FAC Explorer

Finding 539072 (2024-011)

Material Weakness
Requirement
H
Questioned Costs
$1
Year
2024
Accepted
2025-03-28
Audit: 349776
Organization: City of Boston (MA)
Auditor: Kpmg LLP

AI Summary

  • Core Issue: Noncompliance with the grant's period of performance, as 2 out of 4 tested expenditures were charged for services rendered before the award start date.
  • Impacted Requirements: Failure to adhere to federal regulations regarding allowable costs during the specified budget period, risking improper charges to the grant.
  • Recommended Follow-up: Boston Public Schools should enhance their review processes for vendor invoices to ensure service periods align with grant timelines and provide updated training for relevant staff.

Finding Text

Finding number: 2024-011 Federal agency: U.S. Department of Education Pass-through agency: Commonwealth Department of Elementary and Secondary Education Program: Student Support and Academic Enrichment Program ALN #: 84.424 Award number: 0309-000548-2024-0035 Award year: September 12, 2023 to September 30, 2025 Finding: Internal Control and Compliance over Period of Performance Prior Year Finding: No Type of Finding: Material Weakness and Material Noncompliance Criteria Period of Performance A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308, 200.309, and 200.403(h). A period of performance may contain one or more budget periods. LEAs and SEAs must obligate funds during the 27 months, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. This maximum period includes a 15-month period of initial availability plus a 12-month period for carryover. Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of period of performance associated with those expenditures charged to grant awards which began during fiscal year 2024 and cost transfers, we noted noncompliance for 2 expenditures out of a sample of 4. Per review of the underlying vendor invoices, the service period for these expenditures started prior to the award start date of September 12, 2023.Cause This appears to be due to an insufficient review of invoices to ensure the underlying services performed by vendors are within the grant awards outlined grant period. Effect Insufficient review of vendor invoices increases the risk of costs being charged to a grant award outside its approved budget period. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: $1,250,864 Recommendation We recommend that the Boston Public Schools (BPS) re-enforce its policies and procedures to ensure their review of expenditures charged to the award also includes a detailed review of the underlying vendor service period. View of Responsible Officials from the Auditee BPS will take a multi-step approach to ensuring accuracy of spending to the grant award period: 1. Reinforce our existing practice of ensuring that period of service is reflected on Purchase Orders, which it was for the PO’s in question. 2. Working with major suppliers to ensure they understand the grant funded nature of their program and the eligible dates of service, which are outlined on the Purchase Order 3. Review / Update training for our Accounts Payable team on ensuring that the period of service on an invoice matches the period of service on the Purchase Order 4. Review / Update training for our State & Federal Grants, Programs, and Compliance teams to ensure that expenses are reviewed before the end of the grant period to ensure compliance with federal regulations.

Corrective Action Plan

Boston Public Schools will take a multi-step approach to ensure accuracy of spending to the grant award period. Anticipated Completion Date: January 31, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

