TOWN OF CLINTONLocal Government

2024-001 U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster – ALN 10.553, 10.555 & 10.559 Significant Deficiency in Internal Controls Over Compliance Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: The District utilized prices that were competitively procured by French River Collaborative, of which it is a member, and did not obtain individual contracts with the five vendors. Additionally, the District only obtained one of the four required suspension and debarment certifications. Cause: The District did not follow federal award policies and procedures for contract management and suspension and debarment verification when procuring school lunch goods and services. Effect: The District might not obtain the proper negotiated rates that were part of the competitive procurement. The District is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. It was determined that none of the three vendors were suspended or debarred from federal awards. Questioned Costs: None Repeat Finding from Prior Year: Yes; Finding 2023-001 Recommendation: The District should obtain individual contracts with vendors that were competitively procured by the Collaborative and require those vendors to attest on suspension and debarment certifications, for all applicable purchases of goods and services. Views of Responsible Official: Management agrees with the finding.

2024-002 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education COVID-19 – Education Stabilization Fund – ALN 84.425 Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Two final financial reports due during the prior fiscal years were not submitted. Cause: A lack of formal reconciliation and review process for grants. Effect: The District is not in compliance with reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Yes; Finding 2023-003. Recommendation: The District should implement procedures to verify that reports are completed and submitted to the oversight agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.

2024-003 U.S. Department of the Treasury COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - ALN 21.027 Material Weakness in Internal Controls Over Compliance and Compliance Finding Criteria: Per 2 CFR section 200.328 of the Uniform Guidance, each recipient must report program outlays and program income on a cash or accrual basis, as prescribed by the federal awarding agency. The compliance supplement identifies four Key Line Items required to be reported to the federal awarding agency which include (1) current period obligation, (2) cumulative obligation, (3) current period expenditure and (4) cumulative expenditure. An obligation is an order placed for property and services and entering into contracts, subawards, and similar transactions that require payment. Condition: As of the March 31, 2024, reporting date, the Town’s Project and Expenditure report had reported cumulative expenditures that were understated by approximately $148,000 and cumulative obligations were overstated by approximately $3,505,000. Additionally, the Project and Expenditure report for the period ending March 31, 2024, was not filed until March 25, 2025. Cause: The Town did not reconcile the Project and Expenditure report with the Town’s general ledger before submitting. Additionally, the Town had a lack of formal review process to make sure the report was filed in a timely manner. Effect: The Town did not properly report grant expenditures and obligations in the Project and Expenditure report that was filed nearly eleven months after the deadline. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The Town should implement procedures to reconcile the financial information in the Project and Expenditure reports to the Town’s general ledger and contract files within a timely manner of reporting deadline. Views of Responsible Official: Management agrees with the finding.

2024-004 U.S. Department of the Treasury COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - ALN 21.027 Significant Deficiency in Internal Controls Over Compliance and Compliance Finding Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Suspension and debarment compliance was not verified for five vendors. Cause: Lack of formal federal procurement policies and procedures and resulted in required suspension and debarment checks not being performed. Effect: The Town is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. It was determined that none of the five vendors were suspended or debarred from federal awards. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The Town should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred. Views of Responsible Official: Management agrees with the finding.

2024-005 U.S. Department of the Treasury COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - ALN 21.027 Significant Deficiency in Internal Controls Over Compliance Criteria: The Uniform Guidance required written policies regarding cash management, determination of allowable costs, employee travel, procurement and subrecipient monitoring. Condition: The Town did not have formal written policies that covered all federal award criteria, including determination of allowable costs, suspension and debarment and subrecipient monitoring. Cause: Incomplete documentation of policies and procedures. Effect: The Town is not in compliance with the Uniform Guidance requirements. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The Town should implement procedures to document all federal awards policies required by the Uniform Guidance. Views of Responsible Official: Management agrees with the finding.

2023-001 U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster – ALN 10.553, 10.555 & 10.559 Significant Deficiency in Internal Controls Over Compliance and Compliance Finding Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: A competitive procurement process, which includes suspension and debarment certifications, was not properly performed by the Town for the purchase of school lunch food products. Cause: The Town utilized vendors that were previously contracted in prior years without performing a current procurement and suspension and debarment verification. Effect: The Town is not in compliance with Federal procurement or suspension and debarment requirements. Questioned Costs: $453,359 Repeat Finding from Prior Year: Yes; Finding 2022-001 Recommendation: The Town should implement procedures to perform competitive procurements, which include suspension and debarment certification, for all applicable purchases of goods and services. Views of Responsible Official: Management agrees with the finding.

