City of BostonLocal Government

Prior Year Finding: No Federal Agency: U.S. Department Commerce Federal Program: Economic Development Cluster City Department: Mayor’s Office of Workforce Development (OWD) Assistance Listing Number: 11.307 Federal Award Number and Year: ED22HDQ3070112 (9/1/2022 – 9/1/2026) ED22HDQ3070112 (7/2/2024 – 9/1/2026) Compliance Requirement: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements. On March 8, 2025, FSRS.gov was retired, and all subaward reporting data and functionality transitioned to SAM.gov after that date. The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. §§ 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.) Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The OWD did not report subaward information in accordance with FFATA requirements. Context: The OWD informed auditors that no subawards were reported. Therefore, a sample was unavailable for testing. Cause: The OWD does not have procedures or controls regarding subaward reporting in accordance with FFATA requirements. Effect: Subawards were not reported in accordance with FFATA requirements. Questioned costs: None noted. Recommendation: We recommend the OWD develop procedures and internal controls to ensure that all required subawards are reported timely and accurately to SAM.gov no later than the end of the month following the month of issuance of each subaward. Views of responsible officials: Management agrees with the finding.

Prior Year Finding: No Federal Agency: Department of Housing and Urban Development Federal Program: Housing Opportunities for Persons with Aids City Department: Mayor’s Office of Housing (MOH) Assistance Listing Number: 14.241 Federal Award Number and Year: MAH21-F001 (8/6/2021-8/6/2024) MAH22-F001 (8/22/2022-8/22/2025) MAH23-F001 (7/13/2023-7/13/2026) MAH24-F001 (9/9/2024-9/9/2027) Compliance Requirement: Special Tests and Provisions – Housing Quality Standards Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: Per 24 CFR sections 574.310(b)(1)-(2), the following standards apply for all housing for which HOPWA funds are used under § 574.300(b)(3), (4), (5), and (8). 1) State and local requirements. Each recipient of assistance under this part must provide safe and sanitary housing that is in compliance with all applicable State and local housing codes, licensing requirements, and any other requirements in the jurisdiction in which the housing is located regarding the condition of the structure and the operation of the housing. 2) HUD housing standards. Except for such variations as are proposed by the grantee and approved by HUD, the housing must meet the standards for HUD housing in 24 CFR 5.703, except that: i. As applied to HOPWA, “HUD housing” in 24 CFR 5.703 means the units eligible persons occupy or will occupy, systems equipment that directly services those units, items and components within the primary and secondary means of egress from those units' doors to the public way, and common features related to the residential use of the building (e.g., the laundry room, community room, mail room). ii. Housing that continues to meet the HOPWA housing quality standards that applied when the eligible person(s) moved into that housing shall not be required to meet new or different standards under 24 CFR 5.703. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: MOH did not perform required housing quality inspections. Context: For seven of nine housing units selected for testing, MOH did not perform the required housing quality inspections. Cause: MOH’s procedures and internal controls were not sufficient to ensure that all required housing quality inspections were performed. Effect: Not performing the required housing quality inspections may result in the City providing support for housing units that do not meet housing quality standards. Questioned costs: Undetermined. Recommendation: We recommend MOH review and enhance internal controls and procedures to ensure that required inspections are performed timely. Views of responsible officials: Management agrees with the finding.

Prior Year Finding: No Federal Agency: Department of Education Federal Program: English Language Acquisition State Grants City Department: Boston Public Schools (BPS) Assistance Listing Number: 84.365 Federal Award Number and Year: S365A220021 (7/1/2022) S365A230021 (7/1/2023) S365A240021 (7/1/2024) Pass-through Agency: Massachusetts Department of Elementary and Secondary Education Pass-through Identifying Number and Year: 180-719236-2023-0035 (10/4/2022-9/30/2024) 180-000547-2024-0035 (9/12/2023-9/30/2025) 180-000547-2025-0035 (9/13/2024-9/30/2026) Compliance Requirement: Allowable Costs/Cost Principles – Time and Effort Reporting Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: 2 CFR Section 200.430 (8)(i) Standards for Documentation of Personnel Expenses states that: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: i. Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ii. Be incorporated into the official records of the non-Federal entity; iii. Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; iv. Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; v. Comply with the established accounting policies and practices of the non-Federal entity; vi. Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: BPS did not have evidence of time and effort certifications. Context: For eight of forty transactions tested, no documentation related to time and effort certifications was maintained by BPS. Cause: BPS controls were not sufficient to ensure that time and effort reporting was performed and documented, in accordance with federal requirements. Effect: There is an increased risk of charging unallowed costs to the program. Questioned costs: $21,174 Recommendation: We recommend BPS should enhance procedures, implement proper controls, and perform additional training over time and effort reporting. BPS should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Documentation should be readily available for audit. Views of responsible officials: Management agrees with the finding.

Prior Year Finding: No Federal Agency: Department of Education Federal Program: English Language Acquisition State Grants City Department: Boston Public Schools (BPS) Assistance Listing Number: 84.365 Federal Award Number and Year: S365A240021 (7/1/2024) Pass-through Agency: Massachusetts Department of Elementary and Secondary Education Pass-through Identifying Number and Year: 180-000547-2025-0035 (9/13/2024-9/30/2026) Compliance Requirement: Period of Performance, Allowable Costs/Cost Principles Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awardingagency or pass-through entity made the federal award that were authorized by the federal awardingagency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. 2 CFR Section 200.430 (8)(i) Standards for Documentation of Personnel Expenses states that: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: i. Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ii. Be incorporated into the official records of the non-Federal entity; iii. Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; iv. Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; v. Comply with the established accounting policies and practices of the non-Federal entity; vi. Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: BPS charged costs to the federal grant before the grant’s allowable period of performance. BPS also did not have evidence of timely supervisory review and approval of employee time summary reports. Context: For five of eight transactions tested during the beginning of the period of performance for the FY 2025 award, costs were incurred prior to the period of performance start date. The period of performance start date was September 13, 2024 and the expenditures were incurred on August 26, 2024. For eight of eight transactions tested during the beginning of the period of performance for the FY 2025 award, the payroll department time summary report was not signed and approved timely by the Department head. The department time summary reports were signed and approved subsequent to selection by auditors, approximately sixteen months after the end of the pay period. Cause: BPS’ procedures and internal controls were not operating effectively to ensure that expenditures were charged to the correct grant year. BPS’ controls were not sufficient to ensure that time and effort reporting was performed and documented in a timely manner, in accordance with federal requirements. Effect: Costs could be deemed unallowable by the awarding agency if funds are expended prior to the allowable period of performance. There is an increased risk of charging unallowed costs to the program. Questioned costs: Below the reportable threshold. Recommendation: We recommend BPS review and enhance its procedures and internal controls to ensure it charges expenditures to the program that are incurred within an award’s allowable period of performance. BPS should enhance procedures, implement proper controls, and perform additional training over time and effort reporting. BPS should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Documentation should be readily available for audit. Views of responsible officials: Management agrees with the finding.

Prior Year Finding: No Federal Agency: Department of Education Federal Program: English Language Acquisition State Grants City Department: Boston Public Schools (BPS) Assistance Listing Number: 84.365 Federal Award Number and Year: S365A220021 (7/1/2022) S365A230021 (7/1/2023) S365A240021 (7/1/2024) Pass-through Agency: Massachusetts Department of Elementary and Secondary Education Pass-through Identifying Number and Year: 180-719236-2023-0035 (10/4/2022-9/30/2024) 180-000547-2024-0035 (9/12/2023-9/30/2025) 180-000547-2025-0035 (9/13/2024-9/30/2026) Compliance Requirement: Special Tests and Provisions – Participation of Private School Children Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance: For programs under Title VIII of the ESEA (Assistance Listing 84.011, 84.365, 84.367, and 84.424), an agency, consortium, or entity receiving financial assistance under an applicable program must provide eligible private school children and their teachers or other education personnel with equitable services or other benefits under the program. Before an agency, consortium, or entity makes any decision that affects the opportunity of eligible private school children, teachers, and other educational personnel to participate, the agency, consortium, or entity must engage in timely and meaningful consultation with private school officials. Expenditures for services and benefits to eligible private school children and their teachers and other education personnel must be equal on a per-pupil basis to the expenditures for participating public school children and their teachers and other educational personnel, taking into account the number and education needs of the children, teachers and other education personnel to be services (Section 8501 of ESEA (20 USC 7881); 34 CFR sections 299.6 through 299.9). The control of funds used to provide equitable services to eligible private school students, teachers and other educational personnel, and families, and title to materials, equipment, and property purchased with those funds must be in a public agency and the public agency must administer the funds, materials, equipment, and property. The provision of equitable services must be by employees of a public agency or through a contract by the public agency with an individual, association, agency, or organization that is independent of the private school. The contract must be under the control of the public agency (Sections 1117(d), and 8501(d) of ESEA (20 USC 6320(d), and 7881(d); section 18005(b) of the CARES Act; 34 CFR sections 76.661, 200.64(b)(3), 200.67, and 299.9). Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: BPS did not retain the correspondence with private schools to support the student counts reported in their enrollment calculation. Context: For five of five private schools selected for testing, BPS was unable to provide documentation to support the student counts for private school children. Cause: BPS’ procedures and internal controls were not sufficient to ensure that all supporting documentation relating to compliance with providing equitable services for eligible private school children is maintained. Effect: BPS is potentially using inaccurate or incomplete data when calculating the amount of funds available for equitable services for eligible private school children. Questioned costs: Undetermined. Recommendation: We recommend BPS review and enhance internal controls and procedures to ensure that they retain copies of correspondence with private schools to ensure completeness and accuracy of the calculation. Views of responsible officials: Management agrees with the finding.

Prior Year Finding: 2024-009 Federal Agency: Department of Education Federal Program: Student Support and Academic Enrichment City Department: Boston Public Schools (BPS) Assistance Listing Number: 84.424 Federal Award Number and Year: S424A220022 (7/1/2022) S424A230022 (7/1/2023) S424A240022 (7/1/2024) Pass-through Agency: Massachusetts Department of Elementary and Secondary Education Pass-through Identifying Number and Year: 309-719226-2023-0035 (10/4/2022-9/30/2024) 309-000548-2024-0035 (9/12/2023-9/30/2025) 309-000548-2025-0035 (9/13/2024-9/30/2026) Compliance Requirement: Special Tests and Provisions – Participation of Private School Children Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or specific requirement: Compliance: For programs under Title VIII of the ESEA (Assistance Listing 84.011, 84.365, 84.367, and 84.424), an agency, consortium, or entity receiving financial assistance under an applicable program must provide eligible private school children and their teachers or other education personnel with equitable services or other benefits under the program. Before an agency, consortium, or entity makes any decision that affects the opportunity of eligible private school children, teachers, and other educational personnel to participate, the agency, consortium, or entity must engage in timely and meaningful consultation with private school officials. Expenditures for services and benefits to eligible private school children and their teachers and other education personnel must be equal on a per-pupil basis to the expenditures for participating public school children and their teachers and other educational personnel, taking into account the number and education needs of the children, teachers and other education personnel to be services (Section 8501 of ESEA (20 USC 7881); 34 CFR sections 299.6 through 299.9). The control of funds used to provide equitable services to eligible private school students, teachers and other educational personnel, and families, and title to materials, equipment, and property purchased with those funds must be in a public agency and the public agency must administer the funds, materials, equipment, and property. The provision of equitable services must be by employees of a public agency or through a contract by the public agency with an individual, association, agency, or organization that is independent of the private school. The contract must be under the control of the public agency (Sections 1117(d), and 8501(d) of ESEA (20 USC 6320(d), and 7881(d); section 18005(b) of the CARES Act; 34 CFR sections 76.661, 200.64(b)(3), 200.67, and 299.9). Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: BPS did not retain the correspondence with private schools to support the student counts reported in their enrollment calculation. Context: For seven of seven private schools selected for testing, BPS was unable to provide documentation to support the student counts for private school children. Cause: BPS’ procedures and internal controls were not sufficient to ensure that all supporting documentation relating to compliance with providing equitable services for eligible private school children is maintained. Effect: BPS is potentially using inaccurate or incomplete data when calculating the amount of funds available for equitable services for eligible private school children. Questioned costs: Undetermined. Recommendation: We recommend BPS review and enhance internal controls and procedures to ensure that they retain copies of correspondence with private schools to ensure completeness and accuracy of the calculation. Views of responsible officials: Management agrees with the finding.

Prior Year Finding: No Federal Agency: Department of Homeland Security Federal Program: Homeland Security Grant Program (HSGP) City Department: Mayor’s Office of Emergency Management (OEM) Assistance Listing Number: 97.067 Federal Award Number and Year: UASIFFY21 (2/8/2024-6/30/2025) UASIFFY22 (10/26/2022-6/30/2025) UASIFFY23 (10/15/2023-6/30/2026) Pass-Through Agency: Massachusetts Executive Office of Public Safety and Security Pass-Through Identifying Number and Year: BOSTONFFY21UASI (2/8/2024-6/30/2025) BOSTONFFY2022UASI (10/26/2022-6/30/2025) BOSTONFFY23UASI (10/24/2023-6/30/2026) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per 2 CFR section 200.332(a) - Requirements for Pass-Through Entities states, in part, that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: OEM omitted required federal award information from subawards it issued to their subrecipients. Context: For five of five subawards selected for testing, the subaward agreement did not include the federal award identification number and the federal award date for when the Federal agency awarded the funds to the prime recipient. Cause: OEM’s procedures and internal controls were not sufficient to ensure that subawards included all required information in accordance with 2 CFR 200.332. Effect: Noncompliance with subrecipient monitoring requirements occurred. Additionally, excluding required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program information and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Questioned costs: Undetermined. Recommendation: We recommend OEM review and enhance internal controls and procedures to ensure that required information is included in its subawards. Views of responsible officials: Management agrees with the finding.

Finding number: 2024-003 Federal agency: U.S. Department of Agriculture Pass-through agency: Commonwealth Department of Elementary and Second Education Program: Child Nutrition Cluster – National School Lunch Program ALN #: 10.555 Award number: 13-035 Award year: July 1, 2023 to June 30, 2024 Finding: Internal Control and Compliance over Allowability and Reporting Prior Year Finding: Yes; 2023-003 Type of Finding: Significant Deficiency and Noncompliance Criteria Allowability: Reimbursement for meals served is not based on costs; it is determined solely by applying the applicable meals times rates formula. Financial Reporting: a. Claims for Reimbursement SFAs and sponsors must submit monthly claims for reimbursement for meals and snacks served to eligible students within 60 days following the last day of the month covered by the claim (7 CFR sections 210.8, 220.11, 215.10, and 225.15(c). The state agency has an additional 30 days to submit a consolidated report to FNS (7 CFR 210.5(d), 220.13(b)(2), 215.11(c)(2), and 225.8). b. Recordkeeping Each month’s claim for reimbursement and all data used in the claims review process must be maintained on file. Accurate records must be maintained justifying all meals claimed and documenting that all Program funds were spent only on allowable Child Nutrition Program costs. Failure to maintain such records may be grounds for denial of reimbursement for meals served and/or administrative costs claimed during the period covered by the records in question. Records are required to be retained for a period of three years after submission of the final Claim for Reimbursement for the fiscal year. Or, if audit findings have not been resolved, the records must be retained beyond the three-year period aslong as required for the resolution of the issues raised by the audit. School food authorities are required to make the information available to the Department and the state agency upon request. Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our completeness and accuracy testing of the City of Boston Public Schools Food and Nutrition Services (FNS) monthly claims for reimbursement and recordkeeping, which included the allowability of meals reimbursed, we noted that edit checks were performed and documented monthly at the school site level confirming meal count reports. However, out of a sample of 60 days across 12 schools, there were 14 days across 7 schools that did not agree to the underlying manual tally sheets. Additionally, out of a sample of 12 monthly Field Coordinator reviews across 72 school sites, there were 3 reviews where the City was unable to provide evidence that the Field Coordinator’s review and approval took place. Cause This appears to be due to insufficient policies and procedures surrounding the claims for reimbursement and recordkeeping. Effect Meal count reports utilized for the monthly claims for reimbursement are not complete and accuracy, nor do they have complete and accurate underlying records to substantiate the meals requested for reimbursement. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs $108 Recommendation We recommend that FNS enhance their policies and procedures to include a more thorough review and approval of meal counts at the school level to ensure allowability as well as completeness and accuracy of the meal counts submitted for reimbursement. Additionally, we recommend FNS re-enforce their policy to ensure underlying records are maintained in accordance with program requirements. View of Responsible Officials from the Auditee FNS agrees with the importance of accurate meal counting and claiming. Because most errors result from arithmetic or data entry mistakes when cafeteria staff record meals served on paper tally sheets and laterenter totals into the computer, we now require that all meals served in the cafeterias be recorded electronically in the POS system at the point of service. We are also exploring ways to use the electronic POS system to record meals that are served in classrooms. The monthly review of school edit check reports by the field coordinators is also now documented using a Google Form that each coordinator is required to complete each month for review by the financial analyst prior to submission of the claim. We will emphasize the importance of proper meal counting and retention of documents during training for cashiers and cafeteria managers.

