Finding 1208843 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-04-27
Audit: 399773
Organization: Town of Westford (MA)

AI Summary

  • Core Issue: A significant deficiency in internal controls was found regarding vendor verification for suspension and debarment compliance.
  • Impacted Requirements: Compliance with 2 CFR Part 200.214 is necessary to ensure that federal funds are not awarded to ineligible vendors.
  • Recommended Follow-Up: Strengthen procedures to document the timing of vendor verification before transactions are executed.

Finding Text

2025-001 Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Assistance Listing Number: 21.027 Federal Award Identification Number: Not available Pass-Through Agency: Massachusetts Department of Revenue Pass-Through Number(s): ARPA#2FUNDS0330 Award Period: July 1, 2024 – June 30, 2025 Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters 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. Condition and Context: For one (1) of five (5) transactions tested, the Town had a documented verification that the vendor was not suspended or debarred. However, the verification was not dated/time-stamped. Therefore, we could not determine if the verification occurred prior to entering into transaction with the vendor. Questioned Costs: None. Cause: Procedures were not in place to document the timing of the verification that all vendors were not suspended or debarred from participation in federal programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification (or untimely verification) of vendors’ suspension or debarment status could cause federal grant funds to be expended to vendors that are excluded from participation in federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend procedures be strengthened to ensure that the timing of the verification of vendors’ suspension and debarment status is documented prior to executing transactions. Views of responsible officials and planned corrective actions: Management agrees with the finding.

Corrective Action Plan

2025-001 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) – 21.027 Recommendation: We recommend procedures be strengthened to ensure that documentation of verification of vendors’ suspension and debarment status is obtained prior to executing transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District has begun strengthening its procurement and accounts payable procedures to ensure vendor suspension and debarment verification is completed and documented before any contract is executed or transaction is processed with federal funds. Going forward, staff will verify vendor eligibility through SAM.gov or other required sources, retain evidence of the verification in the contract or procurement file, and use a standardized checklist to document compliance. The District will also review internal procedures with relevant staff and reinforce this requirement for all applicable federally funded purchases and contracts. Name(s) of the contact person(s) responsible for corrective action: Director of Finance, in coordination with Superintendent and Assistant Superintendent’s Office. Planned completion date for corrective action plan: April 30, 2026

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1208844 2025-002
    Material Weakness Repeat
  • 1208845 2025-002
    Material Weakness Repeat
  • 1208846 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $2.22M
10.555 NATIONAL SCHOOL LUNCH PROGRAM $234,936
10.553 SCHOOL BREAKFAST PROGRAM $68,343
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $57,840
93.008 MEDICAL RESERVE CORPS SMALL GRANT PROGRAM $46,436
66.818 BROWNFIELDS MULTIPURPOSE, ASSESSMENT, REVOLVING LOAN FUND, AND CLEANUP COOPERATIVE AGREEMENTS $45,175
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $41,740
93.069 PUBLIC HEALTH EMERGENCY PREPAREDNESS $33,550
97.044 ASSISTANCE TO FIREFIGHTERS GRANT $20,683
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $20,281
84.027 SPECIAL EDUCATION GRANTS TO STATES $18,010
16.607 BULLETPROOF VEST PARTNERSHIP PROGRAM $17,950
16.922 EQUITABLE SHARING PROGRAM $17,215
84.365 ENGLISH LANGUAGE ACQUISITION STATE GRANTS $17,012
16.585 TREATMENT COURT DISCRETIONARY GRANT PROGRAM $14,062
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $13,842
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $9,440
93.103 FOOD AND DRUG ADMINISTRATION RESEARCH $2,727