EIN: 046001404
UEI: PAK6PY31SJ53
Audited by: CliftonLarsonAllen LLP
Oversight agency: 21 [Department of the Treasury]
View federal awards & risk assessment →
Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 30, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 30, 2026 (28 days from today).
What is a management decision? →Significant Deficiency in Internal Control Over Compliance and Other Noncompliance Matter Child Nutrition Cluster, ALN’s 10.553 & 10.555 Federal Award Identification Number (FAIN) and Year: 2025; FAIN not available. Pass-through Agency: Massachusetts Department of Elementary and Secondary Education Pass-through Identifying Number: 09-207 Award Period: July 1, 2024 through June 30, 2025 Compliance Requirement: Reporting Criteria or Specific Requirement: School food authorities and sponsors must submit monthly claims for reimbursement of meals served to eligible students within sixty (60) days following the last day of the month covered by the claim in accordance with CFR Title 7, sections 210.8, 220.11, 215.10, and 225.15(c). Each month’s claim for reimbursement and all data used in the claims review process must be maintained on file, and failure to maintain such records may be grounds for denial of reimbursement for meals served during the period covered by the records in question. Condition and Context: For one (1) of thirty-seven (37) claims for reimbursement selected for testing, the meal count within the data used in the claims review process did not categorically agree with the corresponding meal count identified within the monthly claim for reimbursement submitted to the State. Questioned Costs: None above the reportable threshold. Cause: The standard internal controls implemented for the review and submission of monthly claims for reimbursement were not applicable for the discrepancy observed resulting in a categorical difference (2) between the meal count data compared to meals claimed for reimbursement from the State. Effect: Noncompliance with the federal program occurred as the City claimed a reimbursement which did not categorically align with the supporting meal count record. Repeat Finding: Yes, 2024-002 Recommendation: We recommend the review and approval process over monthly claims for reimbursement be strengthened to enhance the prevention of discrepancies between the claim for reimbursement and underlying data. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Significant Deficiency in Internal Control Over Compliance and Other Noncompliance Matter Child Nutrition Cluster, ALN’s 10.553 & 10.555 Federal Award Identification Number (FAIN) and Year: 2025; FAIN not available. Pass-through Agency: Massachusetts Department of Elementary and Secondary Education Pass-through Identifying Number: 09-207 Award Period: July 1, 2024 through June 30, 2025 Compliance Requirement: Reporting Criteria or Specific Requirement: School food authorities and sponsors must submit monthly claims for reimbursement of meals served to eligible students within sixty (60) days following the last day of the month covered by the claim in accordance with CFR Title 7, sections 210.8, 220.11, 215.10, and 225.15(c). Each month’s claim for reimbursement and all data used in the claims review process must be maintained on file, and failure to maintain such records may be grounds for denial of reimbursement for meals served during the period covered by the records in question. Condition and Context: For one (1) of thirty-seven (37) claims for reimbursement selected for testing, the meal count within the data used in the claims review process did not categorically agree with the corresponding meal count identified within the monthly claim for reimbursement submitted to the State. Questioned Costs: None above the reportable threshold. Cause: The standard internal controls implemented for the review and submission of monthly claims for reimbursement were not applicable for the discrepancy observed resulting in a categorical difference (2) between the meal count data compared to meals claimed for reimbursement from the State. Effect: Noncompliance with the federal program occurred as the City claimed a reimbursement which did not categorically align with the supporting meal count record. Repeat Finding: Yes, 2024-002 Recommendation: We recommend the review and approval process over monthly claims for reimbursement be strengthened to enhance the prevention of discrepancies between the claim for reimbursement and underlying data. Views of Responsible Officials: Management agrees with the finding.
Child Nutrition Cluster, ALN’s 10.553 & 10.555 Recommendation: We recommend the review and approval process over monthly claims for reimbursement be strengthened to enhance the prevention of discrepancies between the claim for reimbursement and underlying data. Explanation of disagreement with audit finding: Management agrees with the finding. Action taken in response to finding: Newton operated the National School Lunch Program (NSLP) during the Extended School Year (ESY) for the first time during the summer 2024, which created a reporting challenge. Students from across the district's 23 schools attended ESY in seven (7) schools/sites, but their school-year home schools could not be changed in the Student Information System (Aspen). Therefore, student meal counts reported to their home school on the FP9 but had to be reported on the DESE School Report for the ESY school/site they attended. Given the system interface complexities, some counts had to be manually entered, for which two (2) meal counts were incorrectly entered for breakfast versus lunch. Given that the district did not operate the School Breakfast Program (SBP) and did not serve breakfast, these two (2) manual errors were counted as lunch counts when entered for the School Report. The total meal count did match on the FP9 and School Report. For this inconsistency, the correct action should have been to manually update these two counts in the Point of Sale system (Mosaic) so that the two breakfast counts reflected correctly as lunch counts. Name(s) of the contact person(s) responsible for corrective action: Amy Mistrot, NPS Director of Business Operations. Planned completion date for corrective action plan: Newton was able to set conditional parameters in Aspen for ESY 2025 so that the student meal counts reported to their ESY school/site versus their home school, so this reporting issue was corrected the following summer.
2024-002
FAC accepted this audit on March 31, 2025 — management decision was due October 1, 2025.
2024-001 COVID-19 Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027 Federal Award Identification Number: Not Available. Award Period: March 3, 2021 through December 31, 2024 Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The United States Code of Federal Regulations (CFR) Title 2 Part 200.214 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For one vendor in our audit sample of eight, documentation was not provided to support that the City verified the vendor was not debarred or suspended from participation in Federal assistance programs or activities for the fiscal year ended June 30, 2024. Questioned Costs: None. The vendor was not suspended or debarred. Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities prior to entering into a transaction. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2024-001 COVID-19 Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027 Federal Award Identification Number: Not Available. Award Period: March 3, 2021 through December 31, 2024 Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The United States Code of Federal Regulations (CFR) Title 2 Part 200.214 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For one vendor in our audit sample of eight, documentation was not provided to support that the City verified the vendor was not debarred or suspended from participation in Federal assistance programs or activities for the fiscal year ended June 30, 2024. Questioned Costs: None. The vendor was not suspended or debarred. Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities prior to entering into a transaction. Views of Responsible Officials: Management agrees with the finding.