Finding number: 2024-004 Federal agency: U.S. Department of Agriculture Pass-through agency: Commonwealth Department of Elementary and Second Education Program: Child and Adult Care Food Program ALN #: 10.558 Award number: 13-035-CF-815 Award year: July 1, 2023 to June 30, 2024 Finding: Internal Control over Allowability Prior Year Finding: No Type of Finding: Significant Deficiency Criteria Reimbursement for Operating Costs of Child and Adult Care Centers CACFP centers and sponsors of centers shall be reimbursed solely according to the meals-times-rates formula outlined in II, “Program Procedures.” Costs claimed by the institution as operating costs must be related to preparing and serving meals to children and/or adults under the CACFP (7 CFR 226.11(c) and definition of “operating costs” in 7 CFR 226.2). Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing over the allowability of meals reimbursed, we noted that edit checks were performed and documented monthly at the school site level confirming meal count reports. However, out of a sample of 12 monthly Field Coordinator reviews across 72 school sites, there were 3 reviews where the City was unable to provide evidence that the Field Coordinator’s review and approval took place. Cause Field Coordinator edit checks were not precise enough to detect meal count differences for those sites which use a hardcopy tally sheet to count meals priors to entering into the POS system. Additionally, the City was unable to provide documentation showing that the Field Coordinator's review and approval took place in cases. This appears to be due to an insufficient process for documenting and retaining evidence of the Field Coordinator's monthly review. Effect Meal count reports utilized for the monthly claims for reimbursement are not complete and accuracy, nor do they have complete and accurate underlying records to substantiate the meals requested for reimbursement. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs None Recommendation We recommend that FNS enhance their policies and procedures to include a more thorough review and approval of meal counts at the school level to ensure allowability as well as completeness and accuracy of the meal counts submitted for reimbursement. Additionally, we recommend FNS re-enforce their policy to ensure underlying records are maintained in accordance with program requirements. View of Responsible Officials from the Auditee FNS agrees with the importance of accurate meal counting and claiming. We have implemented a new standard operating procedure for after-school supper meals served under CACFP that includes more thorough review of meal counts and related documentation prior to submission of the claim, monthly documentation of the edit check review by Field Coordinators using a Google Form, and procedures for holding program and site-based staff accountable for correctly documenting meal counts and submitting paperwork in a timely manner.

Finding number: 2024-005 Federal agency: U.S. Department of Housing and Urban Development Pass-through agency: N/A – Direct Funding Program: CDBG Entitlement/Special Purpose Grants Cluster ALN #: 14.218 Award number: Various Award year: Various Finding: Internal Control over FFATA Reporting Prior Year Finding: No Type of Finding: Significant Deficiency Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No.109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reporting should be made in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of the Special Reporting for Federal Funding Accounting and Transparency Act (FFATA) reports, we were unable to verify the review and approval of the FFATA reports by the City Auditor’s Office for 7 out of 7 reports selected for testing. Additionally, we were unable to verify the reports were submitted timely. Cause This appears to be due to lack of a formal documented review over when the FFATA reports were approved and submitted. Effect The City Auditor’s Office has an insufficient process in place to ensure the timely filing of the FFATA reports. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation We recommend that the City Auditor’s Office re-enforce control procedures to ensure that the FFATA reports formal review, approval and submission is documented. View of Responsible Officials from the Auditee The City has performed reviews and approvals prior to FFATA reports being submitted, however it has been verbal due to the proximity of the individuals working on this activity. The City will implement Google Calendar meetings and email confirmations once review is completed so that there is documentation of review approval and submission of FFATA reports.

Finding number: 2024-006 Federal agency: U.S. Department of Education Pass-through agency: Commonwealth Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies ALN #: 84.010 Award number: 0305-000549-2024-0035 Award year: September 12, 2023 to September 30, 2025 Finding: Internal Control and Compliance over Payroll Costs Prior Year Finding: Yes; 2023-006 Type of Finding: Significant Deficiency and Noncompliance Criteria In accordance with 2 CFR 200.430(i)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both Federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of allowable costs associated with payroll charges, we noted that the City of Boston Public Schools (BPS) documents time and attendance of employees on daily timesheets signed by the employee, and that these timesheets are approved by the Department Head/Supervisor on a Department Time Summary Report (DTSR). However, for our sample of 60 payroll transactions charged to the program, 3 transactions were not supported by a completed timesheet. Cause This appears to be due to an insufficient system for collecting, filing and maintaining supporting documentation for payroll transactions charged to Federal programs. Effect Insufficient review of payroll documentation increases the risk of inaccurate payroll costs being allocated to a grant award. Additionally, BPS is not in compliance with 2 CFR 200.430(i)(1) regarding documentation in support of salaries and wages charge to the federal program. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: Questioned costs of $13,382, for unsupported payroll charges, were charged to ALN # 84.010, Award No. 0305-000549-2024-0035 Recommendation We recommend that BPS re-enforce its policies and procedures to ensure their review of payroll charges and records are retained to ensure that all payroll costs charged to the federal program are supported by documentation as required by 2 CFR 200.430(i)(1). View of Responsible Officials from the Auditee BPS will add additional guidance around timesheet retention to the trainings for new timekeepers and at the annual payroll training held every August.

Finding number: 2024-007 Federal agency: U.S. Department of Education Pass-through agency: Commonwealth Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies ALN #: 84.010 Award number: Various Award year: Various Finding: Internal Control over Annual Report Card, High School Graduation Rate Prior Year Finding: Yes; 2023-009 Type of Finding: Significant Deficiency Criteria An SEA and its LEAs must report graduation rate data for all public high schools at the school, LEA, and state levels using the four-year adjusted cohort rate and, at an SEA’s or LEA’s discretion, one or more extended-year adjusted cohort rates. Graduation rate data must be reported both in the aggregate and disaggregated by the subgroups in Section 1111(c)(2) of the ESEA, homeless status, status as a child in foster care using a four-year adjusted cohort graduation rate (and any extended-year adjusted cohort rates) (ESEA sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25)(20 USC 6311(h)(1)(C)(iii)(II) and 7801(23), (25). Except as noted below, only students who earn a regular high school diploma may be counted as a graduate for purposes of calculating graduation rates. The term “regular high school diploma” means the standard high school diploma that is awarded to the preponderance of students in the state and that is fully aligned with the state standards (but not to alternate academic achievement standards for students with the most significant cognitive disabilities) or a higher diploma. A regular high school diploma does not include a recognized equivalent of a diploma, such as a general equivalency diploma (GED), certificate of completion, certificate of attendance, or similar lesser credential (ESEA, Section 8101(43) (20 USC 7801(43). An SEA may, but is not required to, award a state-defined alternate diploma for students with the most significant cognitive disabilities who take an alternate assessment aligned with alternate academic achievement standards. That diploma must be standards based, aligned with the state’s requirements for a regular high school diploma, and obtained within the time period for which the state ensures the availability of a free appropriate public education. If an SEA awards an alternate diploma, the SEA may count those students in its four-year and any extended-year adjusted cohort graduation rate, even if the student takes more than four years to receive the alternate diploma (ESEA, Section 8101(23)(A)(ii)(I)(bb), (25)(A)(ii)(I)(bb) (20 USC 7801(23)(A)(ii)(I)(bb), (25)(A)(ii)(I)(bb). To remove a student from the cohort, a school or LEA must confirm, in writing, that the student transferred out, emigrated to another country, transferred to a prison or juvenile facility, or is deceased. To confirm that a student transferred out, the school or LEA must have official written documentation that the student enrolled in another school or in an educational program that culminates in the award of a regular high school diploma. A student who is retained in grade, enrolls in a GED program, or leaves school for any other reason may not be counted as having transferred out for the purpose of calculating graduation rate and must remain in the adjusted cohort (ESEA sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25) (20 USC 6311(h)(1)(C)(iii)(II) and 7801(23), (25). Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition Per the City of Boston Public School’s (BPS) Student Withdrawal Procedures policy, school leaders are required to sign off, via a Google Form, prior to state data submissions in October, March and June that there is sufficient documentation to support all students who have withdrawn from their school. During our testing of 14 public high schools in which BPS is responsible for reporting graduation data, 6 school leaders did not submit their school’s certification for the data submission timeframe selected. Additionally, we noted 2 schools where the school leader provided a certification; however, their certification was not submitted prior to the state’s data submission. Lastly, we noted that for 2 of 60 students removed from their respective cohorts in the Student Information Management System (SIMS) selected for testing, the City of Boston Public Schools (BPS) could not provide any official written documentation that the student emigrated to another country, is deceased, or is enrolled in another school or in an education program that culminates in the award of a regular high school diploma. Cause This appears to be due to an insufficient system for collecting school leader’s certifications prior to state submission and insufficient review of supporting documentation before removal of students from the adjusted cohort graduation rate. Effect BPS is potentially misstating the number of students in the adjusted cohorts used by the Commonwealth of Massachusetts to determine the 4-year adjusted cohort graduation rate. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation BPS management should re-enforce their policy and the requirements with staff related to the removal of students from the adjusted cohorts used to determine the 4-year adjusted cohort graduation rate. In addition,BPS management should re-enforce their policies and procedures to obtain and monitor official written documentation of student transfers that is required to remove students from their respective cohort. View of Responsible Officials from the Auditee While all school leaders have not completed the certification form, BPS central office staff conduct reviews of all withdrawal documentation prior to state reporting submissions. For any student found to not have sufficient documentation in that testing, central office staff reach out to school leaders to alert them to the issue and instruct them to upload sufficient documentation. If that documentation is not uploaded by a certain date, the withdrawal codes for those students are changed to reflect a dropout status. In this year’s sample of 60 students, BPS was able to produce documentation for 58 students, a marked improvement from previous year’s samples.

Finding number: 2024-008 Federal agency: U.S. Department of Education Pass-through agency: Commonwealth Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies ALN #: 84.010 Award number: Various Award year: Various Finding: Internal Control over Assessment System Security Prior Year Finding: Yes; 2023-010 Type of Finding: Significant Deficiency Criteria SEAs, in consultation with LEAs, are required to establish and maintain an assessment system that is valid, reliable, and consistent with relevant professional and technical standards. Within their assessment system, SEAs must have policies and procedures to maintain test security and ensure that LEAs implement those policies and procedures (Title I, Section 1111(b)(2)(B)(iii) of the ESEA (20 USC 6311(b)(2)(B)(iii). Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition Each year schools who administer the Massachusetts Comprehensive Assessment System (MCAS) test are required to review and sign the Superintendent’s Assurance of Proper MCAS Test Administration form (Assurance Form), attesting their school will meet all the requirements and test administration protocols as outlined by the City of Boston Public Schools (BPS) and the Massachusetts Department of Secondary Education. During our testing of 16 schools in which BPS is responsible for administering the MCAS test, the form for one school were not obtained. Cause This appears to be due to an insufficient system for collecting and retaining school leader’s certifications ensuring they will meet all requirements and test administration protocols.Effect Schools are potentially not following all requirements and protocols related to the administration of the MCAS test and therefore not maintaining an assessment system that is valid, reliable and consistent with professional technical standards. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation BPS management should re-enforce their policy and the requirements to obtain and monitor official written documentation of school’s compliance with the administration of the MCAS test. View of Responsible Officials from the Auditee In addition to the superintendent’s assurance form, staff from the Office of Data and Accountability conduct announced and unannounced visits to schools during MCAS testing. These visits include observations of testing locations and test material storage, as well as support when questions arise. Observation notes are stored centrally.

Finding number: 2024-009 Federal agency: U.S. Department of Education Pass-through agency: Commonwealth Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies; Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants); and Student Support and Academic Enrichment Program ALN #: 84.010; 84.367; 84.424 Award number: Various Award year: Various Finding: Internal Control over Participation of Private School Children Prior Year Finding: Yes; 2023-008 Type of Finding: Significant Deficiency Criteria For programs funded under Title I, Part A (Assistance Listing 84.010), an LEA, after timely and meaningful consultation with private school officials, must provide equitable services to eligible private school children, their teachers, and their families. Eligible private school children are those who reside in a participating public school attendance area and have educational needs under Section 1115(c) of the ESEA (20 USC 6315(c). The amount of funds an LEA makes available for equitable services under Title I, Part A must be equal to the proportion of funds generated by private school children from low-income families who reside in participating public school attendance areas. An LEA must determine the proportional share available for services for eligible private school children based on the total amount of Title I funds received prior to any expenditures or transfers of funds within the program, such as reservations for administration, parental involvement, and district-wide activities (20 USC 6320(a)(4)(A). LEAs determine the proportional share by multiplying the proportion of children from low-income families who attend private schools and live in participating Title I attendance areas by the LEA’s total Title I allocation (including any funds transferred into Title I). For more information, see Title I, Part A of the ESEA: Providing Equitable Services to Eligible Private School Children, Teachers, and Families (October 7, 2019) (https://oese.ed.gov/files/2020/07/equitable-services-guidance100419.pdf). For programs under Title VIII of the ESEA (Assistance Listing 84.011, 84.365, 84.367, and 84.424), an agency, consortium, or entity receiving financial assistance under an applicable program must provide eligible private school children and their teachers or other education personnel with equitable services or other benefits under the program. Before an agency, consortium, or entity makes any decision that affects the opportunity of eligible private school children, teachers, and other educational personnel to participate, the agency, consortium, or entity must engage in timely and meaningful consultation with private school officials. Expenditures for services and benefits to eligible private school children and their teachers andother education personnel must be equal on a per-pupil basis to the expenditures for participating public school children and their teachers and other educational personnel, taking into account the number and education needs of the children, teachers and other education personnel to be services (Section 8501 of ESEA (20 USC 7881); 34 CFR sections 299.6 through 299.9). The control of funds used to provide equitable services to eligible private school students, teachers and other educational personnel, and families, and title to materials, equipment, and property purchased with those funds must be in a public agency and the public agency must administer the funds, materials, equipment, and property. The provision of equitable services must be by employees of a public agency or through a contract by the public agency with an individual, association, agency, or organization that is independent of the private school. The contract must be under the control of the public agency (Sections 1117(d), and 8501(d) of ESEA (20 USC 6320(d), and 7881(d); section 18005(b) of the CARES Act; 34 CFR sections 76.661, 200.64(b)(3), 200.67, and 299.9). Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition ALN 84.010: As part of the City of Boston Public School’s (BPS) policy over compliance with private school funding, we noted the data on children from low-income families who reside in the participating Title I public school attendance area and attend the private school is provided by the private school officials, which is then inputted and calculated by BPS on their Title I application. We were able to verify that the amount of funds available for equitable services for BPS was determined by multiplying the proportion of private school children from low-income families residing in participating public school attendance areas by the LEA’s total Title I, Part A allocation. However, we were unable to confirm completeness and accuracy of the eligible private school children counts used in the calculation as BPS did not retain the correspondence from the schools to support the data ultimately included in their calculation. ALN 84.367 and ALN 84.424: As part of BPS’ policy over compliance with private school funding, we noted the private school student count is provided by the private school officials, which is then inputted and calculated by BPS on their Title II and Title IV applications. We were able to verify that the amount of funds available for equitable services for BPS are equal on a per-pupil basis. However, we were unable to confirm completeness and accuracy of the eligible private school children counts used in the calculation as BPS did not retain the correspondence from the schools to support the data ultimately included in their calculation.Cause This appears to be due to an insufficient system in place to ensure retention of all supporting documentation related to compliance with providing equitable services for eligible private school children. Effect BPS is potentially using inaccurate or incomplete data when calculating the amount of funds available for equitable services for eligible private school children. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation When utilizing data provided by private school officials to determine the eligible private school child count, we recommend BPS retain copies of their correspondence to ensure completeness and accuracy of the calculation. View of Responsible Officials from the Auditee BPS requests that private schools wishing to participate in receiving Title funds submit detailed student eligibility information, and which is saved to an internal drive, with other supporting documentation pertaining to equitable services compliance. This adjustment to record keeping practice has been instituted beginning with the FY25 grant application cycle.

