Finding Text
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Federal Award Identification Number and Year: H027A230076 (9/8/2023 – 9/30/2025), H027A240076 (9/10/2024 – 9/30/2026), FH027A230076 (11/3/2023 – 9/30/2024) Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-000558-2024-0700, 240-000558-2025-0700, 274-000662-2025-0700 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Qualified Opinion) Criteria or specific requirement: Under the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Part 200), specifically 2 CFR §200.430(i), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Additionally, the non-Federal entity is required to have written procedures and a system of internal controls to ensure that charges for compensation are accurate, allowable, and properly allocated to each applicable cost objective. Condition: For the year ended June 30, 2025, The District did not maintain adequate time and effort documentation to support payroll costs charged to the Special Education (SPED) program. Specifically, for a sample of employees whose compensation was partially or fully charged to SPED, required time and effort certifications were either missing, incomplete, or did not clearly support the allocation of time between SPED and non‑SPED activities. Questioned costs: $88,558 Context: During testing of payroll expenditures it was identified that the District was not able to provide the time and effort documentation required for SPED payroll expenditures. Cause: District procedures for monitoring and retaining time and effort documentation were not consistently implemented. In addition, management oversight procedures did not ensure that required certifications were completed timely, reviewed for accuracy, and retained in accordance with federal requirements. Effect: Without adequate time and effort documentation, the District is unable to demonstrate that payroll expenditures charged to the SPED program were allowable and allocable. This condition increases the risk that federal funds may have been charged for costs not properly supported or not benefiting the SPED program, resulting in noncompliance with federal grant requirements. Repeat Finding: No. Recommendation: Establish and formally document procedures to ensure time and effort documentation is completed in accordance with federal requirements. Require periodic review of procedures by management to verify accuracy and completeness. Ensure all time and effort documentation is properly retained and readily available for audit purposes. Provide training to applicable staff on federal time and effort documentation requirements for SPED programs. Views of responsible officials: There is no disagreement with the audit finding.