EIN: 042304133
UEI: D3KCJZDMC7V5
Data as of August 20, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 22, 2020. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by June 22, 2021, which was (1885 days ago).
What is a management decision? →Finding Number: 2020-001 Federal Agency: U.S. Department of Health and Human Services Pass-through Agency: Massachusetts Early Education & Care Program: Child Care and Development Fund Cluster (CCDF) CFDA#: 93.575 and 93.596 Award numbers: Various Award Years: July 1, 2017 to June 30, 2022 Finding: Internal Control over Payroll Costs Prior Year Finding: No Criteria In accordance with 2 CFR 200.430(i)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both Federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. 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 allowable costs associated with payroll charges, we noted that Action for Boston Community Development, Inc. and subsidiaries (the Organization) documents time and attendance of employees on daily timesheets as well as weekly Time and Effort Reporting worksheets. The timesheets and worksheets are then reviewed by each employee?s supervisor ensuring appropriate salary and wage distribution to the Child Care and Development Fund Program (CCDF). However, for 17 out of 40 payroll transactions selected for testing, the daily timesheets and Time and Effort Reporting worksheets were not completed and reviewed. Cause This appears to be the result of an insufficient policy and lack of compensating controls when employees were moved to a remote working environment. Effect Insufficient review of daily timesheets or other time allocation documentation increases the risk of inaccurate payroll costs being allocated to a grant award. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Cost: None Recommendation: We recommend that the Organization enhance its policies and procedures to include a documented review of employees? time allocation while in a remote work environment. View of Responsible Officials from the Auditee In March 2020, when the Governor of Massachusetts declared a state of emergency and instituted a state wide shut down for all but essential businesses and workers, Action for Boston Community Development (ABCD) immediately took emergency measures to ensure the safety of both staff and clients. While some programs, such as food pantries, were still operating at ABCD sites, the majority of programs began providing services remotely with the majority of staff working remotely. At the same time, ABCD still needed to pay staff for their work. As timecards were still done on paper it was not feasible to deliver paper timecards to over 700 staff and get them back in time to process a weekly in-house payroll. As a result, an interim method of accounting for time worked had to be implemented. For a brief period, ABCD instructed supervisors to monitor the time their staff worked and to provide that information to payroll staff. Shortly after, a timecard template was designed and was sent via email to staff to complete. Once completed, the employee sent it to their supervisor for approval. The supervisors, in turn, approved each of their employee?s time and forwarded the information to payroll staff for processing payroll. Additionally, ABCD has contracted with its human resource / payroll vendor to implement a cloud-based electronic timecard system. The system will allow employees to login to report their time and for supervisors to go in and approve that time before it is processed by payroll staff. The cause of this condition was the direct result of a health emergency caused by a world-wide pandemic. ABCD responded as quickly and as effectively as possible to an extremely unique and difficult situation to resolve this condition. The corrective action was completed.
Finding Number 2020-001 View of Responsible Officials from the Auditee / Corrective Action: In March 2020, when the Governor of Massachusetts declared a state of emergency and instituted a state wide shut down for all but essential businesses and workers, Action for Boston Community Development (ABCD) immediately took emergency measures to ensure the safety of both staff and clients. While some programs, such as food pantries, were still operating at ABCD sites, the majority of programs began providing services remotely with the majority of staff working remotely. At the same time, ABCD still needed to pay staff for their work. As timecards were still done on paper it was not feasible to deliver paper timecards to over 700 staff and get them back in time to process a weekly in-house payroll. As a result, an interim method of accounting for time worked had to be implemented. For a brief period, ABCD instructed supervisors to monitor the time their staff worked and to provide that information to payroll staff. Shortly after, a timecard template was designed and was sent via email to staff to complete. Once completed, the employee sent it to their supervisor for approval. The supervisors, in turn, approved each of their employee?s time and forwarded the information to payroll staff for processing payroll. Additionally, ABCD has contracted with its human resource / payroll vendor to implement a cloud-based electronic timecard system. The system will allow employees to login to report their time and for supervisors to go in and approve that time before it is processed by payroll staff. The cause of this condition was the direct result of a health emergency caused by a world-wide pandemic. ABCD responded as quickly and as effectively as possible to an extremely unique and difficult situation to resolve this condition. Responsible Contact Person: Marjorie Lombard, Vice President / Chief Financial officer Expected Completion Date: Completed
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on November 19, 2019. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by May 19, 2020, which was (2284 days ago).
