Finding 1241207 (2024-003)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2026-10-26
Audit: 415304
Organization: Town of Carver (MA)
Auditor: CBIZ CPAS PC

AI Summary

  • Core Issue: The Town failed to submit its annual report on time and lacked proper internal controls for report preparation and review.
  • Impacted Requirements: Non-compliance with federal reporting deadlines and inadequate documentation for expenditure classifications as required by the U.S. Department of the Treasury.
  • Recommended Follow-up: Strengthen internal controls by ensuring timely report submissions, implementing independent review processes, and maintaining detailed accounting records for accurate reporting.

Finding Text

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: 2021 Compliance Requirement: Reporting Criteria or Specific Requirement Recipients of State and Local Fiscal Recovery Funds are required to submit complete and accurate program Project and Expenditure Reports by the deadlines established by the U.S. Department of the Treasury. In addition, recipients should maintain effective internal controls over the preparation and review of reports to ensure information reported is accurate, supported, and submitted timely, as required by 2 CFR §200.303. Adequate accounting records should also be maintained to identify and support expenditures reported as direct and pass-through activities. Condition: The Town did not submit its required annual report by the established due date. In addition, the Town did not maintain documented segregation of duties over the preparation and review of the report, as there was no evidence provided to show that the report had been independently reviewed prior to submission. During audit testing, management provided a general ledger detail intended to support amounts reported under the ARPA program. However, the ledger detail incorrectly classified expenditures between direct expenditures and pass-through expenditures. Although the audit team was able to reconcile and validate total program expenditures incurred during the fiscal year and appropriately classify those expenditures into the correct reporting categories for SEFA presentation, management was unable to provide a detailed ledger identifying the appropriate direct expenditures along with transaction dates. As a result, the audit team was unable to trace the direct expenditures reported to supporting accounting records containing the dates necessary to verify the accuracy and completeness of information included in the annual report. Context: The Town was required to submit the annual project and expenditure report for the period of April 1, 2023 to March 31, 2024 by April 30, 2024. This report was submitted on December 23, 2024. Cause: The Town's internal controls over ARPA reporting were not sufficiently designed or implemented to ensure: 1. Required reports were completed and submitted by established deadlines. 2. Reports were subject to documented independent review prior to submission. 3. Accounting records captured and maintained sufficient detail to support expenditure classifications and reporting information required by the U.S. Department of the Treasury. Effect or Potential Effect: Failure to submit required reports timely may result in noncompliance with federal reporting requirements and may limit the ability of federal agencies to monitor program performance and expenditures. Additionally, inadequate supporting records and the lack of independent review increase the risk that inaccurate or incomplete information could be reported to the federal government and remain undetected. Questioned Costs - None reported. Identification as a Repeat Finding - Not a repeat finding. Recommendation: The Town should strengthen its internal controls over ARPA reporting by: • Establishing procedures to ensure all required reports are prepared and submitted by applicable deadlines. • Implementing documented supervisory review procedures to provide appropriate segregation of duties between report preparation and approval. • Enhancing its accounting processes to accurately distinguish direct expenditures from passthrough expenditures and maintain detailed supporting records, including transaction dates, sufficient to support all amounts reported to the U.S. Department of the Treasury. • Retaining documentation demonstrating both the preparation and review of all required program reports. 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

Views of Responsible Officials The Town acknowledges the finding and notes that the issues identified relate to reporting activities performed during FY2024. During and following that period, the Town experienced substantial turnover among personnel responsible for grant administration, financial reporting, and ARPA compliance activities. Since the audit period, the Town has established improved oversight of federal grant compliance responsibilities and has assigned reporting responsibilities to designated staff. Procedures are being implemented to ensure that all federal reporting deadlines are identified and monitored, reports are reviewed by supervisory personnel prior to submission, and documentation supporting submitted reports is retained in a centralized manner.Additionally, the Town has improved its grant accounting and tracking procedures to better distinguish direct expenditures from pass-through expenditures and to maintain supporting documentation sufficient to support federal reporting requirements. Management believes these actions will significantly improve compliance with federal reporting standards going fonvard. Responsible Official: Finance Directorffown Accountant

Categories

Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1241206 2024-003
    Material Weakness Repeat
  • 1241208 2024-004
    Material Weakness Repeat
  • 1241209 2024-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 COVID-19 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $1.10M
10.555 NATIONAL SCHOOL LUNCH PROGRAM $82,334
84.027 SPECIAL EDUCATION GRANTS TO STATES $72,598
93.276 DRUG-FREE COMMUNITIES SUPPORT PROGRAM GRANTS $72,247
10.555 COVID-19 NATIONAL SCHOOL LUNCH PROGRAM $40,609
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $32,000
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $19,919
84.425 COVID-19 EDUCATION STABILIZATION FUND $11,299
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $10,552
97.042 EMERGENCY MANAGEMENT PERFORMANCE GRANTS $3,437
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $915