Finding 1169707 (2025-001)

Finding 2025-001 This finding impacts the activities allowed and unallowed and allowable costs/cost principles compliance requirements for the major program, Assistance Listing Number 10.555, National School Lunch Program (Child Nutrition Cluster), funded by the U.S. Department of Agriculture and passed through DESE. Criteria: Per the Immigration Reform and Control Act of 1986, employers must complete Form I- 9 for each individual hired for employment in the United States. The form must be completed within three business days of the employee’s start date and retained in accordance with Federal regulations. The Internal Revenue Service requires all employees to submit a properly completed Form W-4 to ensure accurate income tax withholding. Condition: During the testing of twenty-five employee files, four instances were identified where Form I-9s were either missing and four separate instances where Form W-4s were missing. Cause: The Organization had turnover among management positions and other positions and the internal controls in place were not followed. Effect: Missing employment documentation may result in non-compliance with the OMB and DESE regulations, potentially subjecting the Organization to penalties or fines, including issues with charter renewal or funding, and increasing the risk of tax withholding errors. Questioned Costs: There were no questioned costs as a result of the material weakness. Was the finding a repeat of a finding in the immediately prior year?: No Recommendation: AAFCPAs recommends the Organization implement a standardized checklist and conduct periodic internal reviews of onboarding documentation to ensure all required forms are properly completed and retained in accordance with Federal regulations. Management’s Response: As of October 2025, the responsibility for onboarding new staff and collecting the required paperwork has shifted to new personnel. Codman management is conducting a thorough audit of all personnel files and will engage in ongoing, periodic personnel file audits as well to ensure compliance with collecting and maintaining necessary paperwork.