Finding 1235971 (2025-003)

Finding 2025-003 – Special Education Cluster – AL No. 84.027 Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Criteria: Costs charged to the major programs should meet the requirements as set forth by Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles). Condition: During our test of controls over compliance it was noted that there are expenditures charged to the Special Education Cluster for expenses that are unallowable costs. Context: During our test of expenditures and review of the general ledger against the Special Education Cluster as it is related to compliance it was noted that the FY 23 Special Education IEP grant had an invoice charged to the grant for promotional clothing to the budget line as classroom supplies. The FY 2024 Special Education IEP grant had an expense that was not part of the approved grant agreement with the pass through entity. The FY 2025 Special Education IEP grant had 2 expenses that were not part of the approved grant agreement with the pass through entity. The FY 2025 Special Education Grants to States grant had five instances where the invoice charged to the grant was not in agreement with the pass through entity’s grant agreement. FY 2025 Special Education Grants to States grant had two expenses whose supporting documentation was a quote as the invoice was not received. Effect: Assabet Valley Regional Technical High School was not in compliance with the allowable costs/ cost principals requirement as set forth by the Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles). Questioned Costs: Total questioned costs for the FY 23 Special Education IEP $296.28, FY 2024 Special Education IEP $300.00, FY 2025 Special Education IEP $2,544.00, and FY 2025 Special Education Grants to States $5,862.14. Questioned costs were calculated based on actual invoice costs. Cause: Staff did not properly follow the grant agreement. Staff did not properly review payables to ensure that they were paying for an invoice rather than a quote.. Identification as a Repeat Finding: 2024-005 Recommendation: We recommend the Assabet Valley Regional Technical High School follow procedures to ensure that expenditures charged to the grants are allowable costs as set forth by Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles) Responsible for Corrective Plan: Director of Business Operations Estimated Completion Date: Changes are to go into effect immediately. Action Taken: Grant managers and Business Office staff will review purchases for grants to ensure only allowable expenses are paid. The Business Manager will review all warrants for accuracy ensuring invoices and not quotes are paid.