EIN: 046006142
UEI: KHG6E511JK78
Audited by: CliftonLarsonAllen LLP
Oversight agency: 84 [Department of Education]
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Data as of September 7, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on August 4, 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 February 4, 2027 (142 days from today).
What is a management decision? →For the year ended June 30, 2025, The District did not maintain adequate time and effort documentation to support payroll costs charged to the Special Education (SPED) program. Specifically, for a sample of employees whose compensation was partially or fully charged to SPED, required time and effort certifications were either missing, incomplete, or did not clearly support the allocation of time between SPED and non‑SPED activities. Questioned costs: $88,558 Context: During testing of payroll expenditures it was identified that the District was not able to provide the time and effort documentation required for SPED payroll expenditures. Cause: District procedures for monitoring and retaining time and effort documentation were not consistently implemented. In addition, management oversight procedures did not ensure that required certifications were completed timely, reviewed for accuracy, and retained in accordance with federal requirements. Effect: Without adequate time and effort documentation, the District is unable to demonstrate that payroll expenditures charged to the SPED program were allowable and allocable. This condition increases the risk that federal funds may have been charged for costs not properly supported or not benefiting the SPED program, resulting in noncompliance with federal grant requirements. Repeat Finding: No. Recommendation: Establish and formally document procedures to ensure time and effort documentation is completed in accordance with federal requirements. Require periodic review of procedures by management to verify accuracy and completeness. Ensure all time and effort documentation is properly retained and readily available for audit purposes. Provide training to applicable staff on federal time and effort documentation requirements for SPED programs. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Federal Award Identification Number and Year: H027A230076 (9/8/2023 – 9/30/2025), H027A240076 (9/10/2024 – 9/30/2026), FH027A230076 (11/3/2023 – 9/30/2024) Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-000558-2024-0700, 240-000558-2025-0700, 274-000662-2025-0700 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Qualified Opinion) Criteria or specific requirement: Under the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Part 200), specifically 2 CFR §200.430(i), 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 controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Additionally, the non-Federal entity is required to have written procedures and a system of internal controls to ensure that charges for compensation are accurate, allowable, and properly allocated to each applicable cost objective. Condition: For the year ended June 30, 2025, The District did not maintain adequate time and effort documentation to support payroll costs charged to the Special Education (SPED) program. Specifically, for a sample of employees whose compensation was partially or fully charged to SPED, required time and effort certifications were either missing, incomplete, or did not clearly support the allocation of time between SPED and non‑SPED activities. Questioned costs: $88,558 Context: During testing of payroll expenditures it was identified that the District was not able to provide the time and effort documentation required for SPED payroll expenditures. Cause: District procedures for monitoring and retaining time and effort documentation were not consistently implemented. In addition, management oversight procedures did not ensure that required certifications were completed timely, reviewed for accuracy, and retained in accordance with federal requirements. Effect: Without adequate time and effort documentation, the District is unable to demonstrate that payroll expenditures charged to the SPED program were allowable and allocable. This condition increases the risk that federal funds may have been charged for costs not properly supported or not benefiting the SPED program, resulting in noncompliance with federal grant requirements. Repeat Finding: No. Recommendation: Establish and formally document procedures to ensure time and effort documentation is completed in accordance with federal requirements. Require periodic review of procedures by management to verify accuracy and completeness. Ensure all time and effort documentation is properly retained and readily available for audit purposes. Provide training to applicable staff on federal time and effort documentation requirements for SPED programs. Views of responsible officials: There is no disagreement with the audit finding.
Time & Effort Documentation. Due to the timing of the retirement of the SPED Administrative Assistant who was responsible for documenting the time & effort of staff paid for from the SPED 240 Grant, the necessary paperwork/documentation was not collected as required. The Corrective Action Plan will consist of training the new SPED Administrative Assistant on this requirement, and to have multiple check-ins during the year with the Director of Support Services and the SPED Administrative Assistant on this requirement. Lastly, we are taking the additional step to add language into each annual payroll contract of staff funded from the SPED 240 Grant, that they are funded, and to what proportion, by that grant. This will be overseen by the School Business Administrator in concert with the Director of Support Services, and will be effective for the FY26 Single Audit cycle.
FAC accepted this audit on September 10, 2025 — management decision was due March 10, 2026.
FAC accepted this audit on October 15, 2024 — management decision was due April 15, 2025.
FAC accepted this audit on October 31, 2023 — management decision was due May 1, 2024.
FAC accepted this audit on November 16, 2022 — management decision was due May 16, 2023.
