Finding 2024-004 – Special Education Cluster – AL No. 84.027 Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Criteria: Grantees must provide reasonable assurance that federal awards are expended only for allowable activities and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Management of the School is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition: Control deficiencies related to disbursements were noted as a result of the testing of internal controls over payroll. Specifically, a sample of payroll disbursements charged to the major program were tested in order to determine if adequate internal controls were in place. As a result of the testing of payroll disbursements charged to the program, the employees tested were for pay periods outside the period of performance and were found to not have time and effort certifications for the pay periods tested. Cause: We did not have a full-time payroll staff member or a grant manager. Context: During our test of payroll transactions charged to the Special Education Cluster it was noted that Payroll transactions were charged to the FY 24 Special Education PL94-142 grant were for services prior to the grant start date of 8/28/23 in the amount of $24,196.32. Additionally, the same payroll transactions were not supported with Time and Effort certifications for payroll charged to the FY 24 Special Education PL94-142. Effect or Potential Effect: Due to the material weakness and noncompliance in internal controls noted above, there is a risk of unallowable expenditures being charged to the federal grant. Identification as a Repeat Finding: This is not a repeat finding. Questioned Costs: Total questioned costs for the payroll charged to the grant that was outside the period of performance and not supported with Time and Effort certifications totaled $24,196.32. Recommendation: The Assabet Valley Regional Technical High School should improve the internal controls over Allowable Costs by ensuring employee’s payroll charged to the federal grant is within the period of performance and supported with Time and Effort certifications. Responsible for Corrective Plan: Sabrina Howley Estimated Completion Date: 11/5/25, Ongoing Action Taken: In June 2023 Assabet’s staff member handling grants retired. They only came in once a week to help with grants until new staff could be hired. In October of 2023 our current grant manager was hired and had very limited training on grants before the retiree quit fully in January 2024. Also at the same time we had no trained payroll staff to verify the salaries where paid out of the correct account line. We are double checking that the staff is paid correctly and not before a grant begins or ends. Also all staff will have signed a time and effort sheet for any pay periods they are paid out of grants.