TOWN OF WINCHENDONLocal Government

2024-004 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster – ALN(s) 84.027 & 84.173 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 were not filed in a timely manner for Special Education Cluster grants. Cause: A lack of a formal review process for grants in prior years. Effect: The School is not in compliance with federal grant reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Yes, Finding 2022-001 and 2023-004. Recommendation: We recommend that final financial reports be completed and submitted to the pass-through agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.

2024-005 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 Material Weakness in Internal Controls over Compliance Criteria: Per the 2024 OMB Compliance Supplement, capital expenditures for general and special purpose equipment purchases and improvements to land, buildings and equipment are subject to prior approval by the pass-through entity. Condition: The Schools’ files did not include documentation of pre-approval for the purchase and installation of alarm systems and security cameras. Cause: A lack of central grant recordkeeping for all federal awards. Effect: The Town did not comply with grant approval requirements for purchases totaling $70,424. Questioned Costs: None. Repeat Finding from Prior Year: No. Recommendation: The Town should implement procedures to maintain all required grant documentation, including pass-through agency approvals, for all grants. Views of Responsible Official: Management agrees with the finding.

2024-006 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: One Education Stabilization Fund final financial report has not been submitted that is overdue. Cause: Lack of procedures to timely report financial information to the pass-through agency. Effect: The Town is not in compliance with reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The School should implement procedures to file all reporting timely and accurately. Views of Responsible Official: Management agrees with the finding.

2024-007 U.S. Department of 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 200.328 of the Uniform Guidance, each recipient must report program outlays and program income on a cash or accrual basis, as prescribed by the federal agency. The compliance supplement identified 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. Condition: As of the March 31, 2024 reporting date, the Town’s Project and Expenditure report had reported cumulative expenditures that were approximately $29,900 less than what was recorded in the grant fund on the general ledger. Cause: The Town did not reconcile the Project and Expenditure report with the Town’s general ledger before submitting. Effect: The Town did not properly report grant expenditures in the Project and Expenditure reporting. Questioned Costs: None Repeat Finding from Prior Year: Yes; Finding 2023-008 Recommendation: The Town should implement procedures to reconcile the financial information in the Project and Expenditure reports to the Town’s general ledger before submission. Views of Responsible Official: Management agrees with the finding.

2023-004 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster – ALN(s) 84.027 & 84.173 COVID-19 - Special Education Cluster – ALN(s) 84.027X & 84.173X 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: Final financial reports were not filed in a timely manner for a Special Education Cluster grant. Cause: A lack of a formal review process for grants in prior years. Effect: The School is not in compliance with federal grant reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Finding 2022-001. Recommendation: We recommend that final financial reports be completed and submitted to the pass-through agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.

2023-005 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster – ALN(s) 84.027 & 84.173 COVID-19 - Special Education Cluster – ALN(s) 84.027X & 84.173X 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: Invoices were charged for services performed prior to the award approval dates by the pass-through agency. Cause: Invoices were not provided in a timely manner by vendors nor were services dates properly identified by the Town. Numerous payroll entries were recorded to correct prior year findings and close out grants with some payroll being outside the period. Effect: The Town expended funds outside of the period of performance which resulted in questioned costs. Questioned Costs: $36,266.50 Repeat Finding from Prior Year: Finding 2022-002. Recommendation: The Town 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.

2023-006 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster – ALN(s) 84.027 & 84.173 COVID-19 - Special Education Cluster – ALN(s) 84.027X & 84.173X Material Weakness in Internal Controls over Compliance and Compliance 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: Time and effort certifications were not maintained for grant employees’ whose salaries and wages were not supported by detailed time records. Cause: The School did not assign the preparation of federal payroll documentation to any employee. Effect: The School is not in compliance with applicable cost principles related to salaries and wages. Questioned Costs: $121,309.68 Repeat Finding from Prior Year: No Recommendation: The School should implement procedures to obtain time and effort certifications from grant employees whose wages are not supported with detailed time records. Time and effort certifications should be obtained on a semi-annual basis for employees whose work is solely for a single grant and on a monthly basis for employees whose work involves more than one grant or activity. Views of Responsible Official: Management agrees with the finding.

2023-007 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education COVID-19 – Education Stabilization Fund – ALN(s) 84.425D & 84.425U Significant Deficiency in Internal Controls over Compliance 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: Final financial report revenues and expenditures were overstated in the Town’s general ledger. Cause: Reconciliations are not properly performed to Town’s general ledger. Effect: The Town’s general ledger balances do not properly reflect federal grant balances. The reporting submitted to the pass-through agency was deemed to be accurate. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The School should reconcile the final financial reports to the Town’s general ledger prior to submission. Views of Responsible Official: Management agrees with the finding.

