Finding 521096 (2023-009)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2025-02-03
Audit: 341024
Organization: City of Medford (MA)

AI Summary

  • Core Issue: Internal controls over compliance were inadequate, leading to missed checks on vendor suspension and debarment.
  • Impacted Requirements: Compliance with 2 CFR section 200.214, which prohibits contracts with suspended or debarred parties.
  • Recommended Follow-Up: Implement procedures to ensure all contractors are verified as eligible for federal awards before engagement.

Finding Text

2023-009 U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X & 84.173X Significant Deficiency in Internal Controls Over Compliance Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Suspension and debarment compliance was not verified for two covered transactions. Cause: Lack of appropriate oversight resulted in required debarment checks not being performed or the appropriate certifications signed by the vendors. Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. The two vendors were ultimately verified as not being suspended or debarred from participating in federal awards. Questioned Costs: None Repeat Finding from Prior Year: No. Recommendation: The City should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred. Views of Responsible Official: Management agrees with the finding.

Corrective Action Plan

Condition: Suspension and debarment compliance was not verified for two covered transactions. Corrective Action Planned: All Purchase Order requests that are associated with a federal government grant will all have an attached list showing the company is not on the debarment list. We will also update our School Contract language to include specific wording where the Vendor acknowledges the law and forfeits the contract if they are on the debarment list after the contract has been signed. A statement will be added to the contracts that states the following: ‘The Contractor (or use the term in the contract that identifies the vendor instead of Contractor) certifies under the pains and penalties of perjury, that the Contractor is not currently debarred or suspended by the Federal government, or any of its agencies, entities or subdivisions, nor is the Contractor currently debarred or suspended by the Commonwealth Massachusetts or any of its agencies, entities or subdivisions.’ If there is a section in the contract where the vendor certifies to other conditions (i.e. state taxes paid), then this language could be included under that section as another certification requirement. A Google Drive has been created to upload all supporting documents on a yearly basis. Anticipated Completion Date: 2/17/2025 Contact: Noel Velez, Director of Finance and Fiona Maxwell, Procurement Director

Categories

Procurement, Suspension & Debarment Internal Control / Segregation of Duties Subrecipient Monitoring Significant Deficiency

Other Findings in this Audit

  • 521082 2023-004
    Material Weakness
  • 521083 2023-005
    Material Weakness
  • 521084 2023-006
    Material Weakness
  • 521085 2023-007
    Significant Deficiency Repeat
  • 521086 2023-004
    Material Weakness
  • 521087 2023-005
    Material Weakness
  • 521088 2023-006
    Material Weakness
  • 521089 2023-007
    Significant Deficiency Repeat
  • 521090 2023-004
    Material Weakness
  • 521091 2023-005
    Material Weakness
  • 521092 2023-006
    Material Weakness
  • 521093 2023-007
    Significant Deficiency Repeat
  • 521094 2023-010
    Material Weakness
  • 521095 2023-008
    Material Weakness
  • 521097 2023-008
    Material Weakness
  • 521098 2023-009
    Significant Deficiency
  • 521099 2023-008
    Material Weakness
  • 521100 2023-009
    Significant Deficiency
  • 521101 2023-008
    Material Weakness
  • 521102 2023-009
    Significant Deficiency
  • 1097524 2023-004
    Material Weakness
  • 1097525 2023-005
    Material Weakness
  • 1097526 2023-006
    Material Weakness
  • 1097527 2023-007
    Significant Deficiency Repeat
  • 1097528 2023-004
    Material Weakness
  • 1097529 2023-005
    Material Weakness
  • 1097530 2023-006
    Material Weakness
  • 1097531 2023-007
    Significant Deficiency Repeat
  • 1097532 2023-004
    Material Weakness
  • 1097533 2023-005
    Material Weakness
  • 1097534 2023-006
    Material Weakness
  • 1097535 2023-007
    Significant Deficiency Repeat
  • 1097536 2023-010
    Material Weakness
  • 1097537 2023-008
    Material Weakness
  • 1097538 2023-009
    Significant Deficiency
  • 1097539 2023-008
    Material Weakness
  • 1097540 2023-009
    Significant Deficiency
  • 1097541 2023-008
    Material Weakness
  • 1097542 2023-009
    Significant Deficiency
  • 1097543 2023-008
    Material Weakness
  • 1097544 2023-009
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $10.81M
14.218 Community Development Block Grants/entitlement Grants $2.01M
84.027 Special Education Grants to States $1.05M
84.010 Title I Grants to Local Educational Agencies $670,585
10.553 School Breakfast Program $222,829
84.425U Education Stabilization Fund $200,000
84.027X Special Education Grants to States $115,623
10.555 National School Lunch Program $101,286
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $79,317
16.922 Equitable Sharing Program $58,733
93.959 Block Grants for Prevention and Treatment of Substance Abuse $43,553
84.173 Special Education Preschool Grants $32,388
84.424 Student Support and Academic Enrichment Program $31,268
84.365 English Language Acquisition State Grants $26,114
84.173X Special Education Preschool Grants $24,274
10.558 Child and Adult Care Food Program $23,887
84.048 Career and Technical Education -- Basic Grants to States $14,922
84.425W Education Stabilization Fund $9,500
84.425D Education Stabilization Fund $6,953
16.607 Bulletproof Vest Partnership Program $3,502
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $2,187