Internal controls are not designed to ensure vendors are selected in accordance with the Uniform Guidance. Questioned costs: $33,840 Context: Four out of four vendors tested for procurement were not selected in accordance with Uniform Guidance, which would require quotations from an adequate number of qualified sources or documentation supporting a sole source procurement. No documentation was provided related to the procurement process other than a signed contract with the vendor. Cause: Procedures are not in place to ensure all contracts are procured in accordance with Uniform Guidance requirements. Effect: Noncompliance with federal procurement compliance requirements. Repeat Finding: The finding is a repeat of a finding in the immediate prior year; see finding 2020-001. Recommendation: We recommend the District implement controls that ensure adherence to the procurement requirements of the Uniform Guidance. Views of responsible officials: There is no disagreement with the finding.
Show full finding ▾Hide full finding ▴Type of Finding: ? Material Weakness in Internal Control over Compliance ? Material Noncompliance (Qualified Opinion) Compliance Requirement: Procurement, Suspension and Debarment Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The Martha?s Vineyard Regional High School District should have internal controls designed to ensure compliance with those provisions. The Code of Federal Regulations (CFR) Title 2, part 200.320 states procurement by small purchase procedures (from $10,000 to $250,000). Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. Condition: Internal controls are not designed to ensure vendors are selected in accordance with the Uniform Guidance. Questioned costs: $33,840 Context: Four out of four vendors tested for procurement were not selected in accordance with Uniform Guidance, which would require quotations from an adequate number of qualified sources or documentation supporting a sole source procurement. No documentation was provided related to the procurement process other than a signed contract with the vendor. Cause: Procedures are not in place to ensure all contracts are procured in accordance with Uniform Guidance requirements. Effect: Noncompliance with federal procurement compliance requirements. Repeat Finding: The finding is a repeat of a finding in the immediate prior year; see finding 2020-001. Recommendation: We recommend the District implement controls that ensure adherence to the procurement requirements of the Uniform Guidance. Views of responsible officials: There is no disagreement with the finding.
DEPARTMENT OF EDUCATION 2021-001 Special Education Cluster ? CFDA No. 84.027, 84.173 Recommendation: We recommend the District implement controls that ensure adherence to the procurement requirements of the Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District has new staff in FY22 responsible for expenditures of SPED funds, which includes initial procurement reviews. This current staff has had internal training on procurement requirements. Name(s) of the contact person(s) responsible for corrective action: Mark Friedman, School Business Administrator; Bernie Cormie, Grants Coordinator Planned completion date for corrective action plan: 6/30/2022
2020-001
No supporting documentation was maintained to support the vendor was not suspended or debarred. We confirmed that the vendor was not suspended or debarred. Questioned costs: None Context: One out of one vendor tested. Cause: Procedures are not in place to maintain documentation verifying vendors are not suspended or debarred. Effect: Potential noncompliance with federal procurement, suspension, and debarment compliance requirements. Repeat Finding: The finding is a repeat of a finding in the immediate prior year; see finding 2020-002. Recommendation: We recommend the District implement controls that ensure adherence to the suspension and debarment requirements of the Uniform Guidance. Views of responsible officials: There is no disagreement with the finding.
Show full finding ▾Hide full finding ▴Type of Finding: ? Significant Deficiency in Internal Control over Compliance Compliance Requirement: Procurement, Suspension and Debarment Criteria or specific requirement: The Code of Federal Regulations (CFR) Title 2, part 180.220 states that ?non-Federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All nonprocurement transactions entered into by a recipient (i.e., sub-awards to sub-recipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215.? Condition: No supporting documentation was maintained to support the vendor was not suspended or debarred. We confirmed that the vendor was not suspended or debarred. Questioned costs: None Context: One out of one vendor tested. Cause: Procedures are not in place to maintain documentation verifying vendors are not suspended or debarred. Effect: Potential noncompliance with federal procurement, suspension, and debarment compliance requirements. Repeat Finding: The finding is a repeat of a finding in the immediate prior year; see finding 2020-002. Recommendation: We recommend the District implement controls that ensure adherence to the suspension and debarment requirements of the Uniform Guidance. Views of responsible officials: There is no disagreement with the finding.
2021-002 Special Education Cluster ? CFDA No. 84.027, 84.173 Recommendation: We recommend the District implement controls that ensure adherence to the suspension and debarment requirements of the Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District has put in place procedures to check potential vendors for debarments and suspensions. Moving forward the District will also check this status for any local/municipal entities, including municipal collaboratives. Name(s) of the contact person(s) responsible for corrective action: Mark Friedman, School Business Administrator; Bernie Cormie, Grants Coordinator Planned completion date for corrective action plan: 6/30/2022 If the Department has questions regarding this plan, please call Mark Friedman, School Business Administrator at (508) 693-2007 extension 12.
2020-002
FAC accepted this audit on September 28, 2021 — management decision was due March 28, 2022.
