Finding Text
Federal agency: U.S. Department of Education
Federal program title: Special Education Cluster
Assistance Listing 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, 2021 – June 30, 2022
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Other Matters
Compliance Requirement: Suspension and Debarment
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states
that nonfederal entities are subject to the nonprocurement debarment and suspension regulations
implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards,
subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded
from or ineligible for participation in Federal assistance programs or activities.
Condition and Context: For the four vendors in our statistically valid sample, documentation was not
provided to support that the City verified the vendors were not debarred or suspended from
participation in Federal assistance programs or activities.
Questioned Costs: None
Cause: Procedures were not in place to document the verification that all vendors were not suspended
or debarred from participation in Federal assistance programs or activities.
Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’
debarment or suspension status could cause federal grant funds to be expended with vendors that are
excluded from participation in Federal assistance programs or activities.
Repeat Finding: Yes (Finding 2021-001)
Recommendation: We recommend procedures be implemented to document the verification that all
vendors are not suspended or debarred from participation in Federal assistance programs or activities.
Views of Responsible Officials: Management agrees with the finding.