Action taken in response to finding: The Comptroller’s Office has reiterated procedures to departments to ensure they document the verifications with either contract certifications and/or screenshots of SAM.gov searches. Name(s) of the contact person(s) responsible for corrective action: Stephen Curley, Comptroller. Planned completion date for corrective action plan: Completed. An email was sent out to all department heads to distribute and reaffirm with staff that they need to ensure all vendors paid from federal funding are not suspended or debarred from receiving federal funds which included procedures on how to confirm this.
2024-002 Child Nutrition Cluster, ALN’s 10.553 & 10.555 Federal Award Identification Number (FAIN) and Year: 2024; FAIN not available. Pass-through Agency: Massachusetts Department of Elementary and Secondary Education Pass-through Identifying Number: 09-207 Award Period: July 1, 2023 through June 30, 2024 Compliance Requirement: Reporting Criteria or Specific Requirement: School food authorities and sponsors must submit monthly claims for reimbursement of meals served to eligible students within sixty (60) days following the last day of the month covered by the claim in accordance with CFR Title 7, sections 210.8, 220.11, 215.10, and 225.15(c). Each month’s claim for reimbursement and all data used in the claims review process must be maintained on file, and failure to maintain such records may be grounds for denial of reimbursement for meals served during the period covered by the records in question. Condition and Context: For six (6) of twenty-eight (28) claims for reimbursement selected in our statistically valid audit sample, the meal counts within the data used in the claims review process did not agree with the corresponding meal counts identified within the monthly claims for reimbursement submitted to the State. Upon further review, it was determined that the September 2023 claim for reimbursement submitted to the State was inaccurately prepared for all 23 schools for which meals were claimed for reimbursement. Questioned Costs: $284,295; which represents the difference in reimbursements claimed versus eligible reimbursements supported by the claims data. Cause: Internal controls implemented over the review and submission of monthly claims for reimbursement were not operating effectively. Effect: Noncompliance with the federal program occurred as the City claimed reimbursements for unsupported meal counts. Repeat Finding: No. Recommendation: We recommend the review and approval process over monthly claims for reimbursement be strengthened to ensure discrepancies between the claim for reimbursement and underlying data are detected and corrected timely. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2024-002 Child Nutrition Cluster, ALN’s 10.553 & 10.555 Federal Award Identification Number (FAIN) and Year: 2024; FAIN not available. Pass-through Agency: Massachusetts Department of Elementary and Secondary Education Pass-through Identifying Number: 09-207 Award Period: July 1, 2023 through June 30, 2024 Compliance Requirement: Reporting Criteria or Specific Requirement: School food authorities and sponsors must submit monthly claims for reimbursement of meals served to eligible students within sixty (60) days following the last day of the month covered by the claim in accordance with CFR Title 7, sections 210.8, 220.11, 215.10, and 225.15(c). Each month’s claim for reimbursement and all data used in the claims review process must be maintained on file, and failure to maintain such records may be grounds for denial of reimbursement for meals served during the period covered by the records in question. Condition and Context: For six (6) of twenty-eight (28) claims for reimbursement selected in our statistically valid audit sample, the meal counts within the data used in the claims review process did not agree with the corresponding meal counts identified within the monthly claims for reimbursement submitted to the State. Upon further review, it was determined that the September 2023 claim for reimbursement submitted to the State was inaccurately prepared for all 23 schools for which meals were claimed for reimbursement. Questioned Costs: $284,295; which represents the difference in reimbursements claimed versus eligible reimbursements supported by the claims data. Cause: Internal controls implemented over the review and submission of monthly claims for reimbursement were not operating effectively. Effect: Noncompliance with the federal program occurred as the City claimed reimbursements for unsupported meal counts. Repeat Finding: No. Recommendation: We recommend the review and approval process over monthly claims for reimbursement be strengthened to ensure discrepancies between the claim for reimbursement and underlying data are detected and corrected timely. Views of Responsible Officials: Management agrees with the finding.
Action taken in response to finding: The September 2023 claiming error was caused in part by the Food Service Management Company manually entering the claims in the DESE Portal incorrectly. Newton took responsibility for entering the claims for the balance of FY24. For FY25, Newton now uploads the meal count data from Mosaic, the point-of-sale software, directly into the DESE portal. That upload is done by the Business Operations Analyst and then approved by the Director of Business Operations, which removes substantial exposure for human error during data entry and creates two levels of review prior to approval and submission. The other five discrepancies between the source counts and what was submitted for the DESE claim was to address identified human error in advance to ensure that the monthly claim was accurate. For the September 2023 error, Newton has submitted a Claim Adjustment Form to DESE to provide guidance for the necessary action steps. Name(s) of the contact person(s) responsible for corrective action: Amy Mistrot, NPS Director of Business Operations. Planned completion date for corrective action plan: The internal controls to reduce data entry errors have been implemented and are consistently being used. DESE will provide guidance for the Claim Adjustment Request to address the September 2023 error, which Newton will then implement.
