Finding Text
Federal Agency: U.S. Department of Education
Federal Program Name: Special Education Cluster
Assistance Listing Number: 84.027, 84.173
Federal Award Identification Number: N/A
Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and the Massachusetts Department of Early Education and Care
Pass-Through Number(s): 240-585359-2022-0131, 240-744100-2023-0131, 252-610784-2022-0131, 262-585362-2022-0131, 262-744101-2023-0131, 264-610783-2022-0131
Award Period: July 1, 2021 – June 30, 2023
Compliance Requirement: Procurement, Suspension and Debarment
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Criteria or specific requirement:
The Code of Federal Regulations (CFR) Title 2 Part 200.214 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:
Procedures were not in place to ensure three (3) of five (5) vendors selected for testing in our statistically valid sample and paid from the grant award were not suspended or debarred. Upon further testing, it was determined none of the vendors were suspended or debarred.
Questioned costs:
None
Cause:
Procedures were not in place to ensure vendors are not suspended or debarred.
Effect:
Federal funds could be expended to suspended or debarred vendors and subject to disallowance.
Repeat Finding:
No.
Recommendation:
We recommend the Town enhance procedures and controls to ensure verifications of suspension and debarment statuses are obtained from vendors prior to executing transactions with these vendors.
Views of responsible officials:
Management has updated procedures to ensure vendors are not suspended or debarred and has shared and reviewed this information with staff to ensure that the procedure is carefully followed.