Findings Citing § 200.213

Federal agency: U.S. Department of Education Federal program title: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and Massachusetts Department of Early Education and Care Pass-Through Number(s): Various (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2021 – June 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 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: For the four vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes (Finding 2021-001) Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.

Federal agency: U.S. Department of Education Federal program title: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and Massachusetts Department of Early Education and Care Pass-Through Number(s): Various (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2021 – June 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 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: For the four vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes (Finding 2021-001) Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.

Criteria: Internal 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 be in compliance 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). Compliance: Per 2 CFR 200.213 Suspension and Debarment restricts 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: the County did not maintain documentation of a vendor’s suspension and debarment status. Cause: the County’s Procurement office was unaware of the suspension and debarment verification requirement for all federally funded procurements and subawards $25,000 or more. Questioned Costs: None Effect: Federal funds may be paid to parties that are ineligible to participate in a federal program. Recommendation: We recommend the County evaluate its policies procedures to ensure that suspension and debarment requirements are being met prior to entering into transactions with vendors. Identification of Repeat Finding: This is a first year finding. Views of Responsible Officials: management agrees with the finding.

Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: 2022 Award Period: Fiscal Year 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement 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 be in compliance 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). Compliance: 2 CFR 200.213 Suspension and Debarment restricts 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. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Condition The Town does not have policies and procedures in place to ensure that they do not contract with or make subawards to parties that are suspended or debarred. Questioned Costs None Context Although the Town does not have policies or procedures in place to ensure that they do not contract with or make subawards to parties that are suspended or debarred, we did not identify instances where Federal grant awards were paid to suspended or debarred vendors for 3 of 3 suspension and debarment transactions selected for testing. Cause Management was not aware of the requirements of 2 CFR section 180 within Uniform Guidance. Effect The Town is at risk for noncompliance with federal grants as it relates to suspension and debarment. Repeat Finding No Recommendation We recommend that the Town implement policies and procedures to ensure that potential vendors are not suspended or debarred prior to contracting with them ford goods or services. Views of Responsible Officials Management agrees with this finding.

2021-001 - Procurement, Suspension and Debarment (Significant Deficiency) Condition: During our testwork over procurement, we noted that there were no procurement policy and payments made to vendors before checking suspension or debarment status on www.sam.gov. Criteria: Uniform Grant Guidance and 2 CFR Part 200 Subpart C and D: §200.213 Suspension and debarment. Non-federal entities are subject to the non-procurement 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. Cause: DSAL did not establish adequate internal controls and procedures and procurement policy to ensure and maintain documentation to show that vendors were not suspended, debarred, or otherwise excluded from participating in contracts that are funded through Federal awards. Effect: DSAL is not in compliance with Federal regulations related to the grant and this could put its funding in jeopardy or require DSAL to reimburse the program for improper grant distributions. Auditor's Recommendation: We recommend that DSAL establish a policy and implement procedures to ensure the suspension or debarment status of vendors before entering into contract or transactions funded through Federal grants. Management Response: Management agrees with the findings and has provided the accompanying corrective action plan. Estimated Completion Date: November 20, 2022 Responsible Party: Patrick Eiser - DSAL Operations Director

Federal agency: U.S. Department of Education Federal program title: Special Education Cluster CFDA Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and Massachusetts Department of Early Education and Care Pass-Through Number(s): Various (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2020 – June 30, 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Noncompliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 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: For the one vendor in our statistically valid sample, documentation was not provided to support that the City verified the vendor was not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.

Federal agency: U.S. Department of Education Federal program title: Special Education Cluster CFDA Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and Massachusetts Department of Early Education and Care Pass-Through Number(s): Various (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2020 – June 30, 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Noncompliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 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: For the one vendor in our statistically valid sample, documentation was not provided to support that the City verified the vendor was not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.

Federal agency: U.S. Department of Education Federal program title: Special Education Cluster CFDA Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and Massachusetts Department of Early Education and Care Pass-Through Number(s): Various (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2020 – June 30, 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Noncompliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 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: For the one vendor in our statistically valid sample, documentation was not provided to support that the City verified the vendor was not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.

Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster CFDA Number: 10.555, 10.559 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 09-100 Award Period: July 1, 2020 – June 30, 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Noncompliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 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: For all five vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.

Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster CFDA Number: 10.555, 10.559 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 09-100 Award Period: July 1, 2020 – June 30, 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Noncompliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 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: For all five vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.

Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster CFDA Number: 10.555, 10.559 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 09-100 Award Period: July 1, 2020 – June 30, 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Noncompliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 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: For all five vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.

Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster CFDA Number: 10.555, 10.559 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 09-100 Award Period: July 1, 2020 – June 30, 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Noncompliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 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: For all five vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.

2021-001 - Procurement, Suspension and Debarment (Significant Deficiency) Condition: During our testwork over procurement, we noted that there were no procurement policy and payments made to vendors before checking suspension or debarment status on www.sam.gov. Criteria: Uniform Grant Guidance and 2 CFR Part 200 Subpart C and D: §200.213 Suspension and debarment. Non-federal entities are subject to the non-procurement 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. Cause: DSAL did not establish adequate internal controls and procedures and procurement policy to ensure and maintain documentation to show that vendors were not suspended, debarred, or otherwise excluded from participating in contracts that are funded through Federal awards. Effect: DSAL is not in compliance with Federal regulations related to the grant and this could put its funding in jeopardy or require DSAL to reimburse the program for improper grant distributions. Auditor's Recommendation: We recommend that DSAL establish a policy and implement procedures to ensure the suspension or debarment status of vendors before entering into contract or transactions funded through Federal grants. Management Response: Management agrees with the findings and has provided the accompanying corrective action plan. Estimated Completion Date: November 20, 2022 Responsible Party: Patrick Eiser - DSAL Operations Director

Federal agency: U.S. Department of Education Federal program title: Special Education Cluster CFDA Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and Massachusetts Department of Early Education and Care Pass-Through Number(s): Various (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2020 – June 30, 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Noncompliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 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: For the one vendor in our statistically valid sample, documentation was not provided to support that the City verified the vendor was not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.

Federal agency: U.S. Department of Education Federal program title: Special Education Cluster CFDA Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and Massachusetts Department of Early Education and Care Pass-Through Number(s): Various (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2020 – June 30, 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Noncompliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 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: For the one vendor in our statistically valid sample, documentation was not provided to support that the City verified the vendor was not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.

Federal agency: U.S. Department of Education Federal program title: Special Education Cluster CFDA Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and Massachusetts Department of Early Education and Care Pass-Through Number(s): Various (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2020 – June 30, 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Noncompliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 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: For the one vendor in our statistically valid sample, documentation was not provided to support that the City verified the vendor was not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.

Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster CFDA Number: 10.555, 10.559 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 09-100 Award Period: July 1, 2020 – June 30, 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Noncompliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 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: For all five vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.

Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster CFDA Number: 10.555, 10.559 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 09-100 Award Period: July 1, 2020 – June 30, 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Noncompliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 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: For all five vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.

Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster CFDA Number: 10.555, 10.559 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 09-100 Award Period: July 1, 2020 – June 30, 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Noncompliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 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: For all five vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.

Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster CFDA Number: 10.555, 10.559 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 09-100 Award Period: July 1, 2020 – June 30, 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Noncompliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 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: For all five vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.