2024-003 HOME Investment Partnerships, ALN 14.239 Federal Award Identification Number and Year: MC-DC250213, 2022-2030 Award Period: September 16, 2022 through September 1, 2030 Compliance Requirement: Subrecipient Monitoring Criteria or Specific Requirement: CFR Title 2 section 200.332(a) states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes, amongst other required information, the subrecipients’ unique entity number (UEI). 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. Condition and Context: For three (3) of five (5) subrecipients out of five in our audit sample, the subrecipients’ UEI’s were not included in the subaward document. Questioned Costs: None. Cause: Procedures were not implemented to ensure subrecipient UEI's were accurate and properly included in the subaward documents. Effect: Noncompliance with federal requirements occurred. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to ensure accurate UEI's are obtained and included within subaward documents. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2024-003 HOME Investment Partnerships, ALN 14.239 Federal Award Identification Number and Year: MC-DC250213, 2022-2030 Award Period: September 16, 2022 through September 1, 2030 Compliance Requirement: Subrecipient Monitoring Criteria or Specific Requirement: CFR Title 2 section 200.332(a) states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes, amongst other required information, the subrecipients’ unique entity number (UEI). 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. Condition and Context: For three (3) of five (5) subrecipients out of five in our audit sample, the subrecipients’ UEI’s were not included in the subaward document. Questioned Costs: None. Cause: Procedures were not implemented to ensure subrecipient UEI's were accurate and properly included in the subaward documents. Effect: Noncompliance with federal requirements occurred. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to ensure accurate UEI's are obtained and included within subaward documents. Views of Responsible Officials: Management agrees with the finding.
Action taken in response to finding: Program managers will include the UEI numbers for all subrecipients on their contracts in the future. Name(s) of the contact person(s) responsible for corrective action: Shaylyn Davis-Iannaco, Housing Program Manager; Lara Kritzer, Director of Housing and Community Development. Planned completion date for corrective action plan: This will be implemented with all future contracts in FY26, beginning in July 2025.
2024-004 Community Development Block Grants, ALN 14.218 Federal Award Identification Number and Year: B-23-MC-25-0019, 2024 Award Period: July 1, 2023 through June 30, 2024 Compliance Requirement: Allowable Costs/Cost Principles Criteria or Specific Requirement: (CFR) Title 2 Part 200.430 indicates charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Such records must also reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Condition and Context: For one of forty payroll disbursements in our sample, evidence of management's review of time and effort was not provided. Questioned Costs: None. Cause: Procedures were not implemented effectively to ensure all attestations of time and effort were reviewed and approved by supervising officials. Effect: While time and effort dedicated to cost objectives was documented for the instance in questions, the risk of noncompliance with federal program requirements is present due to the lack of approval from the payroll documentation. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to ensure management's review and approval of time and effort attestation is present on supporting documentation maintained for payroll costs. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2024-004 Community Development Block Grants, ALN 14.218 Federal Award Identification Number and Year: B-23-MC-25-0019, 2024 Award Period: July 1, 2023 through June 30, 2024 Compliance Requirement: Allowable Costs/Cost Principles Criteria or Specific Requirement: (CFR) Title 2 Part 200.430 indicates charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Such records must also reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Condition and Context: For one of forty payroll disbursements in our sample, evidence of management's review of time and effort was not provided. Questioned Costs: None. Cause: Procedures were not implemented effectively to ensure all attestations of time and effort were reviewed and approved by supervising officials. Effect: While time and effort dedicated to cost objectives was documented for the instance in questions, the risk of noncompliance with federal program requirements is present due to the lack of approval from the payroll documentation. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to ensure management's review and approval of time and effort attestation is present on supporting documentation maintained for payroll costs. Views of Responsible Officials: Management agrees with the finding.
Action taken in response to finding: Program staff will continue to ensure that all timesheets are signed by the division head Name(s) of the contact person(s) responsible for corrective action: Janet Antonellis, CDBG Administrative Assistant, Svetlana Taksa, Fiscal Manager, and Lara Kritzer, Director of Housing and Community Development. Planned completion date for corrective action plan: This has been and will continue to be implemented with all future timesheets.
2024-005 Community Development Block Grants, ALN 14.218 Federal Award Identification Number and Year: B-23-MC-25-0019, 2024 Award Period: July 1, 2023 through June 30, 2024 Compliance Requirement: Reporting Criteria or Specific Requirement: 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. 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. Such internal control encompasses compliance with reporting requirements of the federal award. Condition and Context: For one of three subawards tested in our statistically valid sample, the City did not provide documentation supporting the reporting of the subaward to FSRS in accordance with FFATA requirements. For both of the two PR29 CDBG Cash on Hand Quarterly Reports tested in our statistically valid sample, the City improperly calculated the beginning cash on hand at $0.00. Questioned Costs: None. Cause: Procedures were not implemented effectively to ensure the required reports were completed and submitted in accordance with the terms and conditions of the federal award. Effect: Noncompliance occurred as these reports were not completed and processed in accordance with federal award requirements. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to ensure federally required reports are completed and processed in accordance with the requirements of the federal awards. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2024-005 Community Development Block Grants, ALN 14.218 Federal Award Identification Number and Year: B-23-MC-25-0019, 2024 Award Period: July 1, 2023 through June 30, 2024 Compliance Requirement: Reporting Criteria or Specific Requirement: 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. 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. Such internal control encompasses compliance with reporting requirements of the federal award. Condition and Context: For one of three subawards tested in our statistically valid sample, the City did not provide documentation supporting the reporting of the subaward to FSRS in accordance with FFATA requirements. For both of the two PR29 CDBG Cash on Hand Quarterly Reports tested in our statistically valid sample, the City improperly calculated the beginning cash on hand at $0.00. Questioned Costs: None. Cause: Procedures were not implemented effectively to ensure the required reports were completed and submitted in accordance with the terms and conditions of the federal award. Effect: Noncompliance occurred as these reports were not completed and processed in accordance with federal award requirements. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to ensure federally required reports are completed and processed in accordance with the requirements of the federal awards. Views of Responsible Officials: Management agrees with the finding.
Action taken in response to finding: Program managers will continue working to ensure that all FAFTA forms are appropriately reported in SAM.gov Name(s) of the contact person(s) responsible for corrective action: Sharon Cullins, Community Development Planner, and Lara Kritzer, Director of Housing and Community Development. Planned completion date for corrective action plan: This will be implemented immediately.
