Finding 503832 (2021-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2021
Accepted
2024-10-28
Audit: 326125
Organization: City of Framingham (MA)

AI Summary

  • Core Issue: There is a material weakness in internal controls and noncompliance related to procurement records for the Special Education Cluster program.
  • Impacted Requirements: Compliance with 2 CFR section 200.318 is lacking, as records detailing procurement history were not maintained for all contracts tested.
  • Recommended Follow-Up: Strengthen procedures to ensure proper record-keeping for all procurement activities involving federal funds.

Finding Text

Federal agency: U.S. Department of Education Federal program title: Special Education Cluster CFDA Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and Massachusetts Department of Early Education and Care Pass-Through Number(s): Various (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2020 – June 30, 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Compliance Requirement: Procurement Criteria or Specific Requirement: 2 CFR section 200.318, part (i) requires that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition and Context: For all five contracts selected for testing, records sufficient to detail the history of procurement were not maintained. The sample was a statistically valid sample. Questioned Costs: Cannot be determined Cause: Procedures to maintain records sufficient to detail the history of all procurements related to federal funds needs to be strengthened. Effect: Noncompliance with the federal program occurred. Repeat Finding: Yes Recommendation: We recommend procedures to maintain records sufficient to detail the history of all procurements be strengthened. Views of Responsible Officials: Management agrees with the finding.

Corrective Action Plan

2021-002 Special Education Cluster - CFDA No. 84.027 and 84.173 Recommendation: We recommend procedures to maintain records sufficient to detail the history of all procurements be strengthened. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As of 7/1/2022, Framingham Public Schools will no longer claim the Massachusetts Chapter 30B SPED exemption (Appendix A. #8 & #22) for any SPED contracts being paid with federal funds. Instead, these contracts will be subject to the standard Chapter 30B procurement policies. FPS Executive Director of Finance and Operations, Lincoln Lynch IV, will meet with Director of SPED, Laura Spear, and City of Framingham Chief Procurement Officer, Jennifer Pratt, to make them aware of this finding and request that 1) all SPED grant funded contracts going forward will follow standard Chapter 30-B procurement policies and 2) City of Framingham updates their accounting procedures/procurement policies to reflect this change by 7/1/2022. Name(s) of the contact person(s) responsible for corrective action: Lincoln Lynch, IV - Executive Director of Finance and Operations Framingham Public Schools Planned completion date for corrective action plan: In progress with a start date of 7/1/2022.

Categories

Procurement, Suspension & Debarment Material Weakness Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 503829 2021-001
    Material Weakness Repeat
  • 503830 2021-001
    Material Weakness Repeat
  • 503831 2021-001
    Material Weakness Repeat
  • 503833 2021-002
    Material Weakness Repeat
  • 503834 2021-002
    Material Weakness Repeat
  • 503835 2021-003
    Material Weakness
  • 503836 2021-003
    Material Weakness
  • 503837 2021-003
    Material Weakness
  • 503838 2021-003
    Material Weakness
  • 1080271 2021-001
    Material Weakness Repeat
  • 1080272 2021-001
    Material Weakness Repeat
  • 1080273 2021-001
    Material Weakness Repeat
  • 1080274 2021-002
    Material Weakness Repeat
  • 1080275 2021-002
    Material Weakness Repeat
  • 1080276 2021-002
    Material Weakness Repeat
  • 1080277 2021-003
    Material Weakness
  • 1080278 2021-003
    Material Weakness
  • 1080279 2021-003
    Material Weakness
  • 1080280 2021-003
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund $2.79M
84.010 Title I Grants to Local Educational Agencies $1.90M
14.218 Community Development Block Grants/entitlement Grants $1.04M
93.778 Medical Assistance Program $623,637
84.365 English Language Acquisition State Grants $559,712
84.002 Adult Education - Basic Grants to States $319,843
84.367 Improving Teacher Quality State Grants $250,816
84.424 Student Support and Academic Enrichment Program $216,884
16.922 Equitable Sharing Program $212,615
21.019 Coronavirus Relief Fund $180,851
84.287 Twenty-First Century Community Learning Centers $174,365
10.559 Summer Food Service Program for Children $144,766
10.555 National School Lunch Program $98,497
93.069 Public Health Emergency Preparedness $62,812
84.048 Career and Technical Education -- Basic Grants to States $61,965
84.173 Special Education_preschool Grants $59,428
97.039 Hazard Mitigation Grant $59,230
66.818 Brownfields Assessment and Cleanup Cooperative Agreements $55,617
97.042 Emergency Management Performance Grants $50,519
84.196 Education for Homeless Children and Youth $47,021
84.027 Special Education_grants to States $34,695
93.959 Block Grants for Prevention and Treatment of Substance Abuse $27,492
97.044 Assistance to Firefighters Grant $22,002
16.034 Coronavirus Emergency Supplemental Funding Program $20,448
20.600 State and Community Highway Safety $20,034
14.239 Home Investment Partnerships Program $13,160
93.052 National Family Caregiver Support, Title Iii, Part E $8,108
16.607 Bulletproof Vest Partnership Program $5,845
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $5,077
97.067 Homeland Security Grant Program $3,714
45.310 Grants to States $2,590