Town of Westford, Massachusetts

2025-001 Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Assistance Listing Number: 21.027 Federal Award Identification Number: Not available Pass-Through Agency: Massachusetts Department of Revenue Pass-Through Number(s): ARPA#2FUNDS0330 Award Period: July 1, 2024 – June 30, 2025 Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters 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. Condition and Context: For one (1) of five (5) transactions tested, the Town had a documented verification that the vendor was not suspended or debarred. However, the verification was not dated/time-stamped. Therefore, we could not determine if the verification occurred prior to entering into transaction with the vendor. Questioned Costs: None. Cause: Procedures were not in place to document the timing of the verification that all vendors were not suspended or debarred from participation in federal programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification (or untimely verification) of vendors’ suspension or debarment status could cause federal grant funds to be expended to vendors that are excluded from participation in federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend procedures be strengthened to ensure that the timing of the verification of vendors’ suspension and debarment status is documented prior to executing transactions. Views of responsible officials and planned corrective actions: Management agrees with the finding.

2025-001 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) – 21.027 Recommendation: We recommend procedures be strengthened to ensure that documentation of verification of vendors’ suspension and debarment status is obtained prior to executing transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District has begun strengthening its procurement and accounts payable procedures to ensure vendor suspension and debarment verification is completed and documented before any contract is executed or transaction is processed with federal funds. Going forward, staff will verify vendor eligibility through SAM.gov or other required sources, retain evidence of the verification in the contract or procurement file, and use a standardized checklist to document compliance. The District will also review internal procedures with relevant staff and reinforce this requirement for all applicable federally funded purchases and contracts. Name(s) of the contact person(s) responsible for corrective action: Director of Finance, in coordination with Superintendent and Assistant Superintendent’s Office. Planned completion date for corrective action plan: April 30, 2026

2023-001 Improve Controls and Documentation Over Procurement Federal Agency: U.S. Department of the Treasury Cluster/Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Fund AL Numbers: 21.027 Award Year: 2023 Compliance Requirement: Procurement and Suspension and Debarment Type of Finding Compliance Internal Control over Compliance - Significant Deficiency Criteria or Specific Requirement Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Local municipalities are also required to use the same state procurement policies and procedures for federal funds as for non-federal funds, the Town is required to follow Massachusetts General Laws, Chapter (MGL) 30(b). MGL 30(b) requires the solicitation of three written or oral quotes for procurements of supplies between $10,000 and $49,999 and sealed bids or proposals for procurements of supplies $50,000 and over. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context There was no evidence to support that one disbursement properly followed the procurement process before payments for services were made to the vendor. Cause Weaknesses in the design and operation of controls. 2023-001 Improve Controls and Documentation Over Procurement (Continued) Effect or Potential Effect Due to the weaknesses in internal controls noted above, there is a risk that procurements may be awarded to vendors in a manner that is not consistent with federal procurement requirements. Known questioned costs are reported equal to $82,800, as follows: AL Questioned Number(s) Name of Federal Program or Cluster Costs 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Fund $82,800 Recommendation The Town should address the weaknesses in internal controls noted above in order to ensure that federal procurements are conducted in accordance with federal and state requirements. Views of Responsible Official Management agrees with the finding. Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

FINDING NO 2023-001 Significant deficiency in Internal Control Over Compliance – Improve Control and Documentation over Procurement Detail of Finding and Planned Corrective Action Plan During the single audit it was discovered that a summary of bid quotes for one of the items selected for procurement testing was not available. The project selected had initially begun in FY2017 before the Town implemented its procurement tracking system. The individual in charge of the project had resigned and although the Technology Department tried to do a search of the employee’s email, the documentation was not found. The Town maintains an online procurement folder (by fiscal year) available to all departments to store all procurement information by project. The Town views this particular finding as an unfortunate exception to the procedures and policies that it has put into place to procure everything properly during FY2020. The Town will continue to follow all procurement guidelines and store all procurement documentation in a centralized location so that this finding does not happen again. Contact Dan O’Donnell – Finance Director Jesse Beyer – Town Accountant Completion Date (expected) These procedures and policies mentioned above related to procurement are expected to be implemented before the completion of June 30, 2024.