FAC accepted this audit on March 28, 2024 — management decision was due September 28, 2024.
UNITED STATES DEPARTMENT OF EDUCATION Significant Deficiency in Internal Control over Compliance 2023-001 Special Education Cluster, ALN. 84.027, 84.173 Award Period: July 1, 2022 – June 30, 2023 Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.214 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For the one vendor in our audit sample, documentation was not provided to support that the City verified the vendor was not debarred or suspended from participation in Federal assistance programs or activities for the fiscal year 2023 time period. Questioned Costs: None. The vendor was not suspended or debarred. Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴UNITED STATES DEPARTMENT OF EDUCATION Significant Deficiency in Internal Control over Compliance 2023-001 Special Education Cluster, ALN. 84.027, 84.173 Award Period: July 1, 2022 – June 30, 2023 Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.214 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For the one vendor in our audit sample, documentation was not provided to support that the City verified the vendor was not debarred or suspended from participation in Federal assistance programs or activities for the fiscal year 2023 time period. Questioned Costs: None. The vendor was not suspended or debarred. Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
2023-001 Special Education Cluster – Assistance Listing Numbers 84.027, 84.173 Recommendation: We recommend procedures be strengthened to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Explanation of disagreement with audit finding: There is no disagreement with the audit finding and agrees that the vendors were not suspended or disbarred. Action taken in response to finding: The School Department has implemented procedures to document the verifications with either contract certifications and/or screenshots of SAM.gov searches. Name(s) of the contact person(s) responsible for corrective action: Amy Mistrot, NPS Director of Business Operations. Planned completion date for corrective action plan: Completed.
Significant Deficiency in Internal Control over Compliance 2023-002 Special Education Cluster, ALN. 84.027, 84.173 Award Period: July 1, 2022 – June 30, 2023 Compliance Requirement: Allowable Costs/Cost Principles Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.430 indicates charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Such records must also reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Condition and Context: For all of the payroll disbursements in our sample, evidence of management review of time and effort was not provided. Questioned Costs: None. Cause: Procedures were not in place to document the management review of time and effort. Effect: Significant deficiency in internal controls. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to document and maintain on file the management review of time and effort. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Significant Deficiency in Internal Control over Compliance 2023-002 Special Education Cluster, ALN. 84.027, 84.173 Award Period: July 1, 2022 – June 30, 2023 Compliance Requirement: Allowable Costs/Cost Principles Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.430 indicates charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Such records must also reasonably reflect the total activity for which the employee is compensated by the non-Federal entity. Condition and Context: For all of the payroll disbursements in our sample, evidence of management review of time and effort was not provided. Questioned Costs: None. Cause: Procedures were not in place to document the management review of time and effort. Effect: Significant deficiency in internal controls. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to document and maintain on file the management review of time and effort. Views of Responsible Officials: Management agrees with the finding.
2023-002 Special Education Cluster – Assistance Listing Numbers 84.027, 84.173 Recommendation: We recommend procedures be strengthened to document and maintain on file the management review of time and effort. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The School Department has reviewed the finding and is in the planning process with corrective actions. Name(s) of the contact person(s) responsible for corrective action: Amy Mistrot, NPS Director of Business Operations. Planned completion date for corrective action plan: NPS has completed the first of two required Time and Effort Certifications for FY24. We will add managerial review of the completed certifications as an additional level of oversight for both the first and second certifications this year and continue this practice henceforth.
UNITED STATES DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Material Weakness in Internal Control over Compliance and Material Noncompliance 2023-003 HOME Investment Partnership Program, ALN. 14.239 Award Period: July 1, 2022 – June 30, 2023 Compliance Requirement: Subrecipient Monitoring Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.332 – Requirements for Pass- Through Entities states, in part, that all pass-through entities 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. Condition and Context: For one (1) vendor in our sample of five (5) in a population of 13, documentation of monitoring was not provided. For one (1) vendor in our sample of five (5) in a population of 13, there was no evidence of management review of monitoring procedures. Questioned Costs: None Cause: Procedures were not in place to fully document subrecipient monitoring for all subrecipients. Effect: Noncompliance with the federal grant program occurred. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to fully document subrecipient monitoring for all subrecipients. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴UNITED STATES DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Material Weakness in Internal Control over Compliance and Material Noncompliance 2023-003 HOME Investment Partnership Program, ALN. 14.239 Award Period: July 1, 2022 – June 30, 2023 Compliance Requirement: Subrecipient Monitoring Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.332 – Requirements for Pass- Through Entities states, in part, that all pass-through entities 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. Condition and Context: For one (1) vendor in our sample of five (5) in a population of 13, documentation of monitoring was not provided. For one (1) vendor in our sample of five (5) in a population of 13, there was no evidence of management review of monitoring procedures. Questioned Costs: None Cause: Procedures were not in place to fully document subrecipient monitoring for all subrecipients. Effect: Noncompliance with the federal grant program occurred. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to fully document subrecipient monitoring for all subrecipients. Views of Responsible Officials: Management agrees with the finding.
