Finding 1235841 (2025-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-09-21
Audit: 411445
Organization: Town of Wayland (MA)
Auditor: CBIZ CPAS PC

AI Summary

  • Core Issue: The School Department failed to document the justification for using a sole source procurement method, violating federal requirements.
  • Impacted Requirements: Compliance with 2 CFR 200.318 and 200.320, which mandate proper documentation and justification for procurement decisions.
  • Recommended Follow-Up: Establish formal procedures for sole source procurements, implement a review process for documentation, and train staff on federal procurement guidelines.

Finding Text

2025-003 Improve Controls Over Special Education Procurement Federal Agency: U.S. Department of Education Program: Special Education Grants to States AL Number: 84.027/84.173 Award Year: 2025 Type of Finding Compliance – Procurement Internal Control over Compliance – Procurement – Significant Deficiency Criteria or Specific Requirement Under 2 CFR 200.318 and 200.320, non-federal entities are required to maintain adequate documentation supporting procurement decisions, including the method of procurement used; and justify and document the use of noncompetitive (sole source) procurement, including the reasons why competition was not feasible. Specifically, 2 CFR 200.320(c) permits noncompetitive procurement only under limited circumstances and requires proper justification and documentation. Condition and Context During testing of procurement transactions charged to the Special Education Grants to States program, we identified one instance in which the School Department utilized a sole source procurement method; however, no documentation was maintained to support or justify the determination that the vendor qualified as a sole source provider, in accordance with 2 CFR 200.320(c). Cause The School Department does not have sufficient internal controls in place to ensure that sole source determinations are appropriately evaluated and documented against Uniform Guidance criteria. Effect or Potential Effect The lack of documentation supporting sole source procurement increases the risk that procurement may not comply with federal requirements, competitive procurement processes may be inappropriately bypassed; and federal funds may not be used in a manner that ensures full and open competition. Questioned Costs No evidence of improper payment or unallowable costs was identified; therefore, no questioned costs are reported. Recommendation We recommend that the School Department develop and implement formal procedures requiring written justification for all sole source procurements. Ensure documentation clearly addresses the criteria under 2 CFR 200.320(c). Implement a review process to verify that procurement files include all required documentation prior to payment, and provide training to relevant personnel on federal procurement requirements under Uniform Guidance. Views of Responsible Official and Planned Corrective Action Management’s corrective action plan is included at the end of this report.

Corrective Action Plan

Audit Finding Reference: 2025-003 Special Education Planned Corrective Action: For all special education procurements, a formal sole source justification statement will be documented and retained with the purchase records. Planned Implementation Date of Corrective Action: School year 2026-2027 Persons Responsible for Corrective Action: Ronnie Kessler, Director of Student Services Director Kirsteen Patterson, Director of Finance and Operations

Categories

Procurement, Suspension & Debarment Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1235839 2025-001
    Material Weakness Repeat
  • 1235840 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $1.88M
84.027 SPECIAL EDUCATION GRANTS TO STATES $324,294
10.555 NATIONAL SCHOOL LUNCH PROGRAM $149,889
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $37,320
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $16,847
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $14,456
84.365 ENGLISH LANGUAGE ACQUISITION STATE GRANTS $12,569
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $8,297
97.042 EMERGENCY MANAGEMENT PERFORMANCE GRANTS $2,464
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $2,250
84.425 EDUCATION STABILIZATION FUND $1,558