Finding 1238632 (2025-001)

Material Weakness Repeat Finding
Requirement
ABCEFGHIJLMNP
Questioned Costs
-
Year
2025
Accepted
2026-09-30
Audit: 413551
Organization: Town of Pelham (NH)
Auditor: CBIZ CPAS PC

AI Summary

  • Core Issue: The Town lacks formal written policies and procedures for managing federal awards, violating OMB’s Uniform Guidance.
  • Impacted Requirements: Key areas needing documentation include cash management, allowable costs, employee travel, procurement, conflicts of interest, and subrecipient monitoring.
  • Recommended Follow-Up: The Town should prioritize creating and adopting these policies to ensure compliance with federal requirements.

Finding Text

2025-001 Document Policies and Procedures Over Federal Awards Federal Program(s) Information Federal Agency: All Award Name: All Assistance Listing Number: All Award Year: All Compliance Requirement: All Type of Finding Compliance Internal Control Over Compliance – Significant Deficiency Criteria or Specific Requirement OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“UG”) established requirements related to federal awards. The requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following: • Cash management • Determination of allowable costs • Employee travel • Procurement • Conflicts of interest • Subrecipient monitoring and management Condition and Context The Town has not formalized written policies and procedures related to federal awards as required under Uniform Guidance. Cause The Town has not developed written formal documentation of policies and procedures relative to grant federal requirements. Effect or Potential Effect There is a lack of formal documentation of policies and procedures related to federal awards as required by the Uniform Guidance. Questioned Costs None. Identification as a Repeat Finding This is a repeat of finding 2024-001. Recommendation The Town should ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with Uniform Guidance. Views of Responsible Official Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

Corrective Action Plan

During fiscal year 2025 the Town had not yet consolidated all federally required grant administration practices and procedures into a comprehensive written federal grant policy. The Town did, however, maintain policies and procedures applicable to grant-funded activities, including a Procurement Policy effective January 1, 2025 that applied regardless of funding source and addressed grant-funded purchases, procurement, conflicts of interest, record retention, and compliance with grant-specific requirements. The Town was first formally advised of the need for additional comprehensive written federal grant policies and procedures in connection with the audit of its 2024 federal awards, which was conducted in late 2025. Once the finding was communicated, management responded as soon as practicable by developing a comprehensive Grants, Donations & Fundraising Policy incorporating the requirements of 2 CFR Part 200. The policy was adopted by the Board of Selectmen on March 31, 2026 and became effective April 1, 2026. Corrective action has been completed through adoption and implementation of this policy. Management also notes that the 2025 audit reported no questioned costs associated with this finding, identified no material weaknesses in internal control over the major federal program, and resulted in an unmodified opinion that the Town complied, in all material respects, with the applicable compliance requirements. Planned Implementation Date of Corrective Action: Occurred on April 1, 2026 Person Responsible for Corrective Action: Tammy Penny, Finance Direct & Assistant Town Administrator

Categories

Subrecipient Monitoring Allowable Costs / Cost Principles Procurement, Suspension & Debarment Cash Management Significant Deficiency

Other Findings in this Audit

  • 1238631 2025-001
    Material Weakness Repeat
  • 1238633 2025-002
    Material Weakness Repeat
  • 1238634 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
20.205 HIGHWAY PLANNING AND CONSTRUCTION $136,719
16.543 MISSING CHILDREN'S ASSISTANCE $9,370
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $5,050
16.922 EQUITABLE SHARING PROGRAM $3,500