EIN: 046001254
UEI: VP1TFHDS44D8
Audited by: ROSELLI, CLARK AND ASSOCIATES
Oversight agency: 84 [Department of Education]
Data as of August 27, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 23, 2025. 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 March 23, 2026 (158 days ago).
What is a management decision? →Two vendors were awarded a contract without a competitive procurement process as a result of relying on State procurement exemptions which do not apply to this Federal award. Cause: The Town did not follow its documented procurement policies and procedures. Effect: The Town is not in compliance with Federal procurement requirements. Questioned Costs: $49,990 Repeat Finding from Prior Year: Yes; Finding 2023-002. Recommendation: The Town should review and follow its procurement procedures to ensure that competitive procurement procedures are performed on all applicable contracts for goods and services charged to Federal awards. Views of Responsible Official: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2024-001 U.S. Department of the Treasury Passed-through Norfolk County, Massachusetts 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 200.319, procurements must provide for full and open competition. Condition: Two vendors were awarded a contract without a competitive procurement process as a result of relying on State procurement exemptions which do not apply to this Federal award. Cause: The Town did not follow its documented procurement policies and procedures. Effect: The Town is not in compliance with Federal procurement requirements. Questioned Costs: $49,990 Repeat Finding from Prior Year: Yes; Finding 2023-002. Recommendation: The Town should review and follow its procurement procedures to ensure that competitive procurement procedures are performed on all applicable contracts for goods and services charged to Federal awards. Views of Responsible Official: Management agrees with the finding.
Town’s Response: The Town concurs with the audit finding and has begun implementing the corrective actions outlined below. 1. Policy Alignment o Revise the Town’s Procurement Policy to explicitly state that federal Uniform Guidance procurement standards supersede state exemptions when federal funds are used. 2. Procedural Controls o Require a funding source review step in the requisition process: if any portion of funding is federal, staff must apply federal standards. o Incorporate a mandatory compliance checklist for all federally funded procurements, including documentation of cost/price analysis, vendor selection, and conflict of interest certifications. 3. Training & Awareness o Conduct annual training for the Procurement Manager. o Provide written desk guides / “quick reference sheets” for federal vs. state thresholds and documentation requirements. 4. Oversight & Monitoring o Director of Finance/Assistant Finance Director to review and approve all federal-funded procurement files prior to award. o Establish quarterly compliance monitoring of federal procurements, with results reported to the Town Manager via Monthly reports submitted. 5. System Enhancements o Explore Munis configuration options to flag federally funded accounts during requisition entry, ensuring the correct rules are applied. 566 Washington Street, P.O. Box 40, Norwood, MA 02062-0040 Phone No. (781) 762-1240 Responsible Parties: Procurement Manager – day-to-day compliance Completion Date: Policy revision and training to be completed by December 31, 2025. Compliance checklist implementation and monitoring effective immediately for all new procurements using federal funds. Submitted By: Jeffrey O’Neill Director of Finance & Town Accountant
2023-002
FAC accepted this audit on September 19, 2025 — management decision was due March 19, 2026.
2023-002 Improve Documentation and Controls Over Procurement Federal Program(s) Information Federal Agency: U.S. Department of the Treasury Cluster/Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds AL Number(s): 21.027 Award Year: 2023 Compliance Requirement: Procurement Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement Per 2 CFR 200.318–200.327, non-federal entities must use their own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards set forth in the Uniform Guidance. In some cases, the Uniform Guidance may establish stricter requirements for procurement, including the need for full and open competition, documentation of procurement history, and specific justifications for sole source or exempt procurements. Entities must comply with the stricter requirements when procuring services. Condition and Context During testing of procurement transactions, the Town was unable to provide documentation supporting procurement for one selected vendor for a design project. The project proceeded with an existing provider for the Town engaged on other projects rather than following the policies and procedures for soliciting competitive sealed bids or proposals for the specific project under the grant. The Procurement Manager relied on an exemption for engineering services under Massachusetts procurement law, which in this case is less restrictive than Uniform Guidance requirements. As a result, the Town did not comply with the federal procurement standards applicable to this transaction. Cause The Town’s internal controls over procurement did not ensure that federal requirements under Uniform Guidance were followed when state and federal rules differed. The Procurement Manager applied state-level exemptions rather than adhering to more restrictive federal standards. Effect or Potential Effect The absence of procurement documentation and use of state exemptions rather than federal requirements increase the risk of non-compliance and may result in unallowable costs. Questioned costs reported as a result of this transaction are $110,901. TOWN OF NORWOOD, MASSACHUSETTS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUED) FOR THE YEAR ENDED JUNE 30, 2023 13 SECTION III - FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (CONTINUED) 2023-002 Improve Documentation and Controls Over Procurement (Continued) Recommendation The Town strengthen its internal controls over procurement to ensure compliance with Uniform Guidance requirements, regardless of state law exemptions. The Town should ensure adequate documentation is retained for all federally funded procurements, and that procurement staff are trained on the distinction between federal and state procurement requirements. Views of Responsible Officials Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.