2023-003 HOME Investment Partnership Program – Assistance Listing Number 14.239 Recommendation: We recommend procedures be strengthened to fully document subrecipient monitoring for all subrecipients. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We are in the process of strengthening our subrecipient monitoring procedures and tracking process now that new staff have come on board in the last year. Name(s) of the contact person(s) responsible for corrective action: Allison McIntyre, Housing Development Planner; Shaylyn Davis-Iannaco, Housing Program Manager; Lara Kritzer, Director of Housing and Community Development. Planned completion date for corrective action plan: July 2024
Material Weakness in Internal Control over Compliance and Material Noncompliance 2023-004 HOME Investment Partnership Program, ALN. 14.239 Award Period: July 1, 2022 – June 30, 2023 Compliance Requirement: Special Tests and Provisions Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 24 Part 92.504(d) states that during the period of affordability, the participating jurisdiction must perform on-site inspections of HOME-assisted rental housing to determine compliance with the property standards of § 92.251 and to verify the information submitted by the owners in accordance with the requirements of § 92.252. The inspections must be in accordance with the inspection procedures that the participating jurisdiction establishes to meet the inspection requirements of § 92.251. Condition and Context: For one (1) out of nine (9) inspections selected for testing in our audit sample, the inspection was not conducted within the required timeframe in accordance with federal requirements. Questioned Costs: None Cause: Procedures were not in place to perform inspections timely for all inspections. Effect: Noncompliance with the federal grant program occurred. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to perform inspections timely for all inspections. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Material Weakness in Internal Control over Compliance and Material Noncompliance 2023-004 HOME Investment Partnership Program, ALN. 14.239 Award Period: July 1, 2022 – June 30, 2023 Compliance Requirement: Special Tests and Provisions Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 24 Part 92.504(d) states that during the period of affordability, the participating jurisdiction must perform on-site inspections of HOME-assisted rental housing to determine compliance with the property standards of § 92.251 and to verify the information submitted by the owners in accordance with the requirements of § 92.252. The inspections must be in accordance with the inspection procedures that the participating jurisdiction establishes to meet the inspection requirements of § 92.251. Condition and Context: For one (1) out of nine (9) inspections selected for testing in our audit sample, the inspection was not conducted within the required timeframe in accordance with federal requirements. Questioned Costs: None Cause: Procedures were not in place to perform inspections timely for all inspections. Effect: Noncompliance with the federal grant program occurred. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to perform inspections timely for all inspections. Views of Responsible Officials: Management agrees with the finding.
2023-004 HOME Investment Partnership Program – Assistance Listing Number 14.239 Recommendation: We recommend procedures be strengthened to perform inspections timely for all inspections. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Program management has reviewed the finding and is in the planning process for the following corrective actions. Redevelop and maintain a database of HOME units to track completed inspections. Strengthen procedures for tracking the monitoring dates of HOME units within the Consortium and the timely completion of their inspections. Name(s) of the contact person(s) responsible for corrective action: Allison McIntyre, Housing Development Planner; Shaylyn Davis-Iannaco, Housing Program Manager; Lara Kritzer, Director of Housing and Community Development. Planned completion date for corrective action plan: July 2024
FAC accepted this audit on March 30, 2023 — management decision was due September 30, 2023.
FAC accepted this audit on September 20, 2022 — management decision was due March 20, 2023.
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For the one vendor in our statistically valid sample, documentation was not provided to support that the City verified the vendor was not debarred or suspended from participation in Federal assistance programs or activities for the fiscal year 2021 time period. Questioned Costs: None. The vendor was not suspended or debarred. Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors? debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For the one vendor in our statistically valid sample, documentation was not provided to support that the City verified the vendor was not debarred or suspended from participation in Federal assistance programs or activities for the fiscal year 2021 time period. Questioned Costs: None. The vendor was not suspended or debarred. Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors? debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
Recommendation: We recommend procedures be strengthened to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Contract #C-3823, Article III Food Service Program, 3.11 Debarment Certification states, ?The FSMC shall complete and submit to the SFA the United States Department of Agriculture (USDA) Certification Regarding Debarment. The certification must accompany the four (4) additional one-year renewals. [7CFR section 3017.300]? Whitsons did not include the Certificate in the FY21 contract amendment/extension. Whitsons? District Manager for Newton was notified of the omission on 2/24/22 and the requirement for inclusion in the FY23 renewal on 3/15/22. NPS Purchasing was reminded of the Debarment Certification requirement on 4/4/22 when they inquired about the timeline for the FY23 contract renewal. Name(s) of the contact person(s) responsible for corrective action: Amy Mistrot, NPS Director of Business Operations Planned completion date for corrective action plan: August 15, 2022. The FY23 contract renewal has been delayed pending the MA state budget confirmation to determine if universally-free meals will be extended at the state level.
Criteria or Specific Requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal control over federal awards to ensure compliance with federal statutes, regulations and the terms and conditions of the federal award. Condition and Context: For six (6) out of forty (40) general disbursements in our statistically valid sample, appropriate supporting documentation was not provided by the City. Questioned Costs: $45,627 Cause: Procedures were not adhered to for maintaining sufficient documentation for all grant disbursements. Effect: Noncompliance with the federal grant program occurred. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to maintain sufficient documentation for all grant disbursements. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Criteria or Specific Requirement: 2 CFR, Part 200, 200.303 requires an auditee to establish and maintain effective internal control over federal awards to ensure compliance with federal statutes, regulations and the terms and conditions of the federal award. Condition and Context: For six (6) out of forty (40) general disbursements in our statistically valid sample, appropriate supporting documentation was not provided by the City. Questioned Costs: $45,627 Cause: Procedures were not adhered to for maintaining sufficient documentation for all grant disbursements. Effect: Noncompliance with the federal grant program occurred. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to maintain sufficient documentation for all grant disbursements. Views of Responsible Officials: Management agrees with the finding.
