Finding 1236000 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-09-22
Audit: 411608
Organization: Town of Rockland (MA)
Auditor: CBIZ CPAS PC

AI Summary

  • Core Issue: A contract under the Drinking Water State Revolving Fund lacked required federal provisions, risking noncompliance.
  • Impacted Requirements: Compliance with Uniform Guidance (2 CFR § 200) was not met, specifically regarding contract clauses for federal awards.
  • Recommended Follow-Up: Improve procurement procedures to ensure all federal provisions are included in contracts and implement regular reviews of templates and checklists.

Finding Text

Federal Agency: Environmental Protection Agency Award Name: Drinking Water State Revolving Fund Assistance Listing Number: 66.468 Award Year: 2022 Compliance Requirement: Procurement Type of Finding : Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement Per Uniform Guidance (2 CFR § 200.327 and 2 CFR Part 200, Appendix II), all contracts made by non-federal entities under federal awards must contain specific provisions as applicable, such as those for equal employment opportunity, Davis-Bacon, termination for cause, compliance with laws and regulations, and others. These provisions are required to ensure compliance with federal program requirements for procurement. Condition and Context During testing of one contract for the program, we noted that the selected contract did not contain all the required provisions outlined in Appendix II to 2 CFR Part 200. While services were otherwise procured appropriately, documentation of the required contract clauses was not in accordance with the Uniform Guidance, particularly as it relates to the Contract Work Hours and Safety Standards Act and the Clean Air Act and the Federal Water Pollution Control Act. Cause The Town’s procurement processes did not include sufficient controls to ensure that all federally required contract provisions were incorporated into every contract funded with federal awards. Effect or Potential Effect Lack of inclusion of all required federal contract provisions increases the risk of noncompliance with Uniform Guidance and could lead to disputes or enforcement issues if regulatory or compliance matters arise. No questioned costs were identified, as the services procured were determined to be allowable and otherwise appropriate. Recommendation The Town should enhance its procurement procedures to ensure all contracts funded by federal awards include every provision required by Appendix II to 2 CFR Part 200 as applicable. Regular review of contract templates and procurement checklists should be implemented to support compliance. View of Responsible Officials Management’s corrective action plan is included at the end of this report.

Corrective Action Plan

The town will update policies and procedures so that all contracts going forward will have the provisions outline in Appendex II to 2 CFR Part 200 and make sure that the documentation of the required contract clauses is in accordance with the Uniform Guidance, particularly as it relastes to Contract Work Hours and Safety Standards Act and the Clean Air Act and the Federal Water Pollution Control Act. Planned Impletmentation Date of Corrective Action: 9/16/26

Categories

Procurement, Suspension & Debarment Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Special Tests & Provisions

Programs in Audit

ALN Program Name Expenditures
66.458 CLEAN WATER STATE REVOLVING FUND $2.55M
10.555 NATIONAL SCHOOL LUNCH PROGRAM $1.05M
84.027 SPECIAL EDUCATION GRANTS TO STATES $450,042
21.027 COVID-19 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $403,365
14.248 COMMUNITY DEVELOPMENT BLOCK GRANTS SECTION 108 LOAN GUARANTEES $391,118
10.553 SCHOOL BREAKFAST PROGRAM $254,695
14.228 COMMUNITY DEVELOPMENT BLOCK GRANTS/STATE'S PROGRAM AND NON-ENTITLEMENT GRANTS IN HAWAII $250,360
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $179,878
93.967 CENTERS FOR DISEASE CONTROL AND PREVENTION COLLABORATION WITH ACADEMIA TO STRENGTHEN PUBLIC HEALTH $133,333
10.559 SUMMER FOOD SERVICE PROGRAM FOR CHILDREN $107,152
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $89,439
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $30,465
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $29,033
84.425 COVID-19 EDUCATION STABILIZATION FUND $23,987
97.042 EMERGENCY MANAGEMENT PERFORMANCE GRANTS $10,242
16.607 BULLETPROOF VEST PARTNERSHIP PROGRAM $8,990
97.044 ASSISTANCE TO FIREFIGHTERS GRANT $6,085
97.067 HOMELAND SECURITY GRANT PROGRAM $5,405
84.365 ENGLISH LANGUAGE ACQUISITION STATE GRANTS $4,269
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $1,049