Finding Text
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 Elementary and Secondary Education
Pass-Through Number(s): 240-542976-2022-0308, 240-689599-2023-0308, 240-000558-2024-0308,
252-546624-2022-0308, 274-000662-2024-0308, 262-689600-2023-0308, 262-000559-2024-0308, and
264-547238-2022-0308
Award Period: July 1, 2023 - June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The City of Waltham, Massachusetts should have internal controls designed to ensure compliance with those provisions.
Condition: Internal controls were not in place to ensure suspension and debarment checks were being performed prior to entering into a contract.
Questioned costs: None
Context: For 1 instance of the 3 contracts tested, a suspension and debarment check was not performed, for 1 instance out if the 3 contracts tested, a suspension and debarment check has not been performed during the current grant year, and for 1 instance, a suspension and debarment check was performed after expenses had already occurred.
Cause: Procedures are not in place to ensure all vendors are checked to ensure they are not suspended or debarred prior to entering into a contract with a vendor. In addition, for transactions which are originally not expected to be funded with federal funds and later transferred did not meet federal suspension and debarment standards.
Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance.
Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-003.
Recommendation: We recommend that management implement procedures to ensure that vendors are checked to ensure that they are not suspended or debarred prior to entering into a contract with a vendor and that expenses transferred to a federal grant have met the federal suspension and debarment standards.
Views of responsible officials: There is no disagreement with the audit finding.