Finding number: 2024-010 Federal agency: U.S. Department of Education Pass-through agency: Commonwealth Department of Elementary and Secondary Education Program: Special Education (IDEA) Cluster ALN #: 84.027; 84.173 Award number: 240-714716-2023-0035; 0240-000558-2024-0035 Award year: October 3, 2022 to September 30, 2024; October 2, 2023 to September 30, 2025 Finding: Internal Control and Compliance over Payroll Costs Prior Year Finding: Yes; 2023-011 Type of Finding: Significant Deficiency and Noncompliance Criteria In accordance with 2 CFR 200.430(i)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both Federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that thenon-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of allowable costs associated with payroll charges, we noted that the City of Boston Public Schools (BPS) documents time and attendance of employees on daily timesheets signed by the employee, and that these timesheets are approved by the Department Head/Supervisor on a Department Time Summary Report (DTSR). However, for our sample of 60 payroll transactions charged to the program, 4 DTSR’s were not approved. Additionally, although the DTSR was approved, the transactions were not supported by a completed timesheet for an additional 3 selections. Cause This appears to be due to an insufficient system for collecting, filing and maintaining supporting documentation for payroll transactions charged to Federal programs. Effect Insufficient review of payroll documentation increases the risk of inaccurate payroll costs being allocated to a grant award. Additionally, BPS is not in compliance with 2 CFR 200.430(i)(1) regarding documentation in support of salaries and wages charge to the federal program. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: Questioned costs of $13,149, for unsupported payroll charges Recommendation We recommend that BPS re-enforce its policies and procedures to ensure their review of payroll charges and records are retained and documented to ensure that all payroll costs charged to the federal program are supported by documentation as required by 2 CFR 200.430(i)(1). View of Responsible Officials from the Auditee BPS will add additional guidance around timesheet retention to the trainings for new timekeepers and at the annual payroll training held every August. Additionally, BPS is exploring electronic timesheets, with a pilot focusing on staff that work at multiple sites.

Finding number: 2024-011 Federal agency: U.S. Department of Education Pass-through agency: Commonwealth Department of Elementary and Secondary Education Program: Student Support and Academic Enrichment Program ALN #: 84.424 Award number: 0309-000548-2024-0035 Award year: September 12, 2023 to September 30, 2025 Finding: Internal Control and Compliance over Period of Performance Prior Year Finding: No Type of Finding: Material Weakness and Material Noncompliance Criteria Period of Performance A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s 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 (2 CFR sections 200.308, 200.309, and 200.403(h). A period of performance may contain one or more budget periods. LEAs and SEAs must obligate funds during the 27 months, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. This maximum period includes a 15-month period of initial availability plus a 12-month period for carryover. Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of period of performance associated with those expenditures charged to grant awards which began during fiscal year 2024 and cost transfers, we noted noncompliance for 2 expenditures out of a sample of 4. Per review of the underlying vendor invoices, the service period for these expenditures started prior to the award start date of September 12, 2023.Cause This appears to be due to an insufficient review of invoices to ensure the underlying services performed by vendors are within the grant awards outlined grant period. Effect Insufficient review of vendor invoices increases the risk of costs being charged to a grant award outside its approved budget period. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: $1,250,864 Recommendation We recommend that the Boston Public Schools (BPS) re-enforce its policies and procedures to ensure their review of expenditures charged to the award also includes a detailed review of the underlying vendor service period. View of Responsible Officials from the Auditee BPS will take a multi-step approach to ensuring accuracy of spending to the grant award period: 1. Reinforce our existing practice of ensuring that period of service is reflected on Purchase Orders, which it was for the PO’s in question. 2. Working with major suppliers to ensure they understand the grant funded nature of their program and the eligible dates of service, which are outlined on the Purchase Order 3. Review / Update training for our Accounts Payable team on ensuring that the period of service on an invoice matches the period of service on the Purchase Order 4. Review / Update training for our State & Federal Grants, Programs, and Compliance teams to ensure that expenses are reviewed before the end of the grant period to ensure compliance with federal regulations.

Finding number: 2024-012 Federal agency: U.S. Department of Homeland Security Pass-through agency: N/A – Direct Funding Program: Staffing for Adequate Fire and Emergency Response (SAFER) ALN #: 97.083 Award number: EMW-2020-FF-00996 Award year: February 27, 2022 to February 26, 2025 Finding: Internal Control over Financial Reporting and Performance Reporting Prior Year Finding: Yes; 2023-015 and 2023-016 Type of Finding: Significant Deficiency Criteria Financial Reporting Per the Department of Homeland Security (DHS) Notice of Funding Opportunity (NOFO) for Fiscal Year 2020 Staffing for Adequate Fire and Emergency Response (SAFER) Grant Program, recipients of the SAFER Program grants are required to submit an FFR (SF-425) on a semi-annual basis. The FFR is to be submitted using the online FEMA GO based on the calendar year beginning with the period after the start of the period of performance. Grant recipients are required to submit an FFR throughout the entire period of performance of the grant. Reports are due: 1. No later than July 30 (for the period January 1 – June 30) 2. No later than January 30 (for the period July 1 – December 31) 3. Within 120 days after the end of the period of performance Performance Reporting Per the Department of Homeland Security (DHS) Notice of Funding Opportunity (NOFO) for Fiscal Year 2020 Staffing for Adequate Fire and Emergency Response (SAFER) Grant Program and the Federal Emergency Management Agency (FEMA) Grant Programs Directorate Information Bulletin No. 471, the recipient is responsible for completing and submitting a Programmatic Performance Report (PPR) using FEMA GO. For those awards which began in prior year, the PPR is due every six months based on the calendar year until the period of performance ends, and no later than 30 days after the six-month period end.Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition Financial Reporting During our testing of both semi-annual Federal Financial SF-425 (SF-425) reports, we were unable to verify approval of the SF-425 for reporting period ending 12/31/2023 by the Deputy Commissioner of the Boston Fire Department prior to submission. Performance Reporting Additionally, during our testing over both required semi-annual performance progress reports (PPRs) for fiscal year 2023, we noted the semi-annual PPR covering July 1, 2023 to December 31, 2023 was filed 65 days late on April 5, 2024. Additionally, we noted the semi-annual PPR covering January 1, 2024 to June 30, 2024 was filed one day late on August 1, 2024. Cause Financial Reporting This appears to be due to lack of a formal documented review over the semi-annual SF-425 reports. Progress Reporting This appears to be due to inadequate program detail to ensure complete and accurate information for reporting at the time of the submission deadlines. Effect Financial Reporting The Boston Fire Department (BFD) does not have effective internal controls over the Federal award to ensure the completeness and accuracy of the semi-annual SF-425 Financial Report. Performance Reporting The BFD has an insufficient process in place to ensure completeness and accuracy of the period expenditures and the timely filing of the semi-annual PPRs. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs NoneRecommendation We recommend that the BFD re-enforce control procedures to ensure that the SF-425 Financial Reports formal review and approval is documented. Additionally, we recommend that the BPD implement control procedures to ensure that the PPRs are filed timely and reviewed against supporting schedules to ensure completeness and accuracy of each report prior to submission. View of Responsible Officials from the Auditee BFD has taken considerable steps to incorporate and implement proper control procedures surrounding all grant related matters, i.e. programmatic and financial reporting and oversight. In August 2023, the department hired a Financial Grants Manager with more than ten years of experience working in municipal government with grants to ensure proper financial oversight is established and enforced. In February 2024, the department hired a Programmatic Grants Manager to ensure and implement proper policies and procedures regarding programmatic aspects of the department’s external funds. The department has acquired licenses for Airtable, an online platform for creating and sharing relational databases. It combines the features of a database and a spreadsheet, allowing users to store, organize, and collaborate on information about anything. This platform allows the department to track upcoming reporting deadlines, maintain information regarding grant related purchases, etc. The Programmatic and Financial Grants Manager have been reviewing all currently funded grants, to include SAFER, to ensure that the general ledger postings accurately reflect allowable costs so that when reports are filed the information reported in FEMA GO is accurate and complete. The Department projected that timely and accurate filing will be in effect no later than in January 2025 in order to complete the semi-annual reports due for the period ending December 31, 2024. The department had a high success rate in ensuring timely completion, approval and submission of financial reports for the most recently reporting period.

Findings number: 2023 003 Federal agency: U.S. Department of Agriculture Pass through agency: Commonwealth Department of Elementary and Second Education Program: Child Nutrition Cluster – National School Lunch Program ALN #: 10.555 Award number: Various Award year: Various Finding: Internal Control and Compliance over Allowability and Reporting Prior Year Finding: No Type of Finding: Material Weakness Criteria Allowability: Reimbursement for meals served is not based on costs; it is determined solely by applying the applicable meals times rates formula. Financial Reporting: a. Claims for Reimbursement SFAs and sponsors must submit monthly claims for reimbursement for meals and snacks served to eligible students within 60 days following the last day of the month covered by the claim (7 CFR sections 210.8, 220.11, 215.10, and 225.15(c)). The state agency has an additional 30 days to submit a consolidated report to FNS (7 CFR 210.5(d), 220.13(b)(2), 215.11(c)(2), and 225.8). b. Recordkeeping Each month’s claim for reimbursement and all data used in the claims review process must be maintained on file. Accurate records must be maintained justifying all meals claimed and documenting that all Program funds were spent only on allowable Child Nutrition Program costs. Failure to maintain such records may be grounds for denial of reimbursement for meals served and/or administrative costs claimed during the period covered by the records in question. Records are required to be retained for a period of three years after submission of the final Claim for Reimbursement for the fiscal year. Or, if audit findings have not been resolved, the records must be retained beyond the three year period as long as required for the resolution of the issues raised by the audit. School food authorities are required to make the information available to the Department and the state agency upon request. Additionally, 2 CFR 200.303 indicates that non Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our completeness and accuracy testing of the City of Boston Public Schools Food and Nutrition Services (FNS) monthly claims for reimbursement and recordkeeping, which included the allowability of meals reimbursed, we noted that edit checks were performed and documented monthly at the school site level confirming meal count reports. However, out of a sample of 60 days across 12 schools, there were 11 days across 4 schools that did not agree to the underlying manual tally sheets. Additionally, there was one school site that did not retain their tally sheets, and as such, we were unable to confirm the meals were accurate or allowable. Additionally, although a control was identified by the FNS documented policies, we were unable to verify meal counts were being reviewed at the individual school level by the site manager. Cause This appears to be due to insufficient policies and procedures surrounding the claims for reimbursement and recordkeeping. Effect Meal count reports utilized for the monthly claims for reimbursement are not complete and accuracy, nor do they have complete and accurate underlying records to substantiate the meals requested for reimbursement. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs $5,287 Recommendation We recommend that FNS enhance their policies and procedures to include a more thorough review and approval of meal counts at the school level to ensure allowability as well as completeness and accuracy of the meal counts submitted for reimbursement. Additionally, we recommend FNS re enforce their policy to ensure underlying records are maintained in accordance with program requirements. View of Responsible Officials from the Auditee FNS understands that this is a serious issue in schools that use paper tally sheets and has already begun to implement steps to improve the accuracy of meal counting and claiming in response to similar findings from a March 2023 on site DESE review of SY2022 23 meal claims. • Site managers were retrained on June 7, 2023, on procedures for proper counting and claiming of reimbursable meals, and reminded of the document retention policy. • Follow up training was provided during the 2023 24 school year, and more is planned for 2024 25. • In addition, FNS has been reducing the usage of paper tally sheets in favor of electronic records created in the POS system when students scan their ID card or enter their ID number as they are served a reimbursable meal. This greatly improves accuracy by eliminating the possibility of arithmetic or data entry errors that can occur when transferring information from paper sheets into the computer. • FNS has hired a financial analyst, whose duties include working with field coordinators (regional supervisors who oversee groups of schools) to ensure that claims entered into the Titan POS system are accurate, complete and backed up by appropriate documentation.

Finding number: 2023 004 Federal agency: U.S. Department of Agriculture Pass through agency: Commonwealth Department of Elementary and Second Education Program: Child Nutrition Cluster – National School Lunch Program Child Nutrition Cluster – Fresh Fruits and Vegetables ALN #: 10.555, 10.582 Award number: Various Award year: Various Finding: Internal Control over School Food Accounts Prior Year Finding: No Type of Finding: Significant Deficiency Criteria 7 CFR 210.14(a), 210.14(c), 210.19(a)(2), 215.7(d), 220.2 and 220.7(e)(1)(i) indicate that a School Food Authority (SFA) is required to account for all revenues and expenditures of its nonprofit school food service in accordance with State and Federal requirements. A SFA must operate its food services on a non profit basis; all revenue generated by the school food service must be used to operate and improve its food services. Additionally, 2 CFR 200.303 indicates that non Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of school food accounts, it was disclosed that the recording of food service federal reimbursement payments is reviewed and approved by the City of Boston Public Schools Food and Nutrition Services (FNS) Director of Finance. This monthly Cash Receipt Form is prepared and sent from the FNS Director of Finance to the City of Boston Treasury Department (Treasury) outlining the grant’s upcoming wire funds from their monthly claims submission request. However, during our testing of a sample size of three months, we noted the September 2022 cash receipt form was not submitted to Treasury for both the National School Lunch program and Fresh Fruits and Vegetables program. Additionally, we noted a variance of $8,676 between the March 2023 Cash Receipt Form, and the reimbursement request and revenue received for the Fresh Fruits and Vegetable program. Cause This appears to be due to insufficient policies and procedures to ensure the Cash Receipt Form is complete and accurate. Additionally, the policies lack an alternative control in cases where key management is unable to perform the control. Effect The FNS does not have effective internal controls over the SFA. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation We recommend that the FNS enhance its policies to ensure completeness and accuracy of the Cash Receipt Forms and include alternative procedures should the control operator be unavailable. View of Responsible Officials from the Auditee FNS would note that the cash receipt form is not the only control to ensure that school nutrition program revenues are correctly deposited in the school nutrition program account. The FNS Director of Finance also reviews the revenue deposited into the account on at least a monthly basis, compares this with a printed copy of the expected reimbursement amount that was submitted to DESE, writes and initials a confirmation of the deposit amount on the printed reimbursement report, and maintains this paperwork in a file. In the event of a discrepancy between the expected and received amounts, the FNS Director of Finance contacts DESE and/or the city treasury as needed to reconcile. So if a cash receipt form is not submitted or contains an error, any missing or incorrect deposits would be discovered and corrected. However, to reduce the possibility of errors or delays in depositing the funds, the FNS Director of Finance will ensure that the FNS Financial Analyst is able to complete the cash receipt form as a backup when necessary.