Recommendation: We recommend procedures be strengthened to maintain sufficient documentation for all grant disbursements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Three of the six disbursements that are listed on the Audit Report are related to transfer bills received from the Cousens Fund, Newton?s Municipal Trust. Historically, the Planning Department has collected the total payment made by the Cousens Fund on behalf of their client to the utility or rental company, as the total payment may differ from the individual bills submitted with the application. The Cousens Fund was contractually required to save and file the individual bills submitted with the application for assistance. These documents are generally reviewed during a monitoring visit. ? The Cousens Fund was not selected for funding in FY23; however, should they be selected in future years, Planning Staff will ensure that all relevant invoices and documentation are submitted with the transfer bill requests. ? Moving forward, the Planning Department will require all subrecipient?s to submit all relevant backup documentation to be reviewed with each invoice, rather than during a periodic monitoring visit. The other three disbursements that are listed on the Audit Report are related to transfer bills received from Newton?s Purchasing Department. The Planning Department sent a Verizon Landline bill along with the supporting spreadsheet that showed the total bill amount and the payment made by the Housing and Community Development Division of the Planning Department. When asked for the supporting invoices from the Purchasing Department for the postage and printing bills, the Planning Department was given on the spreadsheets summarizing the balance owed by the Housing and Community Development Division. ? Moving forward, the Planning Department will work with both the Comptroller?s Department and the Purchasing Department to ensure copies of the relevant invoices are sent to the Planning Department and filed appropriately. Lastly, Shaylyn Davis, the Senior Community Development Planner will work with Nika Sandal, the Community Development Planner, to develop policies and procedures related to collecting backup documentation from nonprofit and municipal subrecipients to ensure compliance. Name(s) of the contact person(s) responsible for corrective action: - Nika Sandal, Community Development Planner - Amanda Berman, Director of Housing and Community Development Planned completion date for corrective action plan: - The Senior CD Planner and CD Planner will develop the Documentation Collection Policies and Procedures throughout the Summer of 2022 and will put these into practice for FY23.
Criteria or Specific Requirement: 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. Condition and Context: For two (2) out of six (6) FFATA reports selected for testing in our statistically valid sample, reports were submitted greater than one month after the subaward obligation date. For one (1) of out six (6) FFATA reports selected for testing in our statistically valid sample, a report was not submitted for the subaward obligation. Questioned Costs: None Cause: Procedures were not adhered to for complying with FFATA reporting requirements. Effect: Noncompliance with the federal grant program occurred. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to comply with FFATA reporting requirements. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Criteria or Specific Requirement: 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. Condition and Context: For two (2) out of six (6) FFATA reports selected for testing in our statistically valid sample, reports were submitted greater than one month after the subaward obligation date. For one (1) of out six (6) FFATA reports selected for testing in our statistically valid sample, a report was not submitted for the subaward obligation. Questioned Costs: None Cause: Procedures were not adhered to for complying with FFATA reporting requirements. Effect: Noncompliance with the federal grant program occurred. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to comply with FFATA reporting requirements. Views of Responsible Officials: Management agrees with the finding.
Recommendation: We recommend procedures be strengthened to comply with FFATA reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The following policy has been developed to ensure proper compliance with this requirement: The prime awardee is required to collect the following information from the first tier subawardee: - Name of the entity receiving the award - Amount and date of the award - Funding agency - Catalog of Federal Domestic Assistance (CFDA) number - Award title descriptive of the purpose of each funding action - Location of the subrecipient receiving the award and primary location of performance under the award, including city, state, congressional district, and country - DUNS number of subrecipient receiving the award and the parent entity of the subrecipient, should the entity be owned by another entity. This data is collected on the FFATA form. Monthly, or as necessary, Project Managers should input the first tier subaward?s FFATA form information into the spreadsheets. Select the applicable year and input the complete information to the sheet. Then, save the FFATA form into the ?FFATA Forms? folder. The information will then be input and reported into FSRS before the end of the month by the Community Development Planner. Additionally, the Planning Department has initiated monthly HUD Compliance Reporting meeting in order to discuss all contracts that have been executed or are about to be executed to ensure the timely submission of FFATA reports and other compliance reporting requirements. Name(s) of the contact person(s) responsible for corrective action: - Nika Sandal, Community Development Planner - Amanda Berman, Director of Housing and Community Development Planned completion date for corrective action plan: - Policy was implemented in early FY2022 and will continue to be followed throughout FY2023.
FAC accepted this audit on September 26, 2021 — management decision was due March 26, 2022.
UNITED STATES DEPARTMENT OF HOMELAND SECURITY Noncompliance and Significant Deficiency in Internal Control over Compliance 2020-001 Public Assistance Program, CFDA No. 97.036 Award Period: July 1, 2019 ? June 30, 2020 Compliance Requirement: Allowable Costs/Cost Principles Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.430 indicates charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Such records should support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on a federal award and a non-federal award. Condition and Context: Fifteen (15) of forty (40) payroll transactions in our statistically valid sample were not accurately supported by time and effort documentation. Questioned Costs: None in excess of the reportable threshold of the Uniform Grant Guidance. Cause: The City's internal controls surrounding the charges for salaries and wages was deficient in accurately supporting the charges with time and effort documentation. Effect: Noncompliance with the federal grant program occurred. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to accurately support all charges for salaries and wages with time and effort documentation. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴UNITED STATES DEPARTMENT OF HOMELAND SECURITY Noncompliance and Significant Deficiency in Internal Control over Compliance 2020-001 Public Assistance Program, CFDA No. 97.036 Award Period: July 1, 2019 ? June 30, 2020 Compliance Requirement: Allowable Costs/Cost Principles Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.430 indicates charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Such records should support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on a federal award and a non-federal award. Condition and Context: Fifteen (15) of forty (40) payroll transactions in our statistically valid sample were not accurately supported by time and effort documentation. Questioned Costs: None in excess of the reportable threshold of the Uniform Grant Guidance. Cause: The City's internal controls surrounding the charges for salaries and wages was deficient in accurately supporting the charges with time and effort documentation. Effect: Noncompliance with the federal grant program occurred. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to accurately support all charges for salaries and wages with time and effort documentation. Views of Responsible Officials: Management agrees with the finding.
To Whom It May Concern: The City of Newton, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2020. Audit period: July 1, 2019 through June 30, 2020 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Homeland Security 2020-001 Public Assistance Programs ? CFDA No. 97.036 Recommendation: We recommend procedures be strengthened to accurately support all charges for salaries and wages with time and effort documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procedures have been implemented to reconcile salaries and wages to time and effort documentation. Name(s) of the contact person(s) responsible for corrective action: Kimberly Ritcey Planned completion date for corrective action plan: Completed
FAC accepted this audit on February 11, 2020 — management decision was due August 11, 2020.