2023-008 U.S. Department of 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 agency. The compliance supplement identified 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. Condition: As of the March 31, 2023 reporting date, the Town’s Project and Expenditure report had reported cumulative expenditures that were approximately $134,000 more than what was recorded in the grant fund on the general ledger. In addition, obligations were overstated by approximately $85,000. Cause: The Town did not reconcile the Project and Expenditure report with the Town’s general ledger before submitting. Additionally, the Town did not have a clear understanding of reporting requirements for obligations. Effect: The Town did not properly report grant expenditures in the appropriate fund in the Town’s general ledger and obligations were overstated in the Project and Expenditure reporting. 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 before submission. Views of Responsible Official: Management agrees with the finding.

2022-001 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: 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: Final financial reports were not filed in a timely manner for a Special Education Cluster grant. Cause: A lack of a formal review process for grants in prior years. Effect: The School is not in compliance with federal grant reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Finding 2021-001. Recommendation: We recommend that final financial reports be completed and submitted to the pass-through agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.

2022-002 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: 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: Invoices and payroll were charged for services performed prior to the approval dates by the pass-through agency. Cause: Invoices were not provided in a timely manner by vendors nor were services dates properly identified by the Town. Numerous payroll entries were recorded to correct prior year findings and close out grants with some payroll being outside the period. Effect: The Town expended funds outside of the period of performance which resulted in questioned costs. Questioned Costs: $25,880.10 Recommendation: The Town 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.

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: Fiscal year 2019 and 2020 final financial reports were not filed in a timely manner for Title I Grants to Local Educational Agencies and Special Education Cluster grants, respectively. Cause: A lack of a formal review process for grants in prior years. Effect: The School is not in compliance with federal grant reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Finding 2020-001. Recommendation: We recommend that final financial reports be completed and submitted to the pass-through agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.

Criteria: Per 2 CFR section 200.430(i) of the Uniform Guidance, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Semiannual or monthly time and effort certifications are to be utilized if the non-federal entity?s records do not meet the related standards described in the Uniform Guidance. Condition: Time and effort certifications were not maintained for grant employees? whose salaries and wages were not supported by detailed time records. Cause: The School did not assign the preparation of federal payroll documentation to any employee. Effect: The School is not in compliance with applicable cost principles related to salaries and wages. Questioned Costs: None Repeat Finding from Prior Year: Finding 2020-002. Recommendation: The School should implement procedures to obtain time and effort certifications from grant employees whose wages are not supported with detailed time records. Time and effort certifications should be obtained on a semi-annual basis for employees whose work is solely for a single grant and on a monthly basis for employees whose work involves more than one grant or activity. 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: Invoices were charged for services performed prior to the approval date by the passthrough agency. Cause: Invoices were not provided in a timely manner by vendors nor were services dates properly identified by the Town. Effect: The Town expended funds outside of the period of performance which resulted in questioned costs. Questioned Costs: $64,375.17 Recommendation: The Town 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.

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 reports due during the fiscal year were submitted two and eight months after the submission due date for the Title I Grants to Local Educational Agencies and Special Education Cluster grants, respectively. Cause: A lack of a formal reconciliation and review process for grants in prior years. Effect: The School is not in compliance with federal grant reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Finding 2019-003. Recommendation: We recommend that final financial reports be completed and submitted to the pass-through agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.

Criteria: Per 2 CFR section 200.430(i) of the Uniform Guidance, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Semiannual or monthly time and effort certifications are to be utilized if the non-federal entity?s records do not meet the related standards described in the Uniform Guidance. Condition: Time and effort certifications were not maintained for grant employees? whose salaries and wages were not supported by detailed time records. Cause: The School did not assign the preparation of federal payroll documentation to any employee. Effect: The School is not in compliance with applicable cost principles related to salaries and wages. Questioned Costs: None Repeat Finding from Prior Year: Finding 2019-004. Recommendation: The School should implement procedures to obtain time and effort certifications from grant employees whose wages are not supported with detailed time records. Time and effort certifications should be obtained on a semi-annual basis for employees whose work is solely for a single grant and on a monthly basis for employees whose work involves more than one grant or activity. Views of Responsible Official: Management agrees with the 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. Cause: The School relied on State procurement exemptions which do not apply to Federal procurements. Effect: The School is not in compliance with Federal procurement requirements. Questioned Costs: $7,698.50 Repeat Finding from Prior Year: Finding 2019-005. Recommendation: The School should implement procedures to perform procurement procedures on all applicable contracts for goods and services. Views of Responsible Official: Management agrees with the 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 checks are not performed for all covered transactions. Cause: Lack of appropriate oversight resulted in required debarment checks not being performed. Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. Questioned Costs: None Repeat Finding from Prior Year: Finding 2019-006. Recommendation: The School 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.