Finding number: 2023 005 Federal agency: U.S. Department of Treasury Pass through agency: N/A - Direct Program: COVID-19 Emergency Rental Assistance Program ALN #: 21.023 Award number: N/A Award year: January 1, 2021 to September 30, 2025 Finding: Internal Control and Compliance over Subrecipient Monitoring Prior Year Finding: No Type of Finding: Material Weakness Criteria According to 2 CFR 200.331 (b), a pass through entity must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring, which may include consideration of such factors as: • The subrecipient’s prior experience with the same or similar subawards; • The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; • Whether the subrecipient has new personnel or new or substantially changed systems; and • The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Also, according to 2 CFR 200.331 (d), a pass through entity must: • Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. • Follow up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass through entity detected through audits, on site reviews, and other means. Additionally, 2 CFR 200.303 indicates that non Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of subrecipient monitoring for a sample of 2 out of the population of 5 subrecipients, the Mayor's Office of Housing (MOH) was unable to provide documentation for either of the subrecipients showing that a formal risk evaluation had been performed. Cause This appears to be due to inadequate policies and procedures surrounding the initial risk assessment of the subrecipients. Effect The MOH does not have adequate controls over evaluating each subrecipient’s risk of noncompliance for purposes of determining appropriate subrecipient monitoring. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation We recommend that the MOH implement control procedures to ensure that each subrecipient is evaluated for risk of noncompliance to ensure appropriate subrecipient monitoring. View of Responsible Officials from the Auditee The City and the Mayor’s Office of Housing has reinforced all documented policies and procedures with staff to ensure all areas of compliance have appropriate backup documentation to demonstrate that pre-award risk has been assessed.

Finding number: 2023 006 Federal agency: U.S. Department of Education Pass through agency: Commonwealth Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies ALN #: 84.010 Award number: 305 532937 2022 0035; 305 719222 2023 0035 Award year: September 1, 2021 to June 30, 2023 Finding: Internal Control and Compliance over Payroll Costs Prior Year Finding: Yes; 2022 001 Type of Finding: Material Weakness Criteria In accordance with 2 CFR 200.430(i)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both Federally assisted and all other activities compensated by the non Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Additionally, 2 CFR 200.303 indicates that non Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of allowable costs associated with payroll charges, we noted that the City of Boston Public Schools (BPS) documents time and attendance of employees on daily timesheets signed by the employee, and that these timesheets are approved by the Department Head/Supervisor on a Department Time Summary Report (DTSR). However, for our sample of 40 payroll transactions charged to the program, 23 transactions were not supported by a completed timesheet. Additionally, we noted that the DTSR was either not located or not approved by the Department Head/Supervisor for 5 payroll transactions. Cause This appears to be due to an insufficient system for collecting, filing and maintaining supporting documentation for payroll transactions charged to Federal programs. Effect Insufficient review of payroll documentation increases the risk of inaccurate payroll costs being allocated to a grant award. Additionally, BPS is not in compliance with 2 CFR 200.430(i)(1) regarding documentation in support of salaries and wages charge to the federal program. The number of transactions that were not supported by a time sheet represent 57% of the selected population and indicate a systemic problem. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: Questioned costs of $65,817, for unsupported payroll charges, were charged to ALN # 84.010, Award No. 305 532937 2022 0035 and Award No. 305 719222 2023 0035. Recommendation We recommend that BPS re enforce its policies and procedures to ensure their review of payroll changes via signoff on the Department Time Summary is appropriately documented and records are retained to ensure that all payroll costs charged to the federal program are supported by documentation as required by 2 CFR 200.430(i)(1). View of Responsible Officials from the Auditee BPS has updated DTSR training and guidance for timekeepers to ensure that any similar technical issues are addressed quickly and manually adjusted if needed. Training was given in August 2024.

Finding number: 2023 007 Federal agency: U.S. Department of Education Pass through agency: Commonwealth Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies ALN #: 84.010 Award number: Various Award year: Various Finding: Internal Control and Compliance over Reporting Prior Year Finding: Yes; 2022-002 Type of Finding: Material Weakness Criteria The City of Boston Public Schools (BPS) receives funding from the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education (DESE). DESE sets policy for the grants and required reports. DESE issues guidance in Grants for Schools: Getting Them and Using them, A Procedural Manual. According to the DESE’s procedure manual, “At the conclusion of grant activities, recipients must submit a final financial report to the Department, accounting for the expenditure of funds received. Grants Management has developed an online process and standard form (FR1) for collecting this information. The FR1 form should be submitted to Grants Management within sixty (60) days of the end date of the grant. Grant recipients should file their reports after carefully reconciling all figures with their city auditor, town accountant, or agency business manager.” Additionally, 2 CFR 200.303 indicates that non Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our review of compliance with subrecipient reporting requirements for the Title I program, we noted that, for our sample of 6 of the population of 6 FR1 reports required to be filed in fiscal year 2023, all 6 reports were not filed. Cause This appears to be due to inadequate policies and procedures surrounding the filing of financial reports under the program. Effect BPS does not have effective internal controls over the Federal award in regard to the primary recipient’s Title I program reporting requirements. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation We recommend that BPS implement control procedures to ensure that the FR1 form be submitted to DESE Grants Management within sixty (60) days of the end date of the grant in accordance with the reporting requirements of the primary Federal recipient of the Title I program. View of Responsible Officials from the Auditee BPS is working with DESE to revise our control procedures with the switch to their new GEM$ grant management system to ensure we are meeting compliance with FR1 deadlines.

Finding number: 2023 008 Federal agency: U.S. Department of Education Pass through agency: Commonwealth Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies ALN #: 84.010 Award number: Various Award year: Various Finding: Internal Control and Compliance over Participation of Private School Children Prior Year Finding: No Type of Finding: Material Weakness Criteria For programs funded under Title I, Part A (Assistance Listing 84.010), an LEA, after timely and meaningful consultation with private school officials, must provide equitable services to eligible private school children, their teachers, and their families. Eligible private school children are those who reside in a participating public school attendance area and have educational needs under Section 1115(c) of the ESEA (20 USC 6315(c)). The amount of funds an LEA makes available for equitable services under Title I, Part A must be equal to the proportion of funds generated by private school children from low income families who reside in participating public school attendance areas. An LEA must determine the proportional share available for services for eligible private school children based on the total amount of Title I funds received prior to any expenditures or transfers of funds within the program, such as reservations for administration, parental involvement, and district wide activities (20 USC 6320(a)(4)(A)). LEAs determine the proportional share by multiplying the proportion of children from low income families who attend private schools and live in participating Title I attendance areas by the LEA’s total Title I allocation (including any funds transferred into Title I). For more information, see Title I, Part A of the ESEA: Providing Equitable Services to Eligible Private School Children, Teachers, and Families (October 7, 2019) (https://oese.ed.gov/files/2020/07/equitable services guidance100419.pdf). The control of funds used to provide equitable services to eligible private school students, teachers and other educational personnel, and families, and title to materials, equipment, and property purchased with those funds must be in a public agency and the public agency must administer the funds, materials, equipment, and property. The provision of equitable services must be by employees of a public agency or through a contract by the public agency with an individual, association, agency, or organization that is independent of the private school. The contract must be under the control of the public agency (Sections 1117(d), and 8501(d) of ESEA (20 USC 6320(d), and 7881(d); section 18005(b) of the CARES Act; 34 CFR sections 76.661, 200.64(b)(3), 200.67, and 299.9). Additionally, 2 CFR 200.303 indicates that non Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition As part of the City of Boston Public School’s (BPS) policy over compliance with private school funding, private school officials are required to fill out the Boston Public Schools: Non Public Grant Assurance and Participation Form attesting BPS provided timely and meaningful consultation with the school officials in making its determination. However, during our testing of 10 private schools in which BPS provides funding to eligible private school children, BPS was unable to locate the submitted form for one school. Additionally, for the 9 private schools where the form was provided, the authorized private school official certified that BPS did not provide timely and meaningful consultation before having made any decision that affected the participation of eligible private school children. Additionally, we were able to verify that the amount of funds available for equitable services for BPS was determined by multiplying the proportion of private school children from low income families residing in participating public school attendance areas by the LEA’s total Title I, Part A allocation. We noted the data on children from low income families who reside in the participating Title I public school attendance area and attend the private school is provided by the private school officials, which is then inputted and calculated by BPS on their Title I application. However, we were unable to confirm completeness and accuracy of the eligible private school children counts used in the calculation as BPS did not retain the correspondence from the schools to support the data ultimately included in their calculation. Cause This appears to be due to an insufficient system in place to ensure consultations are performed timely and all supporting documentation related to compliance with providing equitable services for eligible private school children. Effect BPS is not conducting timely consultations with private school officials in making its determination for private school funding and as such, private school programs are getting delayed. BPS is potentially using inaccurate or incomplete data when calculating the amount of funds available for equitable services for eligible private school children. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation BPS management should enhance their policy to include tracking of when consultations with private school officials are held to ensure timely and meaning consultation. Additionally, when utilizing data provided by private school officials to determine the eligible private school child count, we recommend BPS retain copies of their correspondence to ensure completeness and accuracy of the calculation. View of Responsible Officials from the Auditee BPS has implemented a revised consultation process for the FY24 FY25 cycle to ensure that the consultation process happens with fidelity and that records are properly stored.

Finding number: 2023 009 Federal agency: U.S. Department of Education Pass through agency: Commonwealth Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies ALN #: 84.010 Award number: Various Award year: Various Finding: Internal Control over Annual Report Card, High School Graduation Rate Prior Year Finding: Yes; 2022-003 Type of Finding: Material Weakness Criteria An SEA and its LEAs must report graduation rate data for all public high schools at the school, LEA, and state levels using the four year adjusted cohort rate and, at an SEA’s or LEA’s discretion, one or more extended year adjusted cohort rates. Graduation rate data must be reported both in the aggregate and disaggregated by the subgroups in Section 1111(c)(2) of the ESEA, homeless status, status as a child in foster care using a four year adjusted cohort graduation rate (and any extended year adjusted cohort rates) (ESEA sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25)(20 USC 6311(h)(1)(C)(iii)(II) and 7801(23), (25))). Except as noted below, only students who earn a regular high school diploma may be counted as a graduate for purposes of calculating graduation rates. The term “regular high school diploma” means the standard high school diploma that is awarded to the preponderance of students in the state and that is fully aligned with the state standards (but not to alternate academic achievement standards for students with the most significant cognitive disabilities) or a higher diploma. A regular high school diploma does not include a recognized equivalent of a diploma, such as a general equivalency diploma (GED), certificate of completion, certificate of attendance, or similar lesser credential (ESEA, Section 8101(43) (20 USC 7801(43))). An SEA may, but is not required to, award a state defined alternate diploma for students with the most significant cognitive disabilities who take an alternate assessment aligned with alternate academic achievement standards. That diploma must be standards based, aligned with the state’s requirements for a regular high school diploma, and obtained within the time period for which the state ensures the availability of a free appropriate public education. If an SEA awards an alternate diploma, the SEA may count those students in its four year and any extended year adjusted cohort graduation rate, even if the student takes more than four years to receive the alternate diploma (ESEA, Section 8101(23)(A)(ii)(I)(bb), (25)(A)(ii)(I)(bb) (20 USC 7801(23)(A)(ii)(I)(bb), (25)(A)(ii)(I)(bb))). To remove a student from the cohort, a school or LEA must confirm, in writing, that the student transferred out, emigrated to another country, transferred to a prison or juvenile facility, or is deceased. To confirm that a student transferred out, the school or LEA must have official written documentation that the student enrolled in another school or in an educational program that culminates in the award of a regular high school diploma. A student who is retained in grade, enrolls in a GED program, or leaves school for any other reason may not be counted as having transferred out for the purpose of calculating graduation rate and must remain in the adjusted cohort (ESEA sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25) (20 USC 6311(h)(1)(C)(iii)(II) and 7801(23), (25))). Additionally, 2 CFR 200.303 indicates that non Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition Per the City of Boston Public School’s (BPS) Student Withdrawal Procedures policy, school leaders are required to sign off, via a Google Form, prior to state data submissions in October, March and June that there is sufficient documentation to support all students who have withdrawn from their school. During our testing of 24 public high schools in which BPS is responsible for reporting graduation data, 13 school leaders did not submit their school’s certification for the data submission timeframe selected. Additionally, we noted 5 schools where the school leader provided a certification; however their certification was not submitted prior to the state’s data submission. Cause This appears to be due to an insufficient system for collecting school leader’s certifications prior to state submission. Effect BPS is potentially misstating the number of students in the adjusted cohorts used by the Commonwealth of Massachusetts to determine the 4 year adjusted cohort graduation rate. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation BPS management should re enforce their policy and the requirements with staff related to the removal of students from the adjusted cohorts used to determine the 4 year adjusted cohort graduation rate. In addition, BPS management should re enforce their policies and procedures to obtain and monitor official written documentation of student transfers that is required to remove students from their respective cohort. View of Responsible Officials from the Auditee The sign off form is only one part of the controls BPS has implemented. The student withdrawal team also reviews individual documentation for every student who has been withdrawn prior to the data certification, and they update the withdrawal code to be a dropout if there is not sufficient documentation. While, we did not have full sign off from school leaders, we did adjust individual withdrawal codes prior to submitting the data to the state. This is a new process that was put in place starting in the fall of 2022. We will continue to update training for school leaders around certification.

Finding number: 2023 010 Federal agency: U.S. Department of Education Pass through agency: Commonwealth Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies ALN #: 84.010 Award number: Various Award year: Various Finding: Internal Control and Compliance over Assessment System Security Prior Year Finding: No Type of Finding: Material Weakness Criteria SEAs, in consultation with LEAs, are required to establish and maintain an assessment system that is valid, reliable, and consistent with relevant professional and technical standards. Within their assessment system, SEAs must have policies and procedures to maintain test security and ensure that LEAs implement those policies and procedures (Title I, Section 1111(b)(2)(B)(iii) of the ESEA (20 USC 6311(b)(2)(B)(iii))). Additionally, 2 CFR 200.303 indicates that non Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition Each year schools who administer the Massachusetts Comprehensive Assessment System (MCAS) test are required to review and sign the Superintendent’s Assurance of Proper MCAS Test Administration form (Assurance Form), attesting their school will meet all the requirements and test administration protocols as outlined by the City of Boston Public Schools (BPS) and the Massachusetts Department of Secondary Education. During our testing of 26 schools in which BPS is responsible for administering the MCAS test, forms for 3 schools were not obtained. Cause This appears to be due to an insufficient system for collecting and retaining school leader’s certifications ensuring they will meet all requirements and test administration protocols. Effect Schools are potentially not following all requirements and protocols related to the administration of the MCAS test and therefore not maintaining an assessment system that is valid, reliable and consistent with professional technical standards. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation BPS management should re enforce their policy and the requirements to obtain and monitor official written documentation of school’s compliance with the administration of the MCAS test. View of Responsible Officials from the Auditee BPS takes testing security very seriously. We have a cross functional team that works with our schools to ensure that protocols are being followed. We will reinforce with our school leaders the need for them to promptly complete the certifications to that effect.

Finding number: 2023 011 Federal agency: U.S. Department of Education Pass through agency: Commonwealth Department of Elementary and Secondary Education Program: Special Education (IDEA) Cluster ALN #: 84.027; 84.173 Award number: 240 532934 2022 0035; 240 714716 2023 0035 Award year: August 23, 2021 to September 30, 2024 Finding: Internal Control over Payroll Costs and Period of Performance Prior Year Finding: No Type of Finding: Material Weakness Criteria Allowable Costs – Payroll In accordance with 2 CFR 200.430(i)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both Federally assisted and all other activities compensated by the non Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Period of Performance A non federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s 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 (2 CFR sections 200.308, 200.309, and 200.403(h)). A period of performance may contain one or more budget periods. LEAs and SEAs must obligate funds during the 27 months, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. This maximum period includes a 15 month period of initial availability plus a 12 month period for carryover. Additionally, 2 CFR 200.303 indicates that non Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of allowable costs and period of performance associated with payroll charges, we noted that the City of Boston Public Schools (BPS) documents time and attendance of employees on daily timesheets signed by the employee, and that these timesheets are approved by the Department Head/Supervisor on a Department Time Summary Report (DTSR). However, for 39 of our sample of 40 payroll transactions charged to the program, we noted that the DTSR was either not located or not approved by the Department Head/Supervisor. Cause This appears to be due to the insufficient retention and documentation over the review and approval of payroll charges. Effect Insufficient review of payroll documentation increases the risk of inaccurate payroll costs being allocated to a grant award. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation We recommend that BPS re enforce its policies and procedures to ensure their review of payroll changes via signoff on the Department Time Summary is appropriately documented and records are retained. View of Responsible Officials from the Auditee BPS has updated DTSR training and guidance for timekeepers to ensure that any similar technical issues are addressed quickly and manually adjusted if needed. Training was given in August 2024.

