Finding 503842 (2022-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2024-10-28
Audit: 326126
Organization: City of Framingham (MA)

AI Summary

  • Core Issue: There is a significant weakness in internal controls over compliance related to procurement records for the Special Education Cluster program.
  • Impacted Requirements: The agency failed to maintain adequate records as required by 2 CFR section 200.318, leading to noncompliance with federal regulations.
  • Recommended Follow-Up: Strengthen procedures to ensure complete and accurate procurement records are maintained for all federal fund contracts.

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 • 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 (Finding 2021-002) 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

2022-002 Special Education Cluster - Assistance Listing Numbers 84.027, 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

Categories

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

Other Findings in this Audit

  • 503839 2022-001
    Material Weakness Repeat
  • 503840 2022-001
    Material Weakness Repeat
  • 503841 2022-001
    Material Weakness Repeat
  • 503843 2022-002
    Material Weakness Repeat
  • 503844 2022-002
    Material Weakness Repeat
  • 1080281 2022-001
    Material Weakness Repeat
  • 1080282 2022-001
    Material Weakness Repeat
  • 1080283 2022-001
    Material Weakness Repeat
  • 1080284 2022-002
    Material Weakness Repeat
  • 1080285 2022-002
    Material Weakness Repeat
  • 1080286 2022-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $10.96M
84.425 Education Stabilization Fund $7.53M
84.010 Title I Grants to Local Educational Agencies $1.93M
10.553 School Breakfast Program $1.03M
14.218 Community Development Block Grants/entitlement Grants $1.02M
84.002 Adult Education - Basic Grants to States $928,107
93.778 Medical Assistance Program $877,537
16.922 Equitable Sharing Program $732,771
21.019 Coronavirus Relief Fund $537,379
84.365 English Language Acquisition State Grants $472,411
84.287 Twenty-First Century Community Learning Centers $442,406
84.367 Improving Teacher Quality State Grants $196,757
10.555 National School Lunch Program $190,151
32.006 Covid-19 Telehealth Program $180,000
10.559 Summer Food Service Program for Children $108,132
84.424 Student Support and Academic Enrichment Program $104,996
84.048 Career and Technical Education -- Basic Grants to States $88,334
84.173 Special Education_preschool Grants $64,355
45.310 Grants to States $61,612
16.738 Edward Byrne Memorial Justice Assistance Grant Program $58,428
97.044 Assistance to Firefighters Grant $57,876
93.788 Opioid Str $51,439
84.196 Education for Homeless Children and Youth $45,000
66.818 Brownfields Assessment and Cleanup Cooperative Agreements $44,731
93.959 Block Grants for Prevention and Treatment of Substance Abuse $42,172
84.027 Special Education_grants to States $33,177
16.034 Coronavirus Emergency Supplemental Funding Program $30,986
14.239 Home Investment Partnerships Program $25,350
93.052 National Family Caregiver Support, Title Iii, Part E $11,500
93.103 Food and Drug Administration_research $10,944
97.042 Emergency Management Performance Grants $8,394
20.600 State and Community Highway Safety $5,807
16.607 Bulletproof Vest Partnership Program $5,565
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $4,923
93.074 Hospital Preparedness Program (hpp) and Public Health Emergency Preparedness (phep) Aligned Cooperative Agreements $1,837
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $1,336