Finding 1235991 (2024-003)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2024
Accepted
2026-09-22
Audit: 411595
Organization: Town of Greenfield (MA)
Auditor: CBIZ CPAS PC

AI Summary

  • Core Issue: Inadequate internal controls led to missing documentation and unapproved invoices for federal program expenses.
  • Impacted Requirements: Compliance with federal guidelines requires all costs to be allowable, allocable, and supported by proper documentation.
  • Recommended Follow-Up: Strengthen internal controls by ensuring all expenses are documented and approved before payment, and regularly review vendor payment processes for compliance.

Finding Text

Federal Program(s) Information Federal Agency: U.S. Department of Treasury Award Name: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Year: 2024 Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Type of Finding Compliance Internal Controls over Compliance – Significant Deficiency Criteria or Specific Requirement Under Uniform Guidance (2 CFR § 200.403, 200.405), costs charged to federal programs must be allowable, allocable, and properly supported. Adequate documentation, such as approved invoices and supporting records, must be maintained for all charges to federal awards. Effective internal controls should ensure that all payments are authorized, reviewed, and retained in accordance with program requirements. Condition and Context During testing of 40 transactions for the Activities Allowed/Allowable Costs (A/B) compliance area one invoice that was less than $10,000 could not be provided and one invoice was not approved prior to payment. Cause The City did not consistently enforce internal controls requiring the retention of supporting documentation and formal approval of invoices prior to processing payments charged to the grant. Effect or Potential Effect Failure to maintain supporting documentation and to ensure invoices are properly approved increases the risk of unallowable or unsupported costs being charged to the federal program, and limits the City’s ability to demonstrate compliance with program requirements. Questioned Costs None reported. Prior Year Finding No Recommendation We recommend the City strengthen internal controls by ensuring all expenditures charged to federal programs are properly documented and approved prior to payment. Management should periodically review vendor payment processes to verify compliance with documentation and approval procedures.

Corrective Action Plan

Audit Finding Reference: 2024-003 Improve Internal Controls and Documentation over Vendor Transactions Planned Corrective Action: Management agrees with recommendation to strengthen internal controls by ensuring all expenditures charged to federal programs are properly documented and approved prior to payment and periodically review vendor payment processes to verify compliance with documentation and approval procedures. Management expects these recommendations to be fully implemented by the start of the next fiscal year. Planned Implementation Date of Corrective Action: July 1, 2026 Person Responsible for Corrective Action: School Superintendent, School Business Office and City Grants Management

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1235989 2024-002
    Material Weakness Repeat
  • 1235990 2024-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.555 NATIONAL SCHOOL LUNCH PROGRAM $786,759
14.228 COMMUNITY DEVELOPMENT BLOCK GRANTS/STATE'S PROGRAM AND NON-ENTITLEMENT GRANTS IN HAWAII $703,447
17.259 WIOA YOUTH ACTIVITIES $675,962
17.278 WIOA DISLOCATED WORKER FORMULA GRANTS $497,571
10.553 SCHOOL BREAKFAST PROGRAM $456,258
17.258 WIOA ADULT PROGRAM $349,161
21.027 COVID-19 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $289,107
10.559 SUMMER FOOD SERVICE PROGRAM FOR CHILDREN $237,959
17.225 UNEMPLOYMENT INSURANCE $169,768
97.039 HAZARD MITIGATION GRANT $160,546
16.710 PUBLIC SAFETY PARTNERSHIP AND COMMUNITY POLICING GRANTS $155,345
93.323 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $129,161
17.207 EMPLOYMENT SERVICE/WAGNER-PEYSER FUNDED ACTIVITIES $112,746
97.044 COVID-19 ASSISTANCE TO FIREFIGHTERS GRANT $66,212
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $62,800
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $49,137
97.042 EMERGENCY MANAGEMENT PERFORMANCE GRANTS $33,948
84.425 COVID-19 EDUCATION STABILIZATION FUND $17,700
17.801 JOBS FOR VETERANS STATE GRANTS $14,282
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $13,763
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $12,826
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $8,413
84.196 EDUCATION FOR HOMELESS CHILDREN AND YOUTH $8,200
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $4,051
66.920 SOLID WASTE INFRASTRUCTURE FOR RECYCLING INFRASTRUCTURE GRANTS $3,568
84.027 COVID-19 SPECIAL EDUCATION GRANTS TO STATES $896
17.245 TRADE ADJUSTMENT ASSISTANCE $696
84.027 SPECIAL EDUCATION GRANTS TO STATES $239