Finding 1241255 (2025-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-10-28
Audit: 415373
Organization: Town of Marlborough (CT)

AI Summary

  • Core Issue: The Town of Marlborough lacks adequate internal controls to verify that vendors are not suspended or debarred before engaging in contracts.
  • Impacted Requirements: Compliance with 2 CFR Part 200 is necessary to ensure federal funds are not awarded to ineligible entities.
  • Recommended Follow-Up: Implement a review process to check the status of contractors against suspension and debarment lists to prevent future compliance issues.

Finding Text

Federal Agency: U.S. Department of Treasury Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number: SLFRP0128 Pass-Through Agency: State of Connecticut Office of Policy and Management Pass-Through Number(s): 12060-OPM20600-29669 Award Period: March 3, 2021, through December 31, 2026 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of suspension, and debarment. The Town of Marlborough, Connecticut (the Town) should have internal controls designed to ensure compliance with those provisions. Condition: During our testing, we noted the Town did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Context: During our testing, it was noted that the Town does not have a policy for verification that an entity with which the Town plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Cause: The Town was unaware the contractors were not being reviewed to ensure they were not suspended or debarred. Effect: There were no instances found that a suspended or debarred entity was paid with federal awards; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: Yes, previously reported as Finding 2024-002. Recommendation: We recommend the Town design controls to ensure an adequate review process is in place to review potential contractors to determine whether they are not suspended or debarred. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Suspension and Debarment over COVID-19 America Rescue Plan Act Recommendation: We recommend that the Town design controls to ensure an adequate review process in place to review potential contractors to determine they are not suspended or debarred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Town has developed a procedure to review the System for Award Management (SAM) before engaging with a contractor in a project that uses federal funds including funds from the America Rescue Plan Act. A written process will be prepared to record and maintain appropriate documentation. Name of the contact person responsible for corrective action: Finance Director and Town Planner Planned completion date for corrective action plan: Since this report is overdue, the estimated date is before the start of the FY 26 audit.

Categories

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
20.513 ENHANCED MOBILITY OF SENIORS AND INDIVIDUALS WITH DISABILITIES $60,152
10.555 NATIONAL SCHOOL LUNCH PROGRAM $48,591
84.358 RURAL EDUCATION $44,915
84.425 EDUCATION STABILIZATION FUND $35,469
84.027 SPECIAL EDUCATION GRANTS TO STATES $29,838
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $28,595
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $10,000
10.553 SCHOOL BREAKFAST PROGRAM $8,608
20.205 HIGHWAY PLANNING AND CONSTRUCTION $6,750
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $5,091
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $3,912
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $1,372