Internal controls are not designed to ensure vendors are selected in accordance with Uniform Guidance. Questioned costs: $34,950 Context: Three out of three vendors tested for procurement were not selected in accordance with Uniform Guidance, which would require quotations from an adequate number of qualified sources or documentation supporting a sole source procurement. No documentation was provided related to the procurement process other than a signed contract with the vendor. Cause: Procedures are not in place to ensure all contracts are procured in accordance with Uniform Guidance requirements. Effect: Noncompliance with federal procurement compliance requirements. Recommendation: We recommend the District implement controls that ensure adherence to the procurement requirements of the Uniform Guidance. Views of responsible officials: There is no disagreement with the finding.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Education Federal Program: Special Education Cluster CFDA Numbers: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-304333-2020-0700 Award Period: July 1, 2019 ? June 30, 2020 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Material Noncompliance (Modified Opinion) Compliance Requirements: Procurement, Suspension, and Debarment Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The Martha?s Vineyard Regional High School District should have internal controls designed to ensure compliance with those provisions. The Code of Federal Regulations (CFR) Title 2, part 200.320 states procurement by small purchase procedures (from $10,000 to $250,000). Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. Condition: Internal controls are not designed to ensure vendors are selected in accordance with Uniform Guidance. Questioned costs: $34,950 Context: Three out of three vendors tested for procurement were not selected in accordance with Uniform Guidance, which would require quotations from an adequate number of qualified sources or documentation supporting a sole source procurement. No documentation was provided related to the procurement process other than a signed contract with the vendor. Cause: Procedures are not in place to ensure all contracts are procured in accordance with Uniform Guidance requirements. Effect: Noncompliance with federal procurement compliance requirements. Recommendation: We recommend the District implement controls that ensure adherence to the procurement requirements of the Uniform Guidance. Views of responsible officials: There is no disagreement with the finding.
Special Education Cluster ? CFDA No. 84.027, 84.173 Recommendation: We recommend the District implement controls that ensure adherence to the procurement requirements of the Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: There was a new School Business Administrator as of February 2020 and the finance team looked at federal grant purchases and put in place procedures to check procurements and debarments/suspensions when purchase requisitions are submitted to the administration office. While most of Martha?s Vineyard Public Schools (MVYPS) federal grant expenditures were on salaries, the remainder fell under the Micro-Purchases threshold. In a few cases for SPED services the dollar amounts fell into the small purchase threshold, and while under State (Chapter 30B) guidelines there is an exemption from procurement requirements for SPED services in connection with a student's Individualized Education Plan (IEP), we have identified the bulk of these services as falling under the Federal Guidelines of "sole source" procurements. MVYPS will closely monitor and document this to ensure that future services continue to fall within this sole source category, or that an appropriate quote/bidding procedure is followed. Name(s) of the contact person(s) responsible for corrective action: Mark Friedman, School Business Administrator Planned completion date for corrective action plan: Immediately
2019-001
No supporting documentation was maintained to support the vendor was not suspended or debarred. We confirmed that the vendor was not suspended or debarred. Questioned costs: None. Context: One out of one vendor tested. Cause: Procedures are not in place to maintain documentation verifying vendors are not suspended or debarred. Effect: Potential noncompliance with federal procurement, suspension, and debarment compliance requirements. Recommendation: We recommend the District implement controls that ensure adherence to the suspension and debarment requirements of the Uniform Guidance. Views of responsible officials: There is no disagreement with the finding.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Education Federal Agency: Department of Education Federal Program: Special Education Cluster CFDA Numbers: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-304333-2020-0700 Award Period: July 1, 2019 ? June 30, 2020 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Compliance Requirements: Suspension and Debarment Criteria or specific requirement: The Code of Federal Regulations (CFR) Title 2, part 180.220 states that ?non-Federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All nonprocurement transactions entered into by a recipient (i.e., sub-awards to sub-recipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215.? Condition: No supporting documentation was maintained to support the vendor was not suspended or debarred. We confirmed that the vendor was not suspended or debarred. Questioned costs: None. Context: One out of one vendor tested. Cause: Procedures are not in place to maintain documentation verifying vendors are not suspended or debarred. Effect: Potential noncompliance with federal procurement, suspension, and debarment compliance requirements. Recommendation: We recommend the District implement controls that ensure adherence to the suspension and debarment requirements of the Uniform Guidance. Views of responsible officials: There is no disagreement with the finding.