Finding number: 2023 012 Federal agency: U.S. Department of Education Pass through agency: Commonwealth Department of Elementary and Secondary Education Program: Special Education (IDEA) Cluster ALN #: 84.027; 84.173 Award number: Various Award year: Various Finding: Internal Control over Maintenance of Effort Prior Year Finding: No Type of Finding: Significant Deficiency Criteria LEAs – Local Maintenance of Effort (1) Eligibility Standard a. To meet the eligibility standard for an award for a fiscal year, the LEA must budget for the education of children with disabilities at least the same amount, from at least one of the following sources ,as the LEA spent for that purpose from the same source for the most recent fiscal year for which information is available: i. Local funds only; ii. The combination of state and local funds; iii. Local funds only on a per capita basis; or iv. The combination of state and local funds on a per capita basis. b. When determining the amount of funds that the LEA must budget to meet the requirement, the LEA may take into consideration, to the extent the information is available, the exceptions and adjustment provided in 34 CFR sections 300.204 and 300.205 that the LEA: i. Took in the intervening year or years between the most recent fiscal year for which information is available and the fiscal year for which the LEA is budgeting; and ii. Reasonably expects to take in the fiscal year for which the LEA is budgeting. c. Expenditures made from funds provided by the federal government for which the SEA is required to account to the federal government or for which the LEA is required to account to the federal government directly or through the SEA may not be considered in determining whether an LEA meets the eligibility standard (34 CFR section 300.203(a)). (2) Compliance Standard a. Except as provided in 34 CFR sections 300.204 and 300.205, funds provided to an LEA under IDEA, Part B must not be used to reduce the level of expenditures for the education of children with disabilities made by the LEA from local funds below the level of those expenditures for the preceding fiscal year. An LEA meets this standard if it does not reduce the level of expenditures for the education of children with disabilities made by the LEA from at least one of the following sources below the level of those expenditures from the same source for the preceding fiscal year, except as provided in 34 CFR sections 300.204 and 300.205: i. Local funds only; ii. The combination of state and local funds; iii. Local funds only on a per capita basis; or iv. The combination of state and local funds on a per capita basis. Expenditures made from funds provided by the federal government for which the SEA is required to account to the federal government or for which the LEA is required to account to the federal government directly or through the SEA may not be considered in determining whether an LEA meets the compliance standard (34 CFR section 300.203(b)). (3) § 300.204 Exception to maintenance of effort Notwithstanding the restriction in § 300.203(b), an LEA may reduce the level of expenditures by the LEA under Part B of the Act below the level of those expenditures for the preceding fiscal year if the reduction is attributable to any of the following: a. The voluntary departure, by retirement or otherwise, or departure for just cause, of special education or related services personnel. b. A decrease in the enrollment of children with disabilities. c. The termination of the obligation of the agency, consistent with this part, to provide a program of special education to a particular child with a disability that is an exceptionally costly program, as determined by the SEA, because the child— i. Has left the jurisdiction of the agency; ii. Has reached the age at which the obligation of the agency to provide FAPE to the child has terminated; or iii. No longer needs the program of special education. d. The termination of costly expenditures for long term purchases, such as the acquisition of equipment or the construction of school facilities. e. The assumption of cost by the high cost fund operated by the SEA under § 300.704(c). Additionally, 2 CFR 200.303 indicates that non Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing to confirm the City of Boston Public Schools (BPS) met Special Education (IDEA) Cluster’s maintenance of effort (MOE) Compliance Standard test, we noted there was four school closures during fiscal year 2023. This resulted in a decrease in the enrollment of children with disabilities, an allowable exception to the MOE calculation as noted above. However, BPS was unable to provide sufficient documentation calculating the actual decrease in the enrollment of children with disabilities and the associated dollar value impact on the MOE calculation. Cause This appears to be due to insufficient policy in place for tracking the MOE compliance and retention of documentation supporting allowable exceptions. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation We recommend that BPS re enforce its policies and procedures to ensure sufficient tracking and documentation is retained supporting all allowable exceptions for the maintenance of effort Compliance Standard requirement. View of Responsible Officials from the Auditee This is the first year BPS met maintenance of effort through the per pupil standard. We are revising our tracking and documentation for special education expenses to ensure that when we meet MOE through this standard we have kept appropriate records to meet MOE compliance requirements.

Finding number: 2023 013 Federal agency: U.S. Department of Education Pass through agency: Commonwealth Department of Elementary and Secondary Education Program: COVID 19 Education Stabilization Fund ALN #: 84.425D Award number: 119 532940 2022 0035 Award year: September 1, 2022 to June 30, 2024 Finding: Internal Control over Payroll Costs Prior Year Finding: No Type of Finding: Significant Deficiency Criteria In accordance with 2 CFR 200.430(i)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both Federally assisted and all other activities compensated by the non Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Additionally, 2 CFR 200.303 indicates that non Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of allowable costs associated with payroll charges, we noted that the City of Boston Public Schools (BPS) documents time and attendance of employees on daily timesheets signed by the employee, as well as weekly time and effort reporting worksheets. The timesheets are then reviewed alongside the bi weekly Department Time Summary Reports (DTSRs) and approved by the Department Head, ensuring appropriate salary and wage distribution. However, for one of our sample of 40 payroll transactions charged to the program, we noted that although the respective DTSR was approved by the Department Head and the employee signed their timesheet, the employee selected was missing from the DTSR. Cause This appears to be due to the review of the DTSR not being precise enough to ensure all employees are included and appropriately charged to the program. Effect Insufficient review of payroll documentation increases the risk of inaccurate payroll costs being allocated to a grant award. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation We recommend that BPS enhance its policies and procedures to include a more detailed review of the Department Time Summary to ensure that all payroll costs charged to the federal program are reviewed and approved. View of Responsible Officials from the Auditee We had a system error for the employee when they changed from temporary to permanent status that led to their time not correctly showing up in the DTSR document. This problem should have been flagged earlier by their department timekeeper for correction. BPS has updated DTSR training and guidance for timekeepers to ensure that any similar technical issues are addressed quickly and manually adjusted if needed.

Finding number: 2023 014 Federal agency: U.S. Department of Homeland Security Pass through agency: N/A – Direct Funding Program: Staffing for Adequate Fire and Emergency Response ALN #: 97.083 Award number: EMW 2020 FF 00996 Award year: February 27, 2022 to February 26, 2025 Finding: Internal Control over Payroll Prior Year Finding: No Type of Finding: Material Weakness Criteria In accordance with 2 CFR 200.430(i)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both Federally assisted and all other activities compensated by the non Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Additionally, 2 CFR 200.303 indicates that non Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of allowable costs associated with payroll charges, we noted the Boston Fire Department (BFD) provides a pay rate text file to the City of Boston Central Payroll Division to process stipend payments. The pay rate file is then uploaded into the City’s payroll system (HCM), which is used to process the fire fighter’s payroll. However, we noted there is no review process over the pay rate file to ensure accuracy of the rates. Cause This appears to be due to a lack of a formal control over the stipend pay rate process. Effect Insufficient review of payroll documentation increases the risk of inaccurate payroll costs being allocated to a grant award. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation We recommend BFD implement a formal process to ensure accuracy of stipend rates prior to upload into the City’s payroll system. View of Responsible Officials from the Auditee The City of Boston and The Boston Fire Department will implement additional internal controls over the review of pay rates. These additional internal controls will ensure that all pay rates are accurate and will include evidence of review and approval.

Finding number: 2023 015 Federal agency: U.S. Department of Homeland Security Pass through agency: N/A – Direct Funding Program: Staffing for Adequate Fire and Emergency Response ALN #: 97.083 Award number: EMW 2020 FF 00996 Award year: February 27, 2022 to February 26, 2025 Finding: Internal Control and Compliance over Financial Reporting Prior Year Finding: No Type of Finding: Material Weakness Criteria Per the Department of Homeland Security (DHS) Notice of Funding Opportunity (NOFO) for Fiscal Year 2020 Staffing for Adequate Fire and Emergency Response (SAFER) Grant Program, recipients of the SAFER Program grants are required to submit an FFR (SF 425) on a semi annual basis. The FFR is to be submitted using the online FEMA GO based on the calendar year beginning with the period after the start of the period of performance. Grant recipients are required to submit an FFR throughout the entire period of performance of the grant. Reports are due: 1. No later than July 30 (for the period January 1 – June 30) 2. No later than January 30 (for the period July 1 – December 31) 3. Within 120 days after the end of the period of performance Additionally, 2 CFR 200.303 indicates that non Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our review of controls in place with the semi annual SF 425 Financial Reporting requirement, we noted that for both our samples of the financial reports required to be filed in fiscal year 2023, there was a lack of an internal control over the filing of the reports in place during the fiscal year. During our review of compliance with the semi annual SF 425 Financial Reporting requirement, we noted that certain financial information within the semi annual report covering July 1, 2022 to December 31, 2022 could not be verified against the general ledger including Line 10e Federal Share of expenditures and Line 10g Total Federal Funds, both reporting $6,125,484. Additionally, we noted the semi annual report covering January 1, 2023 to June 30, 2023 was filed 87 days late on October 25, 2023. Cause This appears to be due to inadequate policies and procedures surrounding the filing of financial reports under the program. Effect The Boston Fire Department (BFD) does not have a process in place to ensure the completeness and accuracy, or the timely filing, of the semi annual SF 425 Financial Report. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs None Recommendation We recommend that the BFD implement control procedures to ensure that the SF 425 Financial Reports are filed timely and reviewed against supporting general ledger schedules to ensure completeness and accuracy of each report prior to submission. View of Responsible Officials from the Auditee BFD has taken considerable steps to incorporate and implement proper control procedures surrounding all grant related matters, i.e. financial reporting and oversight. In August 2023, BFD hired a Financial Grants Manager with more than ten years of experience working in municipal government with grants to ensure proper financial oversight is established and enforced. Additionally, BFD has acquired licenses for Airtable, an online platform for creating and sharing relational databases. It combines the features of a database and a spreadsheet, allowing users to store, organize, and collaborate on information about anything. This platform allows the department to track upcoming reporting deadlines, maintain information regarding grant related purchases, etc. The Financial Grants Manager has been reviewing all currently funded grants, to include SAFER, to ensure that the general ledger postings accurately reflect allowable costs so that when reports are filed the information reported in FEMA GO is accurate and complete. BFD projects that timely and accurate filing will be in effect no later than in January 2025 in order to complete the semi annual reports due for the period ending December 31, 2024.

Finding number: 2023 016 Federal agency: U.S. Department of Homeland Security Pass through agency: N/A – Direct Funding Program: Staffing for Adequate Fire and Emergency Response ALN #: 97.083 Award number: EMW 2020 FF 00996 Award year: February 27, 2022 to February 26, 2025 Finding: Internal Control and Compliance over Performance Reporting Prior Year Finding: No Type of Finding: Material Weakness Criteria Per the Department of Homeland Security (DHS) Notice of Funding Opportunity (NOFO) for Fiscal Year 2020 Staffing for Adequate Fire and Emergency Response (SAFER) Grant Program and the Federal Emergency Management Agency (FEMA) Grant Programs Directorate Information Bulletin No. 471, the recipient is responsible for completing and submitting a Programmatic Performance Report (PPR) using FEMA GO. For those awards which began in prior year, the PPR is due every six months based on the calendar year until the period of performance ends, and no later than 30 days after the six month period end. Additionally, 2 CFR 200.303 indicates that non Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing over both required semi annual performance progress reports (PPRs) for fiscal year 2023, we noted the semi annual PPR covering July 1, 2022 to December 31, 2022 was filed six days late on February 6, 2023. Additionally, we noted the semi annual PPR covering January 1, 2023 to June 30, 2023 was never filed. Cause This appears to be due to inadequate policies and procedures surrounding the filing of PPRs under the program. Effect The Boston Fire Department (BFD) does not have a process in place to ensure the completeness and accuracy, or the timely filing, of the semi annual PPR. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation We recommend that the BPD implement control procedures to ensure that the PPRs are filed timely and reviewed against supporting schedules to ensure completeness and accuracy of each report prior to submission. View of Responsible Officials from the Auditee BFD has taken considerable steps to incorporate and implement proper control procedures surrounding all grant related matters, i.e. programmatic reporting and oversight. In February 2024, BFD hired a Programmatic Grants Manager to ensure and implement proper policies and procedures regarding programmatic aspects of the department’s external funds. Additionally, BFD has acquired licenses for Airtable, an online platform for creating and sharing relational databases. It combines the features of a database and a spreadsheet, allowing users to store, organize, and collaborate on information about anything. This platform allows the department to track upcoming reporting deadlines, maintain information regarding grant related purchases, etc. The Programmatic Grants Manager has been reviewing all currently funded grants, to include SAFER, to ensure that the general ledger postings accurately reflect allowable costs so that when reports are filed the information reported in FEMA GO is accurate and complete. BFD projects that timely and accurate filing will be in effect no later than in January 2025 in order to complete the semi annual reports due for the period ending December 31, 2024.

Finding number: 2022 001 Federal agency: U.S. Department of Education Pass through agency: Massachusetts Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies ALN #: 84.010 Award number: 305 532937 2022 0035 Award year: September 1, 2021 to June 30, 2023 Finding: Internal Control and Compliance over Payroll Costs Prior Year Finding: 2018 001 Type of Finding: Material Weakness Criteria In accordance with 2 CFR 200.430(i)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both Federally assisted and all other activities compensated by the non Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Additionally, 2 CFR 200.303 indicates that non Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of allowable costs associated with payroll charges, we noted that the City of Boston Public Schools (BPS) documents time and attendance of employees on daily timesheets signed by the employee, as well as weekly time and effort reporting worksheets. The timesheets are then reviewed by each employee?s supervisor and the worksheets are reviewed by the Department Head or designee, ensuring appropriate salary and wage distribution. However, for our sample of 40 payroll transactions charged to the program, 6 transactions were not supported by a completed timesheet. Cause This appears to be due to an insufficient system for collecting, filing and maintaining supporting documentation for payroll transactions charged to Federal programs. Effect BPS is not in compliance with 2 CFR 200.430(i)(1) regarding documentation in support of salaries and wages charge to the federal program. The number of transactions that were not supported by a time sheet represent 15% of the selected population and indicate a systemic problem. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: Questioned costs of $24,188, for unsupported payroll charges, were charged to ALN # 84.010, Award No. 305 532937 2022 0035. Recommendation We recommend that BPS implement control procedures to ensure that all payroll costs charged to the federal program are supported by documentation as required by 2 CFR 200.430(i)(1). View of Responsible Officials from the Auditee The District will revert back to the previously approved Google Form process for daily sign in and sign out procedures. This form is authenticated through IT and managed in a centralized repository making it easier to recall data for auditing and validate for weekly time reporting. The District created a new office of Compliance and Risk Management. The office will audit and review the established process quarterly to ensure integrity of the process.

