Finding 544374 (2024-001)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-03-31
Audit: 351019
Organization: Town of Falmouth, Ma (MA)

AI Summary

  • Core Issue: The School awarded contracts to two vendors without following the required competitive procurement process.
  • Impacted Requirements: This violates Federal procurement rules outlined in 2 CFR section 200.319.
  • Recommended Follow-Up: The School should establish procedures to ensure competitive procurement for all relevant contracts.

Finding Text

2024-001 U.S. Department of Education 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 Compliance Finding and Material Weakness in Internal Controls Over Compliance Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Condition: Two vendors were awarded a contract without a competitive procurement process. Cause: The School relied on State procurement exemptions which do not apply to Federal procurements. Effect: The Town is not in compliance with Federal procurement requirements. Questioned Costs: $85,917.50 Repeat Finding from Prior Year: No. Recommendation: The School should implement procedures to perform procurement procedures on all applicable contracts for goods and services. Views of Responsible Official: Management agrees with the finding.

Corrective Action Plan

To: Laura Sitrin, Director of Finance, Town of Falmouth From: Paul Dart, Director of Finance & Operations Date: March 31, 2025 RE: IDEA 240 Grant Expenditures The following outlines the findings, resolution and ongoing corrective actions for the IDEA FY24 Grant and FY25 Grant. Findings: Federal Award Findings and Questioned Costs 2024-001 U.S. Department of Education 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 Resolution: The following corrective actions have been taken to immediately address this finding and ensure compliance with federal procurement regulations going forward: ● Journal entries have been submitted to the Town Accountant in order to move all FY24 expenses originally charged to the FY24 240 IDEA grant to either the School Choice Contracted Services account or Circuit Breaker Contracted Services account, as appropriate. ● A grant amendment is in process to reallocate funds in the FY24 240 grant originally intended for these specialized vendors to out of district tuition instead, ensuring compliance with procurement requirements. ● In addition to the above corrective actions related to the FY24 grant spending, any expenses for goods and services incurred in FY25 that did not meet federal procurement requirements have been corrected for FY24 grants that remain open. ● Grant amendments and journal entries for the FY25 240 grant and FY25 262 grant are in process for the current fiscal year to maintain compliance. These actions resolve the issue in the current fiscal year for all grants that are currently open. To strengthen internal controls and prevent recurrence, the Business Office is updating the District procurement policies and procedures to ensure the most restrictive procurement provision is followed for all purchases made with federal funds. All procurement and grant management staff have met to review training on the federal procurement process including thresholds, methods, documentation/justification for non-competitive procurements, and the differences between state and federal regulations. The district is committed to ensuring continued compliance through ongoing staff training, monitoring and policy updates. For further information or questions regarding this corrective action plan, please do not hesitate to contact me.

Categories

Procurement, Suspension & Debarment Material Weakness

Other Findings in this Audit

  • 544375 2024-001
    Material Weakness
  • 544376 2024-001
    Material Weakness
  • 544377 2024-001
    Material Weakness
  • 544378 2024-001
    Material Weakness
  • 544379 2024-001
    Material Weakness
  • 544380 2024-001
    Material Weakness
  • 544381 2024-001
    Material Weakness
  • 1120816 2024-001
    Material Weakness
  • 1120817 2024-001
    Material Weakness
  • 1120818 2024-001
    Material Weakness
  • 1120819 2024-001
    Material Weakness
  • 1120820 2024-001
    Material Weakness
  • 1120821 2024-001
    Material Weakness
  • 1120822 2024-001
    Material Weakness
  • 1120823 2024-001
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.553 School Breakfast Program $127,913
10.555 National School Lunch Program $110,012
15.685 National Fish Passage $76,524
84.010 Title I Grants to Local Educational Agencies $46,364
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $41,652
84.425 Education Stabilization Fund $33,000
84.424 Student Support and Academic Enrichment Program $22,043
16.738 Edward Byrne Memorial Justice Assistance Grant Program $20,905
84.027 Special Education Grants to States $16,559
45.310 Grants to States $15,077
21.027 Coronavirus State and Local Fiscal Recovery Funds $12,327
20.600 State and Community Highway Safety $8,967
97.042 Emergency Management Performance Grants $8,500
16.607 Bulletproof Vest Partnership Program $8,478
84.365 English Language Acquisition State Grants $2,543
20.616 National Priority Safety Programs $1,960
97.067 Homeland Security Grant Program $1,788
15.616 Clean Vessel Act $1,173
84.048 Career and Technical Education -- Basic Grants to States $37
84.173 Special Education Preschool Grants $30