Special Education Cluster ? CFDA No. 84.027, 84.173 Recommendation: We recommend the District implement controls that ensure adherence to the suspension and debarment requirements of the Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: There was a new School Business Administrator as of February 2020 and the finance team looked at federal grant purchases and put in place procedures to check procurements and debarments/suspensions when purchase requisitions are submitted to the administration office. While most of Martha?s Vineyard Public Schools (MVYPS) federal grant expenditures were on salaries, the remainder fell under the Micro-Purchases threshold. In a few cases for SPED services the dollar amounts fell into the small purchase threshold, and while under State (Chapter 30B) guidelines there is an exemption from procurement requirements for SPED services in connection with a student's Individualized Education Plan (IEP), we have identified the bulk of these services as falling under the Federal Guidelines of "sole source" procurements. MVYPS will closely monitor and document this to ensure that future services continue to fall within this sole source category, or that an appropriate quote/bidding procedure is followed. Name(s) of the contact person(s) responsible for corrective action: Mark Friedman, School Business Administrator Planned completion date for corrective action plan: Immediately
2019-002
FAC accepted this audit on June 9, 2020 — management decision was due December 9, 2020.
Internal controls are not designed to ensure vendors are selected in accordance with Uniform Guidance. Questioned costs: $47,621 Context: Two out of two vendors tested for procurement were not selected in accordance with Uniform Guidance, which would require quotations from an adequate number of qualified sources. No documentation was provided related to the procurement process other than a signed contract with the vendor. Cause: Procedures are not in place to ensure all contracts are procured in accordance with Uniform Guidance requirements. Effect: Noncompliance with federal procurement compliance requirements. Recommendation: We recommend the District implement controls that ensure adherence to the procurement requirements of the Uniform Guidance. Views of responsible officials: There is no disagreement with the finding.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Education Federal Program: Special Education Cluster CFDA Numbers: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-212678-2019-0700 Award Period: July 1, 2018 ? June 30, 2019 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Material Noncompliance Compliance Requirements: Procurement, Suspension, and Debarment Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The Martha?s Vineyard Regional High School District should have internal controls designed to ensure compliance with those provisions. The Code of Federal Regulations (CFR) Title 2, part 200.320 states procurement by small purchase procedures (from $10,000 to $250,000). Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. Condition: Internal controls are not designed to ensure vendors are selected in accordance with Uniform Guidance. Questioned costs: $47,621 Context: Two out of two vendors tested for procurement were not selected in accordance with Uniform Guidance, which would require quotations from an adequate number of qualified sources. No documentation was provided related to the procurement process other than a signed contract with the vendor. Cause: Procedures are not in place to ensure all contracts are procured in accordance with Uniform Guidance requirements. Effect: Noncompliance with federal procurement compliance requirements. Recommendation: We recommend the District implement controls that ensure adherence to the procurement requirements of the Uniform Guidance. Views of responsible officials: There is no disagreement with the finding.
MVRHS will consult proper procurement guidelines for these awards, and will conduct and document the appropriate micro-purchase and small purchase processes.
2018-003
No supporting documentation was maintained to support the vendor was not suspended or debarred. We confirmed that the vendor was not suspended or debarred. Questioned costs: None. Context: One out of one vendor tested. Cause: Procedures are not in place to maintain documentation verifying vendors are not suspended or debarred. Effect: Potential noncompliance with federal procurement, suspension, and debarment compliance requirements. Recommendation: We recommend the District implement controls that ensure adherence to the suspension and debarment requirements of the Uniform Guidance. Views of responsible officials: There is no disagreement with the finding.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Education Federal Program: Special Education Cluster CFDA Numbers: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 240-212678-2019-0700 Award Period: July 1, 2018 ? June 30, 2019 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Compliance Requirements: Procurement, Suspension, and Debarment Criteria or specific requirement: The Code of Federal Regulations (CFR) Title 2, part 180.220 states that ?non-Federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a recipient (i.e., sub-awards to sub-recipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215.? Condition: No supporting documentation was maintained to support the vendor was not suspended or debarred. We confirmed that the vendor was not suspended or debarred. Questioned costs: None. Context: One out of one vendor tested. Cause: Procedures are not in place to maintain documentation verifying vendors are not suspended or debarred. Effect: Potential noncompliance with federal procurement, suspension, and debarment compliance requirements. Recommendation: We recommend the District implement controls that ensure adherence to the suspension and debarment requirements of the Uniform Guidance. Views of responsible officials: There is no disagreement with the finding.
MVRHS will implement procedures to check the sam.gov website to ensure potential vendors are not excluded before entering into a contract or issuing a purchase order.
2018-003
FAC accepted this audit on March 31, 2019 — management decision was due October 1, 2019.
GSA_MIGRATION
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2017-002
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2017-003
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FAC accepted this audit on March 29, 2018 — management decision was due September 29, 2018.
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2016-002
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Show full finding ▾Hide full finding ▴FAC accepted this audit on March 29, 2017 — management decision was due September 29, 2017.
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2015-002
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2015-003
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