Finding 1061844 (2023-001)

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Revenue Pass-Through Number: MA DESE Codes 240, 252, 262, 264 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance Compliance Requirement: Suspension and Debarment 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. Nonfederal entities must verify that contracts with certain parties are not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For the 1 vendor in our testing sample, the Town did not document verification that the vendor was not suspended or debarred from participation in Federal assistance programs or activities. The vendor in our audit sample was not suspended or debarred. 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 the Town enhance procedures and controls to ensure verifications of suspension and debarment statuses are obtained and documented prior to executing transactions with vendors. Views of Responsible Officials: Management agrees with the finding.