Finding 1169708 (2025-002)

Finding 2025-002 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: The Organization is required to have a clearly outlined and signed employment agreement for each employee hired. Condition: During the testing of twenty-five employee files, seven instances were identified where no employment agreement was present for the 2024-2025 school year. 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. 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.