Finding number: 2022 002 Federal agency: U.S. Department of Education Pass through agency: Massachusetts Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies ALN #: 84.010 Award number: Various Award year: Various Finding: Internal Control over Reporting Prior Year Finding: No Type of Finding: Significant Deficiency Criteria The City of Boston Public Schools (BPS) receives funding from the Commonwealth of Massachusetts? Department of Elementary and Secondary Education (DESE). DESE sets policy for the grants and required reports. DESE issues guidance in Grants for Schools: Getting Them and Using them, A Procedural Manual. According to the DESE?s procedure manual, ?At the conclusion of grant activities, recipients must submit a final financial report to the Department, accounting for the expenditure of funds received. Grants Management has developed an online process and standard form (FR1) for collecting this information. The FR1 form should be submitted to Grants Management within sixty (60) days of the end date of the grant. Grant recipients should file their reports after carefully reconciling all figures with their city auditor, town accountant, or agency business manager.? Additionally, 2 CFR 200.303 indicates that non Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our review of compliance with subrecipient reporting requirements for the Title I program, we noted that, for our sample of 4 of the population of 13 FR1 reports required to be filed in fiscal year 2022, 3 reports were filed over a year after the respective grant period ended. Cause This appears to be due to inadequate policies and procedures surrounding the filing of financial reports under the program. Effect BPS does not have effective internal controls over the Federal award in regard to the primary recipient?s Title I program reporting requirements. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation We recommend that BPS implement control procedures to ensure that the FR1 form be submitted to DESE Grants Management within sixty (60) days of the end date of the grant in accordance with the reporting requirements of the primary Federal recipient of the Title I program. View of Responsible Officials from the Auditee The Finance Department at Boston Public Schools will implement an internal fiscal tracker to monitor and update on a quarterly basis to reflect reporting timelines and ensure timely spending of all grant funds. In addition, BPS will create a grant close procedure document that outlines the roles, responsibilities, and tasks associated with completing the FR1.

Finding number: 2022 003 Federal agency: U.S. Department of Education Pass through agency: Massachusetts Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies ALN #: 84.010 Award number: Various Award year: Various Finding: Internal Control and Compliance over Annual Report Card, High School Graduation Rate Prior Year Finding: Yes 2021 002 Type of Finding: Material Weakness Criteria Beginning with annual report cards providing assessment results for the 2010?2011 school year, a State educational agency (SEA) and its local education agencies (LEAs) must report graduation rate data for all public high schools at the school, LEA, and State levels using the 4 year adjusted cohort rate under 34 CFR section 200.19(b)(1)(i) (iv)). Additionally, SEAs and LEAs must include the 4 year adjusted cohort graduation rate (which may be combined with an extended year adjusted cohort graduation rate or rates) in adequate yearly progress (AYP) determinations beginning with determinations based on assessments administered in the 2011?2012 school year. Graduation rate data must be reported both in the aggregate and disaggregated by each subgroup described in 34 CFR section 200.13(b)(7)(ii) using a 4 year adjusted cohort graduation rate. To remove a student from the cohort, a school or LEA must confirm, in writing, that the student transferred out, emigrated to another country, or is deceased. To confirm that a student transferred out, the school or LEA must have official written documentation that the student enrolled in another school or in an educational program that culminates in the award of a regular high school diploma. Additionally, 2 CFR 200.303 indicates that non Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition For 9 of 60 students removed from their respective cohorts in the Student Information Management System (SIMS) selected for testing, the City of Boston Public Schools (BPS) could not provide any official written documentation that the student emigrated to another country, is deceased, or is enrolled in another school or in an education program that culminates in the award of a regular high school diploma. Cause This appears to be due to insufficient review of supporting documentation before removal of students from the adjusted cohort graduation rate. Effect BPS is potentially misstating the number of students in the adjusted cohorts used by the Commonwealth of Massachusetts to determine the 4 year adjusted cohort graduation rate. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation BPS management should re familiarize and re enforce the requirements with staff related to the removal of students from the adjusted cohorts used to determine the 4 year adjusted cohort graduation rate and the policies and procedures to obtain and monitor official written documentation of student transfers required to remove students from their respective cohort. View of Responsible Officials from the Auditee Between April and June 2022, the district contracted with Ernst and Young to complete a review of withdrawal processes and make recommendations to improve monitoring and internal audit processes. In August 2022, the district formed a student withdrawal working group, which created a process memo to support the appropriate withdrawal process for students in grades 9 12. At the August Management and Operations Institute, the student withdrawal working group was able to communicate and train school leaders and their administration on the appropriate withdrawal processes for students. Throughout the fall and winter, the student withdrawal working group has been monitoring the number of students withdrawn from the district; reviewing associated documentation of the withdrawal; and working with school leaders and school administration both at the central office level as well as through the liaisons and leaders within the regional structure to upload appropriate withdrawal documentation or update withdrawal codes to reflect the evidence associated with each student?s withdrawal case.

Finding number: 2022 004 Federal agency: U.S. Department of Education Pass through agency: Massachusetts Department of Elementary and Secondary Education Program: COVID-19 Education Stabilization Fund ALN #: 84.425D Award number: 115 511413 2022 0035 Award year: July 30, 2021 to September 30, 2023 Finding: Internal Control and Compliance over Payroll Costs Prior Year Finding: No Type of Finding: Material Weakness Criteria In accordance with 2 CFR 200.430(i)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both Federally assisted and all other activities compensated by the non Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Additionally, 2 CFR 200.303 indicates that non Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of allowable costs associated with payroll charges, we noted that the City of Boston Public Schools (BPS) documents time and attendance of employees on daily timesheets signed by the employee, as well as weekly time and effort reporting worksheets. The timesheets are then reviewed by each employee?s supervisor and the worksheets are reviewed by the Department Head or designee, ensuring appropriates salary and wage distribution. However, for our sample of 40 payroll transactions charged to the program, 12 transactions were not supported by a completed timesheet. Cause This appears to be due to an insufficient system for collecting, filing and maintaining supporting documentation for payroll transactions charged to Federal programs. Effect BPS is not in compliance with 2 CFR 200.430(i)(1) regarding documentation in support of salaries and wages charge to the federal program. The number of transactions that were not supported by a time sheet represent 30% of the selected population and indicate a systemic problem. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: Questioned costs of $41,281, for unsupported payroll charges, were charged to ALN # 84.425, Award No. 115 511413 2022 0035. Recommendation We recommend that BPS implement control procedures to ensure that all payroll costs charged to the federal program are supported by documentation as required by 2 CFR 200.430(i)(1). View of Responsible Officials from the Auditee The District will revert back to the previously approved Google Form process for daily sign in and sign out procedures. This form is authenticated through IT and managed in a centralized repository making it easier to recall data for auditing and validate for weekly time reporting. The District created a new office of Compliance and Risk Management. The office will audit and review the established process quarterly to ensure integrity of the process.

Finding number: 2022 005 Federal agency: U.S. Department of Health and Human Services Pass through agency: Massachusetts Executive Office of Elderly Affairs Program: Aging Cluster ALN #: 93.044, 93.045, 93.053 Award number: Various Award year: Various Finding: Internal Control over Subrecipient Monitoring Prior Year Finding: No Type of Finding: Significant Deficiency Criteria 2 CFR section 200.331(a) indicates that all pass through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification: (1) Federal Award Identification. ? Subrecipient?s name (which must match registered name in DUNS); ? Subrecipient?s DUNS number (see ? 200.32 Data Universal Numbering System (DUNS) number); ? Federal Award Identification Number (FAIN); ? Federal award date; ? Subaward Period of Performance Start and End Date; ? Amount of Federal Funds Obligated by this action; ? Total Amount of Federal Funds Obligated to the subrecipient; ? Total Amount of the Federal Award committed to the subrecipient by the pass through entity; ? Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); ? Name of Federal awarding agency, pass through entity, and contact information for awarding official of the pass through entity; ? ALN Number and Name; the pass through entity must identify the dollar amount made available under each Federal award and the ALN number at time of disbursement; ? Identification of whether the award is R&D; and ? Indirect cost rate for the Federal award (including if the de minimis rate is charged per ? 200.414 Indirect (F&A) costs). (2) All requirements imposed by the pass through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award. (3) Any additional requirements that the pass through entity imposes on the subrecipient in order for the pass through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports; (4) An approved Federally recognized indirect cost rate negotiated between the subrecipient and the Federal government or, if no such rate exists, either a rate negotiated between the pass through entity and the subrecipient (in compliance with this part), or a de minimis indirect cost rate as defined in ? 200.414 Indirect (F&A) costs, paragraph (b) of this part. (5) A requirement that the subrecipient permit the pass through entity and auditors to have access to the subrecipient?s records and financial statements as necessary for the passthrough entity to meet the requirements of this section, ? 200.300 Statutory and national policy requirements through 200.309 Period of performance, and Subpart F ? Audit Requirements of this part; and (6) Appropriate terms and conditions concerning closeout of the subaward. Condition During our testing of subrecipient monitoring for a sample of 8 out of the population of 20 subrecipients, the City of Boston?s Age Strong Commission (Age Strong Commission) subaward letters were authorized however it was noted that such documents did not contain all of the required elements of 2 CFR Section 200.331(a) listed above. For all 8 subrecipients, the subaward letter did not identify whether the subaward is R&D and did not contain the indirect cost rate for the Federal award. Cause This appears to be due to inadequate review to ensure the subaward includes all of the required elements of 2CFR Section 200.331(a) prior to authorization. Effect Aging does not have adequate controls over subrecipient notification requirements. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation We recommend that OEM execute an updated MOA with its subrecipients that expressly includes all information description in 2 CFR section 200.331(a)(1) as required by the Uniform Guidance. View of Responsible Officials from the Auditee The City of Boston?s Age Strong Commission has revised the addendum that is attached to their award letters to include whether or not the award is R&D and a section on indirect cost rate.

Finding number: 2022 006 Federal agency: U.S. Department of Health and Human Services Pass through agency: Massachusetts Executive Office of Elderly Affairs Program: Aging Cluster ALN #: 93.044, 93.045, 93.053 Award number: Various Award year: Various Finding: Internal Control over Subrecipient Monitoring Prior Year Finding: No Type of Finding: Significant Deficiency Criteria According to 2 CFR 200.331 (b), a pass through entity must evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring, which may include consideration of such factors as: ? The subrecipient?s prior experience with the same or similar subawards; ? The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; ? Whether the subrecipient has new personnel or new or substantially changed systems; and ? The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Also, according to 2 CFR 200.331 (d), a pass through entity must: ? Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. ? Follow up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass through entity detected through audits, on site reviews, and other means. Additionally, 2 CFR 200.303 indicates that non Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of subrecipient monitoring for a sample of 8 out of the population of 20 subrecipients, the City of Boston?s Age Strong Commission (Age Strong Commission) was unable to provide documentation for one of the 8 subrecipients showing that a formal risk evaluation had been performed. In addition, the Age Strong Commission?s internal controls did not include formal risk evaluation procedures. Cause This appears to be due to inadequate policies and procedures surrounding the initial risk assessment of the subrecipients. Effect The Age Strong Commission does not have adequate controls over evaluating each subrecipient?s risk of noncompliance for purposes of determining appropriate subrecipient monitoring. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs None Recommendation We recommend that the Age Strong Commission implement control procedures to ensure that each subrecipient is evaluated for risk of noncompliance to ensure appropriate subrecipient monitoring. View of Responsible Officials from the Auditee A risk assessment questionnaire will be completed prior to funding being awarded to a sub recipient. The City of Boston?s Age Strong Commission?s policies and procedures will be updated to reflect this.

Finding number: 2022 007 Federal agency: U.S. Department of Homeland Security Pass through agency: Massachusetts Executive Office of Public Safety & Security Program: Homeland Security Grant Program ALN #: 97.067 Award number: Boston FFY 19 UASI, Boston FFY 20 UASI, Boston FFY 21 UASI, Boston FFY 22 UASI, Award year: Various Finding: Internal Control over Subrecipient Monitoring Prior Year Finding: No Type of Finding: Significant Deficiency Criteria According to 2 CFR 200.331 (b), a pass through entity must evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring, which may include consideration of such factors as: ? The subrecipient?s prior experience with the same or similar subawards; ? The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; ? Whether the subrecipient has new personnel or new or substantially changed systems; and ? The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Also, according to 2 CFR 200.331 (d), a pass through entity must: ? Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. ? Follow up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass through entity detected through audits, on site reviews, and other means. Additionally, 2 CFR 200.303 indicates that non Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition Based on our testwork, it was noted that the Mayor?s Office of Office of Emergency Management (OEM) did not perform a formal evaluation of each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring to be performed. Further, our review of program monitoring documentation for our sample of 4 of the population of 11 subrecipients indicated that, although OEM performed subrecipient monitoring in fiscal year 2022, OEM did not follow up with 2 out of 4 subrecipients as to why the amount of total program expenditures on the subrecipients? fiscal year 2021 Schedule of Expenditures of Federal Awards (SEFA) were different than total program expenditures reported to them by OEM. Cause This appears to be due to inadequate policies and procedures surrounding both the initial risk assessment of the subrecipients, as well as follow up with subrecipients when differences are noted between funding amounts reported to the subrecipient by OEM and amounts reported of the subrecipient?s SEFA. Effect OEM does not have adequate controls over evaluating each subrecipient?s risk of noncompliance for purposes of determining appropriate subrecipient monitoring, and ensuring that the total amount of expenditures reported on the subrecipient?s SEFA is consistent with grant funding provided by OEM to the subrecipient. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation We recommend that OEM implement control procedures to ensure that each subrecipient is evaluated for risk of noncompliance for determining appropriate subrecipient monitoring, and to ensure that the total amount of expenditures reported on the subrecipient?s SEFA is consistent with grant funding provided by OEM to the subrecipient. View of Responsible Officials from the Auditee OEM will add an event to the departmental annual calendar on the first business day of the month of May of every year indicating that pre risk assessment forms for the upcoming fiscal year beginning on July 1st are to be sent out to subrecipients of federal funds. The addition of this even to the calendar will ensure that all appropriate Admin and Finance staff at OEM are aware of this annual requirement and follow up with subrecipients to receive completed pre risk assessments in advance of the new fiscal year. OEM?s Director of Admin and Finance will be the primary point of contact for pre risk assessment related inquiries from subrecipients, with the Assistant Deputy Chief of Administration serving as a backup point of contact. An event will also be added on the final business day of May each year to ensure that OEM staff follow up with subrecipients that were not responsive to the initial request. OEM will also institute a policy of requiring a written response following receipt of a SEFA letter from OEM detailing the previous fiscal year?s expenditures on behalf of a subrecipient. This written response will contain confirmation that the subrecipients have recorded the same expenditures in their accounting systems as OEM reported in the SEFA letter. Should there be any discrepancy between the information provided in the SEFA from OEM and the expenditures reported by the subrecipient, OEM will schedule a meeting to reconcile any differences and resolve discrepancies within 30 days of being notified of said discrepancies. The Director of Admin and Finance and the Assistant Deputy Chief of Administration will represent OEM in this meeting with the appropriate staff from the subrecipient reporting a discrepancy. Confirmation of resolution of any discrepancies will be documented in writing and attached to SEFA letters for record keeping purposes.

Finding number: 2021-001 Federal Agency: U.S. Department of Housing and Urban Development Pass-through Agency: N/A ? Direct Funding Program: CDBG Entitlement Grants Cluster CFDA#: 14.218 Award number: B-20-MC-25-0002 Award year: July 1, 2020 to September 1, 2027 Finding: Internal Control and Compliance over FFATA Reporting Prior Year Finding: No Type of Finding: Significant Deficiency Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reporting should be made in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition Based on a review of the FFATA reports submitted by the City of Boston Auditing Department in the FSRS system, it was noted that such documents were not submitted in a timely manner to meet the above required reporting timeline. For 10 out of 10 of the selected reports, the submission dates did not meet the compliance deadline. Cause This appears to be due to insufficient policies and procedures in place to ensure reports are submitted within the required timeframe noted above. Effect The City is not in compliance with the FFATA reporting requirements. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation: We recommend that the City enhance their policies and procedures related to the submission of the FFATA reports to ensure they are submitted within the required timeframe. View of Responsible Officials from the Auditee: The City has incorporated a monthly procedure for the review and submission of FFATA reporting.