Show full finding ▾Hide full finding ▴2023-002 Improve Documentation and Controls Over Procurement Federal Program(s) Information Federal Agency: U.S. Department of the Treasury Cluster/Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds AL Number(s): 21.027 Award Year: 2023 Compliance Requirement: Procurement Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement Per 2 CFR 200.318–200.327, non-federal entities must use their own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards set forth in the Uniform Guidance. In some cases, the Uniform Guidance may establish stricter requirements for procurement, including the need for full and open competition, documentation of procurement history, and specific justifications for sole source or exempt procurements. Entities must comply with the stricter requirements when procuring services. Condition and Context During testing of procurement transactions, the Town was unable to provide documentation supporting procurement for one selected vendor for a design project. The project proceeded with an existing provider for the Town engaged on other projects rather than following the policies and procedures for soliciting competitive sealed bids or proposals for the specific project under the grant. The Procurement Manager relied on an exemption for engineering services under Massachusetts procurement law, which in this case is less restrictive than Uniform Guidance requirements. As a result, the Town did not comply with the federal procurement standards applicable to this transaction. Cause The Town’s internal controls over procurement did not ensure that federal requirements under Uniform Guidance were followed when state and federal rules differed. The Procurement Manager applied state-level exemptions rather than adhering to more restrictive federal standards. Effect or Potential Effect The absence of procurement documentation and use of state exemptions rather than federal requirements increase the risk of non-compliance and may result in unallowable costs. Questioned costs reported as a result of this transaction are $110,901. TOWN OF NORWOOD, MASSACHUSETTS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUED) FOR THE YEAR ENDED JUNE 30, 2023 13 SECTION III - FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (CONTINUED) 2023-002 Improve Documentation and Controls Over Procurement (Continued) Recommendation The Town strengthen its internal controls over procurement to ensure compliance with Uniform Guidance requirements, regardless of state law exemptions. The Town should ensure adequate documentation is retained for all federally funded procurements, and that procurement staff are trained on the distinction between federal and state procurement requirements. Views of Responsible Officials Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.
Corrective Action Plan Federal Procurement Audit Finding 2023-002 Town’s Response: The Town concurs with the audit finding and has begun implementing the corrective actions outlined below. 1. Policy Alignment o Revise the Town’s Procurement Policy to explicitly state that federal Uniform Guidance procurement standards supersede state exemptions when federal funds are used. 2. Procedural Controls o Require a funding source review step in the requisition process: if any portion of funding is federal, staff must apply federal standards. o Incorporate a mandatory compliance checklist for all federally funded procurements, including documentation of cost/price analysis, vendor selection, and conflict of interest certifications. 3. Training & Awareness o Conduct annual training for the Procurement Manager. o Provide written desk guides / “quick reference sheets” for federal vs. state thresholds and documentation requirements. 4. Oversight & Monitoring o Director of Finance/Assistant Finance Director to review and approve all federal-funded procurement files prior to award. o Establish quarterly compliance monitoring of federal procurements, with results reported to the Town Manager via Monthly reports submitted. 5. System Enhancements o Explore Munis configuration options to flag federally funded accounts during requisition entry, ensuring the correct rules are applied.
FAC accepted this audit on March 28, 2018 — management decision was due September 28, 2018.
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