure compliance with guidelines and policies outlining the time and effort reporting
and documentation requirements that department heads must adhere with to ensure compliance with federal
and state time and effort reporting requirements. Management will also implement proper training to ensure
that the program managers fully understand the time and effort reporting requirements. Management intends
to implement these procedures in fiscal 2024.
If the Oversight Agency has questions regarding this plan, please call Giovanna Venditti, Director of Finance and
Operations of Nauset Regional School District at 508-255-8800.
Sincerely yours,
Giovanna Venditti
Director of Finance and Operations
Nauset Regional School District