What is a management decision? →Finding Number: 2019-001 Federal Agency: U.S. Department of Health and Human Services Pass-through Agency: Massachusetts Department of Housing and Community Development Program: Community Services Block Grant CFDA#: 93.569 Award numbers: SCOCD4200186BG01000; SCOCD42001960BG0100 Award Years: October 1, 2017 to September 30, 2018 and October 1, 2018 to September 30, 2019 Finding: Internal Control over Subrecipient Monitoring Prior Year Finding: No Criteria 2 CFR section 200.331(a) indicates that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification: (1) Federal Award Identification. ? Subrecipient?s name (which must match registered name in DUNS); ? Subrecipient?s DUNS number (see ? 200.32 Data Universal Numbering System (DUNS) number); ? Federal Award Identification Number (FAIN); ? Federal award date; ? Subaward Period of Performance Start and End Date; ? Amount of Federal Funds Obligated by this action; ? Total Amount of Federal Funds Obligated to the subrecipient; ? Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; ? Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); ? Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity; ? CFDA Number and Name; the pass-through entity must identify the dollar amount made available under each Federal award and the CFDA number at time of disbursement; ? Identification of whether the award is R&D; and ? Indirect cost rate for the Federal award (including if the de minimis rate is charged per ? 200.414 Indirect (F&A) costs). (2) All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award. (3) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the passthrough entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports; (4) An approved Federally recognized indirect cost rate negotiated between the subrecipient and the Federal government or, if no such rate exists, either a rate negotiated between the pass-through entity and the subrecipient (in compliance with this part), or a de minimis indirect cost rate as defined in ? 200.414 Indirect (F&A) costs, paragraph (b) of this part. (5) A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient?s records and financial statements as necessary for the passthrough entity to meet the requirements of this section, ?? 200.300 Statutory and national policy requirements through 200.309 Period of performance, and Subpart F ? Audit Requirements of this part; and (6) Appropriate terms and conditions concerning closeout of the subaward. Also, according to 2 CFR 200.331(b), a pass-through entity must evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring, which may include consideration of such factors as: ? The subrecipient?s prior experience with the same or similar subawards; ? The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F ? Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; ? Whether the subrecipient has new personnel or new or substantially changed systems; and ? The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Condition Based on a review of the CSBG Delegate Agreement (the Agreement) between Action for Boston Community Development, Inc. and subsidiaries? (the Organization) and its subrecipients, it was noted that such documents did not contain all of the required elements of 2 CFR Section 200.331(a) listed above. The Agreements did not contain the subrecipient?s DUNs number. Additionally, although a review process is in place, the Organization was unable to provide documentation showing that a formal review had been performed over their subrecipients risk evaluation. Cause The observation related to subrecipient award letters appears to be due to the Agreement being a standard template which did not include all of the required elements of 2CFR Section 200.331(a). The observation related to subrecipient risk evaluations appears to be due to current policies not requiring formal documentation of the assessment of risk among its subrecipients used to develop the nature and extent of monitoring procedures. Effect The Organization is not in compliance with the requirements related to subrecipient notification and documentation of subrecipient risk assessments for purposes of determining appropriate subrecipient monitoring. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Cost: None Recommendation: We recommend that the Organization execute an updated Agreement with its subrecipients that expressly includes all information described in 2 CFR section 200.331(a)(1) as required by the Uniform Guidance. Additionally, we recommend that the Organization enhance its policies to ensure that each subrecipient?s evaluation and review is formally documented. View of Responsible Officials from the Auditee The Organization has updated its agreements with the three subrecipients to include each of their DUNS numbers so that the agreement now contains all the information as required by 2 CFR section 200.331(a) of the Uniform Guidance. Additionally, monitoring activities are documented through the submission of the annual work plan, annual budget, site visit and site visit report, six-month and twelve month work plan outcome reports, annual report, audited financial report and so on. The Director of Field Operations is responsible for the oversight of the CSBG program and monitoring of the subrecipients. While the subrecipients of the program were monitored and all of the necessary documentation obtained, the organization did not utilize a tracking mechanism to show when all of the materials were received and reviewed. A tracking form has been created so that the monitoring process is formally documented for each of the three subrecipients in accordance with 2 CFR section 200.331(b) of the Uniform Guidance. The corrective action plan has been completed.
Finding Number: 2019-001 Corrective Action: The Organization has updated its agreements with the three subrecipients to include each of their DUNS numbers so that the agreement now contains all the information as required by 2 CFR section 200.331(a) of the Uniform Guidance. Additionally, monitoring activities are documented through the submission of the annual work plan, annual budget, site visit and site visit report, six-month and twelve month work plan outcome reports, annual report, audited financial report and so on. The Director of Field Operations is responsible for the oversight of the CSBG program and monitoring of the subrecipients. While the subrecipients of the program were monitored and all of the necessary documentation obtained, the organization did not utilize a tracking mechanism to show when all of the materials were received and reviewed. A tracking form has been created so that the monitoring process is formally documented for each of the three subrecipients in accordance with 2 CFR section 200.331(b) of the Uniform Guidance. Responsible Contact Person: Joshua Young, Director of Field Operations Expected Completion Date: Completed
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
Track your findings and corrective action plans across audit cycles.
Start tracking findings →Monitor subrecipient audit findings and compliance status.
Start monitoring →Single Audit Intelligence is an independent tool powered by Federal Audit Clearinghouse data. Not affiliated with GSA, OMB, or any federal agency.