UNITED STATES DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Material Noncompliance and Material Weakness in Internal Control over Compliance 2019-001 HOME Investment Partnerships Program, CFDA No. 14.239 Award Period: July 1, 2018 ? June 30, 2019 Compliance Requirement: Subrecipient Monitoring Criteria or Specific Requirement: All pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes specific data elements 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 (2 CFR 200.331). Condition and Context: The City did not obtain subaward documents including the elements required by the Uniform Grant Guidance prior to the disbursement of grant funds to all five (5) subrecipients in our statistically valid sample. Additionally, the City did not obtain Uniform Grant Guidance audit reports from subrecipients who were required to have an annual audit in accordance with the Uniform Grant Guidance. Questioned Costs: None. Cause: Controls were not in place to ensure that subaward documents were obtained and that Uniform Grant Guidance audit reports were obtained prior to expending grant funds to subrecipients. Effect: Noncompliance with the federal grant program occurred. Repeat Finding: No. Recommendation: We recommend procedures be implemented to ensure that subaward documents are completed and executed prior to disbursing funds to subrecipients. The subaward documents should contain the elements required by the Uniform Grant Guidance. Additionally the City should obtain the annual audit reports from subrecipients who are required to have an audit in accordance with the Uniform Grant Guidance. Views of Responsible Officials: Management agrees with the finding. Please refer to the Corrective Action Plan.
Show full finding ▾Hide full finding ▴UNITED STATES DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Material Noncompliance and Material Weakness in Internal Control over Compliance 2019-001 HOME Investment Partnerships Program, CFDA No. 14.239 Award Period: July 1, 2018 ? June 30, 2019 Compliance Requirement: Subrecipient Monitoring Criteria or Specific Requirement: All pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes specific data elements 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 (2 CFR 200.331). Condition and Context: The City did not obtain subaward documents including the elements required by the Uniform Grant Guidance prior to the disbursement of grant funds to all five (5) subrecipients in our statistically valid sample. Additionally, the City did not obtain Uniform Grant Guidance audit reports from subrecipients who were required to have an annual audit in accordance with the Uniform Grant Guidance. Questioned Costs: None. Cause: Controls were not in place to ensure that subaward documents were obtained and that Uniform Grant Guidance audit reports were obtained prior to expending grant funds to subrecipients. Effect: Noncompliance with the federal grant program occurred. Repeat Finding: No. Recommendation: We recommend procedures be implemented to ensure that subaward documents are completed and executed prior to disbursing funds to subrecipients. The subaward documents should contain the elements required by the Uniform Grant Guidance. Additionally the City should obtain the annual audit reports from subrecipients who are required to have an audit in accordance with the Uniform Grant Guidance. Views of Responsible Officials: Management agrees with the finding. Please refer to the Corrective Action Plan.
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2019-001 HOME Investment Partnerships Program ? CFDA No. 14.239 Recommendation: We recommend procedures be implemented to ensure that subaward documents are completed and executed prior to disbursing funds to subrecipients. The subaward documents should contain the elements required by the Uniform Grant Guidance. Additionally the City should obtain the annual audit reports from subrecipients who are required to have an audit in accordance with the Uniform Grant Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In July 2018, the WestMetro HOME Consortium was monitored by HUD, and the City of Newton serves as the Representative Member on behalf of the Consortium. On September 12, 2018, the City received a monitoring response letter from HUD in which it determined that Consortium Member Communities are to be considered ?subrecipients,? and as such, must annually enter into a subrecipient agreement (2 CFR 200.331) with the City of Newton as the Representative Community. The Required Corrective Action defined by HUD in its September 12, 2018 letter was as follows: ?The PJ (City of Newton) is advised to develop a draft template subrecipient agreement to be used with consortium members. The PJ is advised to submit the draft agreement for review within 45 days of the date of this monitoring.? Though the City disagreed with the HUD monitoring finding, and the now subsequent City audit finding, staff nevertheless took great efforts over the course of many months to comply with HUD?s required corrective action. Staff was discouraged because this knowledge had never been shared as it relates to HOME Consortia, nor is this common practice among Consortia members nationwide. Historically, the WestMetro HOME Consortium operated under a Mutual Cooperation Agreement between the City of Newton and the Member Communities, which staff believed was the binding document that gave authority to Member Communities to expend HOME funds, which had been allocated by HUD to each individual community. As a starting point, staff engaged Community Development colleagues across the country to seek assistance in developing a subrecipient agreement for the HOME Program. The response from HOME practitioners and experts was that they had never been required by HUD to take on this additional layer of administration as it relates to Consortia management. Given this knowledge, the City of Newton Community Development Division and Legal Department worked diligently to create a template subrecipient agreement based off HOME federal regulations. Between fall 2018 and June 2019, staff shared updated drafts of the agreement with HUD representatives, incorporating their suggested edits to finalize a temple subrecipient agreement that would be approved by HUD and utilized by the WestMetro HOME Consortium for FY19 funds, and all subsequent years. It was Newton?s plan to start with the most recent fiscal year that had not been expended ? HM19/FFY2018 funds. While Member Communities usually have access to their entitlement funds towards the end of Quarter 1 of the fiscal year, HM19 / FF2018 funds were to be held during this process of developing a new subrecipient agreement. It was understood by Newton that once these agreements were finalized and executed, the Member Communities could bill out for their HM19 funds. The subrecipient agreements would be issued annually - on a grant-based approach and according to the Annual Action Plan. HUD was aware of strategy and did not mention any objections. The HM19-and-forward plan was adopted because prior year HOME grants were already well underway, and in many cases, formal commitments for the funds were in place and could not be retracted. Additionally, if the City chose to enact subrecipient agreements for all prior years, the HOME program would have ceased to operate for the nine-plus months it took for the subrecipient agreements to be developed, approved, executed and returned. Throughout all of the communication with HUD in 2018 and 2019 regarding this