TOWN OF PEMBROKE

2025-001 U.S. Department of the Treasury Direct Award and Passed through Plymouth County, Massachusetts COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – ALN 21.027 Significant Deficiency in Internal Controls over Compliance and Compliance Finding Criteria: 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. Per 2 CFR 200.1, an obligation is an order placed for property and services, contracts and subawards made, and similar transactions that require payment. Condition: Expenditures were not reconciled to the general ledger for reporting submitted to the U.S. Department of the Treasury. Cause: The Town did not have procedures in place to perform reconciliations of required grant reporting. Effect: It was determined that the Town recorded $310,000 of grant costs in the wrong period in the general ledger. Also, the Town overstated expenditures by approximately $89,000 in reporting submitted to the U.S. Department of the Treasury. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The Town should implement procedures to reconcile all federal reporting to the general ledger. Views of Responsible Official: Management agrees with the finding that a reconciliation to the general ledger did not take place. The $310,000 of grant costs were properly obligated at December 31, 2024 with expenditures recorded in a capital project fund.

2024-001 U.S. Department of the Treasury Passed-through the County of Plymouth, Massachusetts COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – ALN 21.027 Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Condition: One vendor was awarded four contracts without a competitive procurement process. Cause: The Town relied on State procurement exemptions which do not apply to Federal procurements. Effect: The Town is not in compliance with Federal procurement requirements. Questioned Costs: $509,016 Repeat Finding from Prior Year: No. Recommendation: The Town should implement procedures to perform competitive procurement procedures on all applicable contracts for goods and services charged to Federal awards. Views of Responsible Official: Management agrees with the finding.

Criteria: The Uniform Guidance requires written policies regarding cash management, determination of allowable costs, employee travel, procurement and subrecipient monitoring. Condition: The Town has not documented its policies regarding federal awards in writing. Cause: Lack of 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: Yes; Finding 2019-001. Recommendation: The Town should implement procedures to properly document all federal awards policies required by the Uniform Guidance. Views of Responsible Official: Management agrees with the finding.

Criteria: Per 2 CFR section 200.309 of the Uniform Guidance, a non-federal entity may charge to a Federal award only allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. Condition: Payroll was charged to the 2020 grant awards for pay periods prior to the approval date by the pass-through agency. Cause: The approval date was later than in prior years and the Town did not adequately plan grant expenditures as a result. Effect: The Town expended funds outside of the period of performance which resulted in questioned costs. Questioned Costs: $11,905 Repeat Finding from Prior Year: Yes; Finding 2019-002. Recommendation: The School should implement procedures to properly monitor award approval dates to ensure that goods and services charged to federal grants occur during the period of performance. Views of Responsible Official: Management agrees with the finding.

2019-001 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster ? CFDA 84.027 & 84.173 Criteria: The Uniform Guidance requires written policies regarding cash management, determination of allowable costs, employee travel, procurement and subrecipient monitoring. Condition: The Town has not documented its policies regarding federal awards in writing. Cause: Lack of 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 properly document all federal awards policies required by the Uniform Guidance. Views of Responsible Official: Management agrees with the finding.

2019-002 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster ? CFDA 84.027 & 84.173 Criteria: Grant funds may only be obligated upon the date of approval by the awarding agency through the end of the grant period. Condition: Payroll was charged to the 2019 grant awards for pay periods prior to the approval date by the pass-through agency. Cause: The approval date was later than in prior years and the Town did not adequately plan grant expenditures as a result. Effect: The Town expended funds outside of the period of performance which resulted in questioned costs. Questioned Costs: $16,913 Repeat Finding from Prior Year: No Recommendation: The School should implement procedures to properly monitor award approval dates to ensure that goods and services charged to federal grants occur during the period of performance. Views of Responsible Official: Management agrees with the finding.

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