Categories

Questioned Costs Period of Performance Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 539061 2024-003
    Significant Deficiency Repeat
  • 539062 2024-004
    Significant Deficiency
  • 539063 2024-005
    Significant Deficiency
  • 539064 2024-006
    Significant Deficiency Repeat
  • 539065 2024-007
    Significant Deficiency Repeat
  • 539066 2024-008
    Significant Deficiency Repeat
  • 539067 2024-009
    Significant Deficiency Repeat
  • 539068 2024-009
    Significant Deficiency Repeat
  • 539069 2024-009
    Significant Deficiency Repeat
  • 539070 2024-010
    Significant Deficiency Repeat
  • 539071 2024-010
    Significant Deficiency Repeat
  • 539073 2024-012
    Significant Deficiency Repeat
  • 1115503 2024-003
    Significant Deficiency Repeat
  • 1115504 2024-004
    Significant Deficiency
  • 1115505 2024-005
    Significant Deficiency
  • 1115506 2024-006
    Significant Deficiency Repeat
  • 1115507 2024-007
    Significant Deficiency Repeat
  • 1115508 2024-008
    Significant Deficiency Repeat
  • 1115509 2024-009
    Significant Deficiency Repeat
  • 1115510 2024-009
    Significant Deficiency Repeat
  • 1115511 2024-009
    Significant Deficiency Repeat
  • 1115512 2024-010
    Significant Deficiency Repeat
  • 1115513 2024-010
    Significant Deficiency Repeat
  • 1115514 2024-011
    Material Weakness
  • 1115515 2024-012
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund $203.78M
84.010 Title I Grants to Local Educational Agencies $58.87M
14.267 Continuum of Care Program $40.38M
10.555 National School Lunch Program $30.91M
84.027 Special Education Grants to States $17.94M
97.067 Homeland Security Grant Program $13.81M
97.083 Staffing for Adequate Fire and Emergency Response (safer) $9.97M
14.239 Home Investment Partnerships Program $5.87M
21.023 Emergency Rental Assistance Program $4.73M
84.173 Special Education Preschool Grants $3.24M
84.424 Student Support and Academic Enrichment Program $3.12M
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $3.00M
14.231 Emergency Solutions Grant Program $2.77M
84.048 Career and Technical Education -- Basic Grants to States $2.24M
84.365 English Language Acquisition State Grants $1.94M
10.558 Child and Adult Care Food Program $1.93M
93.045 Special Programs for the Aging, Title Iii, Part C, Nutrition Services $1.89M
66.443 Reducing Lead in Drinking Water (sdwa 1459b) $1.48M
97.106 Securing the Cities Program $1.28M
14.905 Lead Hazard Reduction Demonstration Grant Program $1.11M
10.582 Fresh Fruit and Vegetable Program $1.09M
14.248 Community Development Block Grants Section 108 Loan Guarantees $919,562
10.559 Summer Food Service Program for Children $883,164
20.500 Federal Transit Capital Investment Grants $815,500
16.833 National Sexual Assault Kit Initiative $777,046
84.287 Twenty-First Century Community Learning Centers $748,658
93.044 Special Programs for the Aging, Title Iii, Part B, Grants for Supportive Services and Senior Centers $737,136
84.184 School Safely National Activities $731,838
97.111 Regional Catastrophic Preparedness Grant Program (rcpgp) $711,470
93.493 Congressional Directives $680,072
93.053 Nutrition Services Incentive Program $593,356
97.024 Emergency Food and Shelter National Board Program $556,657
93.079 Cooperative Agreements to Promote Adolescent Health Through School-Based Hiv/std Prevention and School-Based Surveillance $526,196
20.616 National Priority Safety Programs $496,691
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $425,792
93.043 Special Programs for the Aging, Title Iii, Part D, Disease Prevention and Health Promotion Services $402,254
93.052 National Family Caregiver Support, Title Iii, Part E $398,440
97.044 Assistance to Firefighters Grant $393,945
21.027 Coronavirus State and Local Fiscal Recovery Funds $353,549
94.016 Americorps Seniors Senior Companion Program (scp) 94.016 $329,650
16.738 Edward Byrne Memorial Justice Assistance Grant Program $302,301
20.219 Recreational Trails Program $300,000
97.047 Bric: Building Resilient Infrastructure and Communities $294,366
84.002 Adult Education - Basic Grants to States $276,923
16.741 Dna Backlog Reduction Program $254,896
84.336 Teacher Quality Partnership Grants $222,942
16.015 Missing Alzheimer's Disease Patient Assistance Program $142,079
94.002 Americorps Seniors Retired and Senior Volunteer Program (rsvp) 94.002 $134,183
10.935 Urban Agriculture and Innovative Production $132,138
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs $131,056
14.401 Fair Housing Assistance Program $119,749
84.196 Education for Homeless Children and Youth $106,059
16.588 Violence Against Women Formula Grants $104,318
14.241 Housing Opportunities for Persons with Aids $99,539
45.301 Museums for America $93,526
97.042 Emergency Management Performance Grants $91,427
32.001 Communications Information and Assistance and Investigation of Complaints $77,625
16.745 Criminal and Juvenile Justice and Mental Health Collaboration Program $73,828
16.838 Comprehensive Opioid, Stimulant, and Other Substances Use Program $68,165
10.331 Gus Schumacher Nutrition Incentive Program $65,759
14.889 Choice Neighborhoods Implementation Grants $59,681
10.579 Child Nutrition Discretionary Grants Limited Availability $59,354
97.056 Port Security Grant Program $42,469
10.575 Farm to School Grant Program $37,410
93.042 Special Programs for the Aging, Title Vii, Chapter 2, Long Term Care Ombudsman Services for Older Individuals $35,915
14.246 Community Development Block Grants/brownfields Economic Development Initiative $28,049
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $27,991
66.818 Brownfields Multipurpose, Assessment, Revolving Loan Fund, and Cleanup Cooperative Agreements $25,980
15.904 Historic Preservation Fund Grants-in-Aid $11,270
16.710 Public Safety Partnership and Community Policing Grants $10,945
16.820 Postconviction Testing of Dna Evidence $9,290
14.218 Community Development Block Grants/entitlement Grants $2,146
14.261 National Homeless Data Analysis Project (nhdap) $1,750
10.727 Inflation Reduction Act Urban & Community Forestry Program $1,232
17.259 Wioa Youth Activities $1,145
11.307 Economic Adjustment Assistance $949
17.285 Registered Apprenticeship $582
17.258 Wioa Adult Program $214
21.009 Volunteer Income Tax Assistance (vita) Matching Grant Program $182
17.289 Community Project Funding/congressionally Directed Spending $107
17.278 Wioa Dislocated Worker Formula Grants $101
17.207 Employment Service/wagner-Peyser Funded Activities $67