Significant Deficiency in Internal Controls Over Compliance Criteria: Allowable costs of federal and state grants should be separately identified, charged and reconciled to the Town?s general ledger. Condition: Several grants had activity that was charged against the incorrect grant year accounts in the general ledger. These transactions were not corrected in a timely manner and a portion of these expenditures were not included in final financial reporting filed with the pass-through agency. Prior year grant surpluses and deficits exist on the Town?s general ledger for grants that have been closed out with the pass-through agency. Cause: A lack of a formal reconciliation and review process for grants. Effect: The School has filed many grants late and residual balances exist on the general ledger for grants that are closed. Questioned Costs: None Repeat Finding from Prior Year: Finding 2018-008. Recommendation: Formal reconciliation procedures should be implemented to reconcile grant activity to all grant accounts on the Town general ledger. Views of Responsible Official: Management agrees with the finding.

Significant Deficiency in Internal Controls Over Compliance Criteria: Required grant financial reporting should be submitted to the pass-through agency in an accurate and timely manner. Condition: Final reports filed during the year could not be obtained from the School. In past years, the amounts reported on final reports did not agree to the amounts as recorded in the Town?s general ledger. Cause: A lack of a formal reconciliation and review process for grants. Effect: The School has filed many grants late and amounts reported cannot be supported with the amounts recorded on the general ledger. Questioned Costs: None Repeat Finding from Prior Year: Finding 2018-009. Recommendation: We recommend that final financial reports be completed timely and reconciled to the general ledger before submitting to the pass-through agency. Views of Responsible Official: Management agrees with the finding.

Criteria: Per 2 CFR 200.430(i) of the Uniform Guidance, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Semi-annual or monthly time and effort certifications are to be utilized if the non-federal entity?s records do not meet the related standards described in the Uniform Guidance. Condition: Time and effort certifications were not maintained for grant employees? whose salaries and wages were not supported by detailed time records. Cause: The School did not assign the preparation of federal payroll documentation to any employee. Effect: The School is not in compliance with applicable cost principles related to salaries and wages. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The School should implement procedures to obtain time and effort certifications from grant employees whose wages are not supported with detailed time records. Time and effort certifications should be obtained on a semi-annual basis for employees whose work is solely for a single grant and on a monthly basis for employees whose work involves more than one grant or activity. Views of Responsible Official: Management agrees with the 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. Cause: The School relied on State procurement exemptions which do not apply to Federal procurements. Effect: The School is not in compliance with Federal procurement requirements. Questioned Costs: $60,581 Repeat Finding from Prior Year: No Recommendation: The School should implement procedures to perform procurement procedures on all applicable contracts for goods and services. Views of Responsible Official: Management agrees with the finding.

Significant Deficiency in Internal Controls Over Compliance Criteria: 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 checks are not performed for all covered transactions. Cause: Lack of appropriate oversight resulted in required debarment checks not being performed. Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The School 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.

Criteria: Local educational agencies operating schoolwide programs in any of its Title I schools must have a comprehensive needs assessment of the entire school; a comprehensive plan based on data from the needs assessment; and an annual evaluation of the results achieved by the school wide program. A schoolwide plan must include the following components: (1) schoolwide reform strategies, (2) instruction by highly qualified staff, (3) strategies to increase parental involvement, (4) additional support to students experiencing difficulty and (5) transition plans for assisting preschool children in the successful transition to the schoolwide program. Condition: The Town?s two elementary schools do not have a current, updated schoolwide plan that meets all requirements of the grant. Cause: The Schools schoolwide plans were not designed to meet all of the required elements. Effect: The School is not in compliance with applicable grant requirements to operate a schoolwide plan. Questioned Costs: None Repeat Finding from Prior Year: Finding 2018-010. Recommendation: The Title I grant administrator should work with the individual schools to develop schoolwide plans based on a current needs assessment that addresses all of the required elements. Views of Responsible Official: Management agrees with the finding.

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