Finding number: 2021-002 Federal Agency: U.S. Department of Education Pass-through Agency: Massachusetts Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies CFDA #: 84.010 Award numbers: Various Award years: Various Finding: Internal Control and Compliance over Annual Report Card, High School Graduation Rate Prior Year Finding: Yes, 2020-004 Type of Finding: Material Weakness Criteria Beginning with annual report cards providing assessment results for the 2010?2011 school year, a state educational agency (SEA) and its local educational agencies (LEAs) must report graduation rate data for all public high schools at the school, LEA, and State levels using the 4-year adjusted cohort rate under 34 CFR section 200.19(b)(1)(i)-(iv)). Additionally, SEAs and LEAs must include the 4-year adjusted cohort graduation rate (which may be combined with an extended-year adjusted cohort graduation rate or rates) in adequate yearly progress (AYP) determinations beginning with determinations based on assessments administered in the 2011?2012 school year. Graduation rate data must be reported both in the aggregate and disaggregated by each subgroup described in 34 CFR section 200.13(b)(7)(ii) using a 4-year adjusted cohort graduation rate. To remove a student from the cohort, a school or LEA must confirm, in writing, that the student transferred out, immigrated to another country, or is deceased. To confirm that a student transferred out, the school or LEA must have official written documentation that the student enrolled in another school or in an educational program that culminates in the award of a regular high school diploma. Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition For 17 of 40 students removed from their respective cohorts in the Student Information Management System (SIMS) selected for testing, the City of Boston Public Schools (BPS) could not provide any official written documentation that the student emigrated to another country, is deceased, or is enrolled in another school or in an education program that culminates in the award of a regular high school diploma. Cause This appears to be due to insufficient review of supporting documentation before removal of students from the adjusted cohort graduation rate. Effect BPS is potentially misstating the number of students in the adjusted cohorts used by the Commonwealth of Massachusetts to determine the 4-year adjusted cohort graduation rate. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation: BPS management should re-familiarize and re-enforce the requirements with staff related to the removal of students from the adjusted cohorts used to determine the 4-year adjusted cohort graduation rate and the policies and procedures to obtain and monitor official written documentation of student transfers required to remove students from their respective cohort. View of Responsible Officials from the Auditee: BPS? management has continued to enhance their policies and procedures to improve the process over students being removed from the cohort. BPS is partnering with an outside consulting firm for this area of compliance. The scope of work will include a review of the current process and a review of student enrollment data. The final report will provide recommendations of process improvements.

Finding number: 2020-001 Federal Agency: U.S. Department of Treasury Pass-through Agency: N/A ? Direct Funding Program: COVID-19 Coronavirus Relief Fund CFDA#: 21.019 Award number: N/A Award year: March 1, 2020 to December 30, 2020 Finding: Internal Control and Compliance over Subrecipient Monitoring Prior Year Finding: No Type of Finding: Significant Deficiency Criteria 2 CFR section 200.331(a) indicates that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification: (1) Federal Award Identification. ? Subrecipient?s name (which must match registered name in DUNS); ? Subrecipient?s DUNS number (see ? 200.32 Data Universal Numbering System (DUNS) number); ? Federal Award Identification Number (FAIN); ? Federal award date; ? Subaward Period of Performance Start and End Date; ? Amount of Federal Funds Obligated by this action; ? Total Amount of Federal Funds Obligated to the subrecipient; ? Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; ? Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); ? Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity; ? CFDA Number and Name; the pass-through entity must identify the dollar amount made available under each Federal award and the CFDA number at time of disbursement; ? Identification of whether the award is R&D; and ? Indirect cost rate for the Federal award (including if the de minimis rate is charged per ? 200.414 Indirect (F&A) costs). (2) All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award. (3) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports; (4) An approved Federally recognized indirect cost rate negotiated between the subrecipient and the Federal government or, if no such rate exists, either a rate negotiated between the pass-through entity and the subrecipient (in compliance with this part), or a de minimis indirect cost rate as defined in ? 200.414 Indirect (F&A) costs, paragraph (b) of this part. (5) A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient?s records and financial statements as necessary for the passthrough entity to meet the requirements of this section, ? 200.300 Statutory and national policy requirements through 200.309 Period of performance, and Subpart F ? Audit Requirements of this part; and (6) Appropriate terms and conditions concerning closeout of the subaward. Condition Based on a review of the Award Memorandum (the Memorandum) sent by the City of Boston Auditing Department to its 2 program subrecipients, it was noted that such documents did not contain all of the required elements of 2 CFR Section 200.331(a) listed above. For both subrecipients, the Memorandum did not contain the subrecipient?s DUNS number. Cause This appears to be due to the Memorandum being a standard template which did not include all of the required elements of 2CFR Section 200.331(a). Effect The City is not in compliance with subrecipient notification requirements. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation: We recommend that the City execute an updated Memorandum with its subrecipients that expressly includes all information described in 2 CFR section 200.331(a)(1) as required by the Uniform Guidance. View of Responsible Officials from the Auditee: The City has implemented additional procedures to ensure that all information described in 2 CFR section 200.331(a)(1) as required by Uniform Guidance is included in correspondence to the subrecipients. These additional procedures include an audit checklist which contains all of the required data elements.

Finding number: 2020-002 Federal Agency: U.S. Department of Agriculture Pass-through Agency: Massachusetts Department of Elementary and Secondary Education Program: Child Nutrition Cluster CFDA #s: 10.555, 10.559 Award numbers: Various Award years: Various Finding: Internal Control over School Food Accounts Prior Year Finding: No Type of Finding: Significant Deficiency Criteria 7 CFR 210.14(a), 210.14(c), 210.19(a)(2), 215.7(d), 220.2 and 220.7(e)(1)(i) indicate that a School Food Authority (SFA) is required to account for all revenues and expenditures of its nonprofit school food service in accordance with State requirements. A SFA must operate its food services on a nonprofit basis; all revenue generated by the school food service must be used to operate and improve its food services. Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of school food accounts, it was disclosed that the recording of food service federal reimbursement payments is reviewed and approved by the City of Boston Public Schools (BPS) Food and Nutrition Services Deputy Director. However, this review and approval process is not documented and therefore could not be confirmed during testing. Cause This appears to be the result of the lack of a formal process to document the review and approval of the recording of food service cash receipts. Effect Insufficient documentation over review and approval of the recording of food service federal reimbursement payments increases the risk of inaccurate or untimely recording of these cash receipts.Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation: We recommend that BPS implement formal procedures for documenting the review and approval process over the recording of food service federal reimbursement payments in order to ensure compliance over school food accounts requirements of the cluster. View of Responsible Officials from the Auditee: Management agrees with the audit finding and recommendation. Procedures will be implemented effective immediately to ensure the submission of claims for federal reimbursement payment reflects a preparer and reviewer sign-off.

Finding number: 2020-003 Federal Agency: U.S. Department of Education Pass-through Agency: Massachusetts Department of Elementary and Secondary Education Programs: Title I, Grants to Local Education Agencies; Special Education (IDEA) Cluster CFDA #s: 84.010; 84.027; 84.173 Award numbers: Various Award years: Various Finding: Internal Control over Payroll Costs Prior Year Finding: No Type of Finding: Significant Deficiency Criteria In accordance with 2 CFR 200.430(i)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both Federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of allowable costs associated with payroll charges, we noted that the City of Boston Public Schools (BPS) documents time and attendance of employees on daily timesheets as well as weekly Time and Effort Reporting worksheets (worksheets). The timesheets are then reviewed by each employee?s supervisor and the worksheets are reviewed by the associated Department Head or designee, ensuring appropriate salary and wage distribution. However, for those payroll transactions that occurred during the initial COVID-19 pandemic months of March 2020 through fiscal year end, the daily timesheets were not completed and reviewed. Cause This appears to be the result of an insufficient policy and lack of compensating controls when employees were moved to a remote working environment. Effect Insufficient review of daily timesheets or other time allocation documentation increases the risk of inaccurate payroll costs being allocated to a grant award. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation: We recommend that BPS enhance its policies and procedures to include a documented review of employees? time allocation while in a remote work environment. View of Responsible Officials from the Auditee: BPS re-implemented and required daily timesheets for the 2020/2021 school year to be completed by each employee and to be reviewed by the employee's supervisor and the associated Department Head or designee.

Finding number: 2020-004 Federal Agency: U.S. Department of Education Pass-through Agency: Massachusetts Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies CFDA #: 84.010 Award numbers: Various Award years: Various Finding: Internal Control and Compliance over Annual Report Card, High School Graduation Rate Prior Year Finding: Yes, 2019-003 Type of Finding: Material Weakness Criteria Beginning with annual report cards providing assessment results for the 2010?2011 school year, a state educational agency (SEA) and its local educational agencies (LEAs) must report graduation rate data for all public high schools at the school, LEA, and State levels using the 4-year adjusted cohort rate under 34 CFR section 200.19(b)(1)(i)-(iv)). Additionally, SEAs and LEAs must include the 4-year adjusted cohort graduation rate (which may be combined with an extended-year adjusted cohort graduation rate or rates) in adequate yearly progress (AYP) determinations beginning with determinations based on assessments administered in the 2011?2012 school year. Graduation rate data must be reported both in the aggregate and disaggregated by each subgroup described in 34 CFR section 200.13(b)(7)(ii) using a 4-year adjusted cohort graduation rate. To remove a student from the cohort, a school or LEA must confirm, in writing, that the student transferred out, immigrated to another country, or is deceased. To confirm that a student transferred out, the school or LEA must have official written documentation that the student enrolled in another school or in an educational program that culminates in the award of a regular high school diploma. Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition For 16 of 40 students removed from their respective cohorts in the Student Information Management System (SIMS) selected for testing, the City of Boston Public Schools (BPS) could not provide any official written documentation that the student emigrated to another country, is deceased, or is enrolled in another school or in an education program that culminates in the award of a regular high school diploma. Cause This appears to be due to insufficient review of supporting documentation before removal of students from the adjusted cohort graduation rate. Effect BPS is potentially misstating the number of students in the adjusted cohorts used by the Commonwealth of Massachusetts to determine the 4-year adjusted cohort graduation rate. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation: BPS management should re-familiarize and re-enforce the requirements with staff related to the removal of students from the adjusted cohorts used to determine the 4-year adjusted cohort graduation rate and the policies and procedures to obtain and monitor official written documentation of student transfers required to remove students from their respective cohort. View of Responsible Officials from the Auditee: BPS management has established policies and procedures to ensure when students are removed from the cohort, there is sufficient and appropriate documentation to verify the student is categorized appropriately as either immigrated to another country, deceased, or enrolled in another school or in an education program that culminates in the award of a regular high school diploma. BPS has created a working group that consists of school department management as well as management from the City's Administration and Finance Cabinet to review all of the federal requirements related to calculating the High School Graduation Rate. This committee will update guidance that is sent to each high school and will execute training sessions for all employees that are responsible for this area of compliance. Additional internal procedures are being developed to ensure the compliance of this requirement.

CITY OF BOSTON, MASSACHUSETTS Schedule of Findings and Questioned Costs Year ended June 30, 2019 Finding number: 2019-001 Federal Agency: U.S. Department of Transportation Pass through Agency: Massachusetts Department of Transportation Program: Highway Planning and Construction CFDA#: 20.205 Award numbers: CT DOT INTF 00X0 2012A 0070062 CT DOT 6433 INTF 00X0 2015 A 0077951 Award years: May 2, 2012 to December 31, 2018; June 26, 2014 to June 30, 2019 Finding: Internal Control and Compliance over Proper Reporting of Expenditures in the Schedule of Expenditures of Federal Awards Prior Year Finding: No Type of Finding: Material Weakness Criteria Per Part 200 ? Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, Section 200.510, a recipient of Federal awards subject to audit (the auditee) must prepare a schedule of expenditures of Federal awards (SEFA) for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with ?200.502. Condition/Context During our audit of the Highway Planning and Construction grant and review of the program grant award documents, it was determined that certain expenditures were incorrectly coded as federal expenditures in the City of Boston?s (the City) accounting records. These expenditures were coded to pass-through grant awards in which the grant period had ended and amendments were not received. Expenditures were properly removed from the Schedule of Expenditures of Federal Awards (SEFA). Cause Inaccurate coding of grant awards within the City?s general ledger and inadequate review of the preparation of the SEFA for accuracy. Effect The expenditures for the program were overstated in the current year SEFA. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation: We recommend that the City enhance year-end reporting controls to ensure that the SEFA is complete and accurate, as well as enhance controls to ensure grants are properly coded when inputted into the City?s general ledger. View of Responsible Officials from the Auditee: The City mistakenly coded some of the external highway funds as federal funds. The City has put additional review procedures in place to ensure the accuracy and completeness of the SEFA.

CITY OF BOSTON, MASSACHUSETTS Schedule of Findings and Questioned Costs Year ended June 30, 2019 Finding number: 2019-002 Federal Agency: U.S. Department of Education Pass through Agency: Massachusetts Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies CFDA #: 84.010 Award numbers: Various Award years: Various Finding: Internal Control over Level of Effort Prior Year Finding: Yes; 2018-003 Type of Finding: Significant Deficiency Criteria In accordance with 20 USC 6321(b), Local Educational Agencies may use program funds only to supplement and, to the extent practical, increase the level of funds that would, in the absence of the Federal funds, be made available from non-Federal sources for the education of participating students. In no case may an LEA use Federal program funds to supplant funds from non-Federal sources. The pass-through agency has provided guidance to its subrecipients stating that for Title I, compliance with supplement not supplant is no longer measured by looking at particular Title I expenditures, but is measured instead by whether a school district has a written methodology to ensure that each Title I school receives all of the state and local funds that it would have received if it were not a Title I school. Districts must demonstrate that the methodology they use to allocate state and local funds is ?Title I? neutral?. The methodology must provide each Title I school with all of the state and local money it would have received if it did not participate in the Title I program. Additionally, 2 CFR 200.303 indicates that non Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition The City of Boston Public Schools (BPS) allocates state and local funds to its individual schools based on a weighted student funding methodology. Weights are determined based on individual categories of need at each school without regard to the amount of Title I funding that a school receives. It was noted that complete allocation methodology, although documented among numerous documents, is not summarized in one concise area. It was also noted that the review and approval of the allocation calculations is not formally documented. Cause This appears to be due to a lack of policies and procedures in place at BPS to formally document the processes and controls over this compliance requirement. Effect The lack of a formally documented allocation methodology and the related review and approval process increases the risk of noncompliance with level of effort ? supplement not supplant compliance requirements. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation: We recommend that BPS implement control procedures to formally document both the state and local funding allocation methodology to its school districts and the related review and approval process over this funding allocation. View of Responsible Officials from the Auditee: BPS will formally document the funding allocation methodology and will have approval sign-off for the report. The BPS weighted student funding methodology is being implemented with a specific review to ensure that the methodology is calculated without regard to the Title I funding that each school receives.

CITY OF BOSTON, MASSACHUSETTS Schedule of Findings and Questioned Costs Year ended June 30, 2019 Finding number: 2019-003 Federal Agency: U.S. Department of Education Pass through Agency: Massachusetts Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies CFDA #: 84.010 Award numbers: Various Award years: Various Finding: Internal Control and Compliance over Annual Report Card, High School Graduation Rate Prior Year Finding: Yes, 2018-004 Type of Finding: Material Weakness Criteria Beginning with annual report cards providing assessment results for the 2010?2011 school year, an SEA and its LEAs must report graduation rate data for all public high schools at the school, LEA, and State levels using the 4-year adjusted cohort rate under 34 CFR section 200.19(b)(1)(i)-(iv)). Additionally, SEAs and LEAs must include the 4-year adjusted cohort graduation rate (which may be combined with an extended-year adjusted cohort graduation rate or rates) in adequate yearly progress (AYP) determinations beginning with determinations based on assessments administered in the 2011?2012 school year. Graduation rate data must be reported both in the aggregate and disaggregated by each subgroup described in 34 CFR section 200.13(b)(7)(ii) using a 4-year adjusted cohort graduation rate. To remove a student from the cohort, a school or LEA must confirm, in writing, that the student transferred out, immigrated to another country, or is deceased. To confirm that a student transferred out, the school or LEA must have official written documentation that the student enrolled in another school or in an educational program that culminates in the award of a regular high school diploma. Additionally, 2 CFR 200.303 indicates that non Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition For 15 of 40 students removed from their respective cohorts in the Student Information Management System (SIMS) selected for testing, the City of Boston Public Schools (BPS) could not provide any official written documentation that the student emigrated to another country, is deceased, or is enrolled in another school or in an education program that culminates in the award of a regular high school diploma. Cause This appears to be due to insufficient review of supporting documentation before removal of students from the adjusted cohort graduation rate. Effect BPS is potentially misstating the number of students in the adjusted cohorts used by the Commonwealth of Massachusetts to determine the 4-year adjusted cohort graduation rate. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation: BPS management should re-familiarize and re-enforce the requirements with staff related to the removal of students from the adjusted cohorts used to determine the 4-year adjusted cohort graduation rate and the policies and procedures to obtain and monitor official written documentation of student transfers required to remove students from their respective cohort. View of Responsible Officials from the Auditee: BPS management has established policies and procedures to ensure when students are removed from the cohort, there is sufficient and appropriate documentation to verify the student is categorized appropriately as either immigrated to another country, deceased, or enrolled in another school or in an education program that culminates in the award of a regular high school diploma. BPS has put controls in place to require supporting documentation is provided each time a withdrawal code is entered into the system. This documentation will be verified before the code is accepted. All schools will be sent guidance on an annual basis on the acceptable documents for this process.

