Finding 62135 (2022-001)

Significant Deficiency

Requirement

I

Questioned Costs

-

Year

2022

Accepted

2023-03-27

Audit: 57076

Organization: Town of Chelmsford (MA)

Auditor: Cliftonlarsonallen LLP

AI Summary

Core Issue: The Town failed to document vendor verification against suspension or debarment from federal assistance programs.
Impacted Requirements: Compliance with 2 CFR Part 200.214, which mandates verification of vendor eligibility for federal funding.
Recommended Follow-Up: Implement annual documentation procedures to ensure all vendors are verified as not suspended or debarred.

Finding Text

2022-001 Federal Agency: U.S. Department of Agriculture Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555 Pass-Through Agency: Massachusetts Department of Elementary & Secondary Education Pass-Through Number(s): 09-056 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance Compliance Requirement: Suspension and Debarment 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. Nonfederal entities must verify that contracts with certain parties are not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For all vendors in our statistically valid sample, the Town did not document its verification that vendors are not suspended or debarred from participation in Federal assistance programs or activities. The vendors were not suspended or debarred. Questioned Costs: None. Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors? debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No. Recommendation: We recommend to annually (at a minimum) document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding. See Corrective Action Plan.

Corrective Action Plan

The Town of Chelmsford, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 ? June 30, 2022 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDING?FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF AGRICULTURE 2022-001 Child Nutrition Cluster ? Assistance Listing Numbers 10.553 and 10.555 Recommendation: We recommend to annually (at a minimum) document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Explanation of disagreement with audit finding: There is no disagreement with the audit finding and agrees that the vendors were not suspended or disbarred. Action taken in response to finding: The Chelmsford Public Schools is one of the twelve districts that is part of the Metro North Collaborative (MNC). The MNC executes the competitive bid process for several of the school nutrition products. A certificate of good standing was required in the bid process and the MNC has added the recommended language that the participant certify to the best of its knowledge and belief that it and its principals are not presently debarred, suspended, proposed for disbarment, declared ineligible, or voluntarily excluded from the covered transactions by any Federal department or agency. Chelmsford Public Schools will also assist the MNC with documenting the suspension/debarment verifications at the time of the bid process and bid award with screen shots from the SAM.gov website resource. In addition, the Chelmsford Public Schools has verified that list of vendors is not suspended or disbarred, using the SAM.gov website resource. Name(s) of the contact person(s) responsible for corrective action: The Director of School Nutrition of the Chelmsford Public Schools. Planned completion date for corrective action plan: The spring of 2023 (April ? May timeframe) is when the MNC invites interested vendors to submit bids for the school nutrition products and the bid documents will reflect the recommended language. In January and February of 2023, the Chelmsford Public Schools verified the list of vendors is not suspended or disbarred, using the SAM.gov website resource.

Programs in Audit

ALN	Program Name	Expenditures
84.027	Special Education_grants to States	$1.37M
84.425	Education Stabilization Fund	$715,907
21.027	Coronavirus State and Local Fiscal Recovery Funds	$646,208
10.553	School Breakfast Program	$624,856
21.019	Coronavirus Relief Fund	$358,433
84.010	Title I Grants to Local Educational Agencies	$264,321
84.173	Special Education_preschool Grants	$199,865
10.555	National School Lunch Program	$138,339
84.367	Improving Teacher Quality State Grants	$77,297
97.044	Assistance to Firefighters Grant	$46,357
84.365	English Language Acquisition State Grants	$28,846
97.042	Emergency Management Performance Grants	$9,489

Finding 62135 (2022-001)

AI Summary

Finding Text

Corrective Action Plan

Categories

Other Findings in this Audit

Programs in Audit