finding, there was never an explicit requirement that subrecipient agreements would be developed and executed for funding years prior to HM19. In fact, on June 13, 2019, HUD officially closed out the monitoring findings identified in the September 12, 2018 letter to the City of Newton (see Exhibit A). With regards to the finding related to the subrecipient agreements with the member communities, HUD stated the following: ?This finding has been closed. The City of Newton submitted a revised subrecipient agreement to be used going forward.? Secondly, regarding the recommendation to obtain annual audit reports from subrecipients who are required to have an audit in accordance with the Uniform Grant Guidance, staff did supply the auditors with these audits, however staff was told they were not the correct audits. Staff respectfully requests clarification from the auditors on the specific requirements related to this finding. Once these requirements have been clarified, staff will amend the HM20 subrecipient agreements, some of which have already been fully executed, and will include this requirement in all subrecipient agreements with member communities moving forward. In summary, Newton and the WestMetro HOME Consortium are now at the forefront of a new philosophy / requirement regarding HOME Consortium Members as subrecipients. Acting almost as a test case, staff has complied by developing a new document that governs the annual allocations and purposes of the use of HOME funds with each of the Member Communities. Staff began with HM19/FFY2018 funds and all but one community has executed their agreements. HM20/FFY2019 subrecipient agreements have been released, and to date, five have been executed. Lastly, subrecipient monitoring policies will be adjusted to accommodate these new mandates. Name(s) of the contact person(s) responsible for corrective action: ? Barney Heath: Director of Planning & Development Department ? Amanda Berman: Director of Housing and Community Development ? responsible for oversight of the HOME program, the development of annual subrecipient agreements and monitoring processes Planned completion date for corrective action plan: ? HM19 and HM20 subrecipient agreements have been issued. All but one community has executed its HM19 agreement, and five of the twelve communities have executed their HM20 agreements. ? Staff will not be issuing subrecipient agreements for prior year awards - HM18 and before. ? Over the course of the FY20 fiscal year, the WestMetro HOME Consortium will be overhauling the HOME monitoring process to include collection of the annual audit reports, if required by 2 CFR 200.501. See Corrective Action Plan for chart/table
Noncompliance and Significant Deficiency in Internal Control over Compliance 2019-002 HOME Investment Partnerships Program, CFDA No. 14.239 Award Period: July 1, 2018 ? June 30, 2019 Compliance Requirement: Allowable Costs/Cost Principles Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.430 indicates charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Such records should support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on a federal award and a non-federal award. Condition and Context: Two (2) of seven (7) payroll transactions in our statistically valid sample were charged to the grant in excess of the charges supported by the time and effort documentation. Questioned Costs: None in excess of the reportable threshold of the Uniform Grant Guidance. Cause: The City's internal controls surrounding the allocation of charges to the grant were not implemented to ensure the documentation supporting the charges tested was consistent with charges made to the grant. Effect: Noncompliance with the federal grant program occurred. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to ensure that records supporting the distribution of employee time and effort accurately reflect the charges to the grant program. Views of Responsible Officials: Management agrees with the finding. Please refer to the Corrective Action Plan.
Show full finding ▾Hide full finding ▴Noncompliance and Significant Deficiency in Internal Control over Compliance 2019-002 HOME Investment Partnerships Program, CFDA No. 14.239 Award Period: July 1, 2018 ? June 30, 2019 Compliance Requirement: Allowable Costs/Cost Principles Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.430 indicates charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Such records should support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on a federal award and a non-federal award. Condition and Context: Two (2) of seven (7) payroll transactions in our statistically valid sample were charged to the grant in excess of the charges supported by the time and effort documentation. Questioned Costs: None in excess of the reportable threshold of the Uniform Grant Guidance. Cause: The City's internal controls surrounding the allocation of charges to the grant were not implemented to ensure the documentation supporting the charges tested was consistent with charges made to the grant. Effect: Noncompliance with the federal grant program occurred. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to ensure that records supporting the distribution of employee time and effort accurately reflect the charges to the grant program. Views of Responsible Officials: Management agrees with the finding. Please refer to the Corrective Action Plan.
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2019-002 HOME Investment Partnerships Program ? CFDA No. 14.239 Recommendation: We recommend procedures be strengthened to ensure that records supporting the distribution of employee time and effort accurately reflect the charges to the grant program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: It is the City?s position that errors, both human and electronic, are inevitable and will occur from time to time. Regarding the sample cases, both instances were investigated and determined to be accidental (double entry of the two payrolls). With that said, corrective actions for project tracking will include: ? Updated policies and procedures that outline clear activities to be performed by specific staff members ? The new responsibility of double-checking the database entries against the original project timesheets, on a quarterly basis, as a preparation to running the quarterly staff billings report Name(s) of the contact person(s) responsible for corrective action: ? Danielle Bailey, Grants Manager ? responsible for review and approval of physical and electronic project timesheets ? Janet Antonellis, Administrative Assistant ? responsible for the collection, tracking and data entry of project timesheets Planned completion date for corrective action plan: ? New procedures will be drafted and tested in Q2, FY2020 and full implementation will begin January 1, 2020.
FAC accepted this audit on February 13, 2019 — management decision was due August 13, 2019.
FAC accepted this audit on March 26, 2018 — management decision was due September 26, 2018.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
Show full finding ▾Hide full finding ▴FAC accepted this audit on January 4, 2017 — management decision was due July 4, 2017.
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
Browse other Single Audit organizations in Pennsylvania →
Track your findings and corrective action plans across audit cycles.
Start tracking findings →Monitor subrecipient audit findings and filing records.
Start monitoring →© 2026 Single Audit Intelligence. All data is public domain.