CITY OF BOSTON, MASSACHUSETTS Schedule of Findings and Questioned Costs Year ended June 30, 2019 Finding number: 2019-004 Federal Agency: U.S. Department of Education Pass-through Agency: Massachusetts Department of Early Education and Care Program: Preschool Development Grants CFDA#: 84.419 Award number: 5186PEGBOSTONPUBLIC Award years: March 31, 2015 to August 31, 2019 Finding: Internal Control and Compliance over Payroll Costs Prior Year Finding: Yes; 2018-005 Type of Finding: Material Weakness Criteria In accordance with 2 CFR 200.430(i)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both Federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of allowable costs associated with payroll charges, we noted that the City of Boston Public Schools (BPS) documents time and attendance of employees on daily timesheets signed by the employee, and that these timesheets are approved by the department supervisor on a department time summary report. Our review of 40 payroll transactions charged to the program noted that for 28 payroll transactions tested, an allocation of payroll was made based on estimated time worked on the award for 10 employees whose salary was partially charged to the program; however, no documentation was provided to support this estimate. Cause This appears to be due to a lack of a formal system that documents actual time worked by program for employees that are charged to several funding sources. Effect Insufficient time allocation documentation increases the risk of inaccurate payroll costs being considered for allocation to a grant award. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: Questioned costs of $62,107, for unsupported payroll charges, were charged to CFDA No. 84.419, Award No. 5186PEGBOSTONPUBLIC. Recommendation: We recommend that BPS implement control procedures to ensure that all payroll costs charged to the Federal program are supported by documentation as required by 2 CFR 200.430(i)(1). View of Responsible Officials from the Auditee: The Early Childhood Department at BPS has implemented internal control systems in order to properly tracking salaries and ensure that all payroll costs charged to the program are supported by acceptable documentation.

CITY OF BOSTON, MASSACHUSETTS Schedule of Findings and Questioned Costs Year ended June 30, 2019 Finding number: 2019-005 Federal Agency: U.S. Department of Education Pass-through Agency: Massachusetts Department of Early Education and Care Program: Preschool Development Grants CFDA#: 84.419 Award number: 5186PEGBOSTONPUBLIC Award years: March 31, 2015 to August 31, 2019 Finding: Internal Control and Compliance over Subrecipient Monitoring Prior Year Finding: Yes; 2018-006 Type of Finding: Significant Deficiency Criteria Also, according to 2 CFR 200.331(d), a pass-through entity must: ? Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. ? Follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. ? Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition Our review of program monitoring documentation for our sample of 4 of the population of 8 subrecipients indicated that, although the City of Boston Public Schools (BPS) performed subrecipient monitoring in fiscal year 2019 using the standard template as recommended by the Preschool Expansion Grant Implementation Guide issued by the pass-through agency, which included site visits and periodic meetings with the subrecipient, and reported areas of noncompliance to the subrecipients, BPS did not follow-up and ensure that the subrecipient took timely and appropriate action on reported noncompliance for 4 of the 4 subrecipients tested. Cause This appears to be due to inadequate policies and procedures in place to ensure follow-up over subrecipients when issues of noncompliance are identified during program monitoring reviews. Effect Untimely follow-up could result in findings not being addressed by the City and corrected by the subrecipient in a timely manner. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation: We recommend that BPS implement control procedures to ensure that subrecipients take timely and appropriate action on all areas of noncompliance identified through program monitoring reviews. View of Responsible Officials from the Auditee: BPS subrecipient monitoring procedures for risk assessment and risk evaluation have been enhanced to ensure that all subrecipients take timely and appropriate action on all areas of noncompliance. BPS will train the staff to complete and document the corrective action of the subrecipient.

CITY OF BOSTON, MASSACHUSETTS Schedule of Findings and Questioned Costs Year ended June 30, 2019 Finding Number: 2019-006 Federal Agency: U.S. Department of Health and Human Services Pass-through Agency: Massachusetts Executive Office of Elderly Affairs Program: Aging Cluster CFDA#: 93.044, 93.045, 93.053 Award numbers: CT-ELD 0366 TITLE3FEDYR18BOSTCOM, CT ELD 0366 NSIPPROGRAM2018BOSTN, CT ELD 0366 NSIPPROGRAM2019BOSTN Award years: October 1, 2017 to June 30, 2019 and October 1, 2018 to March 30, 2020 Finding: Internal Control and Compliance over Subrecipient Monitoring Prior Year Finding: No Type of Finding: Significant Deficiency Criteria According to 2 CFR 200.331(b), a pass through entity must evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring, which may include consideration of such factors as: ? The subrecipient?s prior experience with the same or similar subawards; ? The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F ? Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; ? Whether the subrecipient has new personnel or new or substantially changed systems; and ? The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Condition During our testing of subrecipient monitoring for a sample of 11 out of the population of 26 subrecipients, the City of Boston?s Age Strong Commission (Age Strong Commission) was unable to provide documentation showing that a formal risk evaluation had been performed for any of their subrecipients. In addition, the Age Strong Commission?s internal controls did not include formal risk evaluation procedures. Cause This appears to be due to a lack of awareness regarding the requirements of the compliance supplement which changed in recent years. Effect The Age Strong Commission is not in compliance with the requirements related to evaluating each subrecipient?s risk of noncompliance for purposes of determining appropriate subrecipient monitoring. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation: We recommend that the Age Strong Commission implement control procedures to ensure that each subrecipient is evaluated for risk of noncompliance for determining appropriate subrecipient monitoring. View of Responsible Officials from the Auditee: The Age Strong Commission currently has written subrecipient monitoring procedures for risk assessment and risk evaluation. In practice the subrecipients that are deemed to have a potential for risk are site visited and more closely monitored. This evaluation and work has not been documented in the files. The Age Strong Commission will formalize this documentation step and train the staff to complete a checklist and document the evaluation of each subrecipient and the additional steps taken, if warranted.

CITY OF BOSTON, MASSACHUSETTS Schedule of Findings and Questioned Costs Year ended June 30, 2019 Finding Number: 2019-007 Federal Agency: U.S. Department of Homeland Security Pass-through Agency: Massachusetts Executive Office of Public Safety & Security Program: Homeland Security Grant Program CFDA#: 97.067 Award numbers: Boston FFY17 UASI Award years: October 30, 2017 to June 30, 2020 Finding: Internal Control and Compliance over Payroll Costs Prior Year Finding: No Type of Finding: Significant Deficiency Criteria In accordance with 2 CFR 200.430(i)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both Federally assisted and all other activities compensated by the non Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Additionally, 2 CFR 200.303 indicates that non Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of allowable costs associated with payroll charges, we noted that the City?s Office of Emergency Management (OEM) documents time and attendance of employees on daily timesheets signed by the employee, and ensures salary and wage distribution to the Homeland Security Grant Program award through review and approval of employee timesheets by the Assistant Program Director. However, for 2 payroll transactions, timesheets were not reviewed and approved by the assistant program director. Cause This appears to be the result of an insufficient policy and lack of compensating controls when the Assistant Program Director is unavailable to approve timesheets. Effect Insufficient review of department timesheets or other time allocation documentation increase the risk of inaccurate payroll costs being considered for allocation to a grant award. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: Questioned costs of $5,117, for unapproved payroll charges, were charged to CFDA No. 97.067. Award No. Boston FFY17 UASI. Recommendation: We recommend that OEM enhance its policies and procedures to include the review of employees? time allocation by another member of program management while the Program Director is away to ensure time charged to the award is appropriate. View of Responsible Officials from the Auditee: OEM will have the Staff Assistant (the Staff) send a weekly email reminder for all staff to complete timesheets for the immediate past work week. Staff will be required to complete and submit their signed time sheets no later than the Monday immediately following the previous completed work week. Once the Staff member completes his/her timesheet and signs attesting to the accuracy of the time recorded, they shall submit a hard copy to their supervisor. The supervisor will then forward the time sheet to the Deputy Director of Administration or in their absence, the Deputy Director of Operations, for confirmation and approval of time worked or used. After authorizing the timesheets, the Deputy Director of Administration or the Deputy of Director of Operations will forward the hard copies to the Administration and Finance Manager for cross checking and reconciliation of time in BAIS HR. Approved time sheets are filed in the employee?s Department personnel files.

CITY OF BOSTON, MASSACHUSETTS Schedule of Findings and Questioned Costs Year ended June 30, 2019 Finding Number: 2019-008 Federal Agency: U.S. Department of Homeland Security Pass-through Agency: Massachusetts Executive Office of Public Safety & Security Program: Homeland Security Grant Program CFDA#: 97.067 Award numbers: Boston FFY 15 UASI; Boston FFY16 UASI, Boston FFY 17 UASI; Boston FFY 18 UASI Award years: October 1, 2018 to September 30, 2019 Finding: Internal Control and Compliance over Subrecipient Monitoring Prior Year Finding: No Type of Finding: Significant Deficiency Criteria 2 CFR section 200.331(a) indicates that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification: (1) Federal Award Identification. ? Subrecipient?s name (which must match registered name in DUNS); ? Subrecipient?s DUNS number (see ? 200.32 Data Universal Numbering System (DUNS) number); ? Federal Award Identification Number (FAIN); ? Federal award date; ? Subaward Period of Performance Start and End Date; ? Amount of Federal Funds Obligated by this action; ? Total Amount of Federal Funds Obligated to the subrecipient; ? Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; ? Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); ? Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity; ? CFDA Number and Name; the pass-through entity must identify the dollar amount made available under each Federal award and the CFDA number at time of disbursement; ? Identification of whether the award is R&D; and ? Indirect cost rate for the Federal award (including if the de minimis rate is charged per ? 200.414 Indirect (F&A) costs). (2) All requirements imposed by the pass through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award. (3) Any additional requirements that the pass through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports; (4) An approved Federally recognized indirect cost rate negotiated between the subrecipient and the Federal government or, if no such rate exists, either a rate negotiated between the pass through entity and the subrecipient (in compliance with this part), or a de minimis indirect cost rate as defined in ? 200.414 Indirect (F&A) costs, paragraph (b) of this part. (5) A requirement that the subrecipient permit the pass through entity and auditors to have access to the subrecipient?s records and financial statements as necessary for the passthrough entity to meet the requirements of this section, ? 200.300 Statutory and national policy requirements through 200.309 Period of performance, and Subpart F ? Audit Requirements of this part; and (6) Appropriate terms and conditions concerning closeout of the subaward. Condition Based on a review of the original Memorandum of Agreement (MOA) document between the City?s Office of Emergency Management (OEM) and its 9 subrecipients and subsequent addendums, it was noted that such documents did not contain all of the required elements of 2 CFR Section 200.331(a) listed above. For all 9 subrecipients, the MOA did not contain the subrecipient?s DUNS number. The most recent addendums for the period April 1, 2019 through June 30, 2021 contained the subrecipient?s DUNS number for only 2 of the 9 subrecipients. Cause This appears to be due to the MOA being a standard template which did not include all of the required elements of 2CFR Section 200.331(a). Effect OEM is not in compliance with subrecipient notification requirements. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation: We recommend that OEM execute an updated MOA with its subrecipients that expressly includes all information description in 2 CFR section 200.331(a)(1) as required by the Uniform Guidance. View of Responsible Officials from the Auditee: OEM will ensure that all required information is incorporated into the body of sub-recipient documents. All of the required information will be included singularly or cumulatively through the following sub-recipient documents: MOA, Schedule of Expenditures of Federal Awards letters, Award Budget Agreements through Jurisdictional Points of Contact and any project Award Letters.

CITY OF BOSTON, MASSACHUSETTS Schedule of Findings and Questioned Costs Year ended June 30, 2019 Finding Number: 2019-009 Federal Agency: U.S. Department of Homeland Security Pass-through Agency: Massachusetts Executive Office of Public Safety & Security Program: Homeland Security Grant Program CFDA#: 97.067 Award numbers: Boston FFY 15 UASI; Boston FFY16 UASI, Boston FFY 17 UASI; Boston FFY 18 UASI and Boston FFY19 UASI Award years: October 1, 2017 to September 30, 2018 and October 1, 2018 to September 30, 2019 Finding: Internal Control and Compliance over Subrecipient Monitoring Prior Year Finding: No Type of Finding: Significant Deficiency Criteria According to 2 CFR 200.331(b), a pass through entity must evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring, which may include consideration of such factors as: ? The subrecipient?s prior experience with the same or similar subawards; ? The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F ? Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; ? Whether the subrecipient has new personnel or new or substantially changed systems; and ? The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Also, according to 2 CFR 200.331(d), a pass through entity must: ? Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. ? Follow up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass through entity detected through audits, on site reviews, and other means. Condition Based on our testwork, it was noted that the City?s Office of Emergency Management (OEM) did not perform a formal evaluation of each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring to be performed. Further, our review of program monitoring documentation for our sample of 9 of the population of 9 subrecipients indicated that, although OEM performed subrecipient monitoring in fiscal year 2019, OEM did not follow-up with the 3 out of 9 subrecipients to ensure that the subrecipient took timely and appropriate action on reported noncompliance. Cause This appears to be due to inadequate policies and procedures surrounding both the initial risk assessment of the subrecipients, as well as follow up over the subrecipients when issues of noncompliance are identified during program monitoring reviews. Effect OEM is not in compliance with the requirements related to evaluating each subrecipient?s risk of noncompliance for purposes of determining appropriate subrecipient monitoring, and ensuring that subrecipients take timely and appropriate action on all deficiencies pertaining to Homeland Security Grant Program funding provided to the subrecipient. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation: We recommend that OEM implement control procedures to ensure that each subrecipient is evaluated for risk of noncompliance for determining appropriate subrecipient monitoring, and to ensure that subrecipients take timely and appropriate action on all areas of noncompliance identified through program monitoring reviews. View of Responsible Officials from the Auditee: OEM will send all Jurisdictional Points of Contact a Schedule of Expenditures of Federal Awards letter by October 1st covering the previous fiscal year. A risk assessment questionnaire will be included to be completed by an authorized person from the recipient community. Any questionnaire not returned by December 31st will be sent a 2nd request. A site visit will be planned for any jurisdiction that hasn?t complied by January 31st. Uniform Guidance reports will be verified in the Federal Audit Clearinghouse after the Federal deadline of March 31st. Any discrepancies in CFDA 97.067 reported, or audit findings that may pertain to the program will require reconciliation from the jurisdiction. The Administration and Finance Manager will document all interactions related to this process. Inventory site visits will be performed at least once per calendar year for each jurisdiction. Visits will be to ensure that OEM and the jurisdiction(s) are in agreement with the appropriate accounting of and to ensure the proper operational capacity of UASI funded equipment. Jurisdictions further, have a reporting requirement to ensure proper notice and documentation of the disposition of UASI funded equipment.

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