2023-002 U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster – ALN 10.553, 10.555 & 10.559 Significant Deficiency in Internal Controls Over Compliance Criteria: Per 7 CFR Part 225.9 (d)(5), the District must retain records that support its claims for meal reimbursement. Condition: The District’s school lunch office maintained production records and manual count sheets for the elementary school and high school instead of using the point-of-sale system for tracking student meal counts. Cause: The elementary school and high school utilize manual counts to track meals for reimbursement. Effect: Manual records are subject to clerical and other errors which could lead to inaccurate claims for reimbursement. Questioned Costs: None Perspective Information: The District started utilizing the point-of-sale system in the elementary school and high school starting in the FY25 school year. Repeat Finding from Prior Year: No Recommendation: The elementary school and high school should utilize the point-of-sale system for tracking student meal counts. Views of Responsible Official: Management agrees with the finding.

2023-003 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education COVID-19 – Education Stabilization Fund – ALN 84.425 Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Two final financial reports due during the prior fiscal years were not submitted. Cause: A lack of formal reconciliation and review process for grants. Effect: The District is not in compliance with reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Yes; Finding 2022-002. Recommendation: The District should implement procedures to verify that reports are completed and submitted to the oversight agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.

U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster – ALN 10.553, 10.555 & 10.559 Significant Deficiency in Internal Controls and Compliance Finding Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: A competitive procurement process, which includes suspension and debarment certifications, was not properly performed by the Town for the purchase of school lunch food products. Cause: The Town utilized vendors that were previously contracted in prior years without performing a current procurement and suspension and debarment verification. Effect: The Town is not in compliance with Federal procurement or suspension and debarment requirements. Questioned Costs: $342,999 Repeat Finding from Prior Year: No Recommendation: The Town should implement procedures to perform competitive procurements, which include suspension and debarment certification, for all applicable purchases of goods and services. Views of Responsible Official: Management agrees with the finding.

U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education COVID-19 – Education Stabilization Fund – ALN 84.425 Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Two final financial reports due during the fiscal year were not submitted. Cause: A lack of formal reconciliation and review process for grants. Effect: The Town is not in compliance with reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The Town should implement procedures to verify that reports are completed and submitted to the oversight agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.

Reference Number - 2020-001 Federal Program Information: All programs Type of Findings: Compliance ? Other Matters, and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: OMB Uniform Administrative Requirements, Cost Principles and Audit Requirement for Federal Awards (Uniform Guidance) stipulates that federal award recipients must document their policies and procedures and internal controls over certain aspects of financial and program management, including over cash management, determination of allowable costs, employee travel and procurement. Condition and Context: The Town has not completed the process of creating the required documentation required by the Uniform Guidance. Cause: Insufficient documentation of internal controls. Effect: Lack of proper documentation could lead to noncompliance with federal program requirements. Questioned Costs: There are no questioned costs related to this finding. Repeat Finding: This is a repeat finding. Recommendation: The Town should establish policies and procedures as required by the Uniform Guidance. Views of Responsible Officials: There is no disagreement with this audit finding.

Reference Number - 2019-001 Federal Program Information: All programs Type of Findings: Compliance ? Other Matters, and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: OMB Uniform Administrative Requirements, Cost Principles and Audit Requirement for Federal Awards (Uniform Guidance) stipulates that federal award recipients must document their policies and procedures and internal controls over certain aspects of financial and program management, including over cash management, determination of allowable costs, employee travel and procurement. Condition and Context: The Town has not completed the process of creating the required documentation required by the Uniform Guidance. TOWN OF CLINTON, MASSACHUSETTS Schedule of Findings and Questioned Costs Year Ended June 30, 2019 Cause: Insufficient documentation of internal controls. Effect: Lack of proper documentation could lead to noncompliance with federal program requirements. Questioned Costs: There are no questioned costs related to this finding. Repeat Finding: This is a repeat finding. Recommendation: The Town should establish policies and procedures as required by the Uniform Guidance. Views of Responsible Officials: There is no disagreement with this audit finding.

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