EIN: 046006430
UEI: UX3JNY6UDNG3
Data as of August 21, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 31, 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 October 1, 2026 (40 days from today).
What is a management decision? →Four vendors were awarded a contract without a competitive procurement process. Context: Procurement was not documented for four vendors that provided professional services through Federal awards. Cause: The District did not follow its established policy regarding federal procurement as the District relied on State procurement exemptions which do not apply to this award Effect: The District charged expenditures that did not adhere to federal procurement requirements which could result in unallowable costs. Questioned Costs: $78,355 Repeat Finding from Prior Year: Yes. Finding 2024-002. Recommendation: The District should adhere to its grant award procedures to perform competitive procurement procedures on all applicable contracts for goods and services charged to Federal awards. Views of Responsible Official: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2025-001 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Condition: Four vendors were awarded a contract without a competitive procurement process. Context: Procurement was not documented for four vendors that provided professional services through Federal awards. Cause: The District did not follow its established policy regarding federal procurement as the District relied on State procurement exemptions which do not apply to this award Effect: The District charged expenditures that did not adhere to federal procurement requirements which could result in unallowable costs. Questioned Costs: $78,355 Repeat Finding from Prior Year: Yes. Finding 2024-002. Recommendation: The District should adhere to its grant award procedures to perform competitive procurement procedures on all applicable contracts for goods and services charged to Federal awards. Views of Responsible Official: Management agrees with the finding.
Finding 2025-001 Condition: Four vendors were awarded a contract without a competitive procurement process. Corrective Action Planned: The district will implement controls to ensure that the all federal grants have the higher standard of the federal procurement, which is above the MGL Chapter 30B exemption to special education services, applied to federal grant spending. All efforts for quotes for contracted services will be memorialized in a memo to the Director of Finance and Operations prior to execution of contracts. Anticipated Completion Date: Completed. Contact: Ross Mulkerin, Director of Finance and Operations
2024-002
FAC accepted this audit on April 1, 2025 — management decision was due October 1, 2025.
Costs were recorded for service periods prior to grant approval date. Cause: The District did not properly identify service periods for costs reported under grant. Effect: The District expended funds outside of the period of performance which resulted in questioned costs. Questioned Costs: $155,246 Repeat Finding from Prior Year: No Recommendation: The District should implement procedures to properly monitor award performance dates to ensure that goods and services charged to federal grants are within the approved grant period. Views of Responsible Official: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2024-001 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 Criteria: Per 2 CFR section 200.309 of the Uniform Guidance, a non-federal entity may charge to a Federal award only allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. Condition: Costs were recorded for service periods prior to grant approval date. Cause: The District did not properly identify service periods for costs reported under grant. Effect: The District expended funds outside of the period of performance which resulted in questioned costs. Questioned Costs: $155,246 Repeat Finding from Prior Year: No Recommendation: The District should implement procedures to properly monitor award performance dates to ensure that goods and services charged to federal grants are within the approved grant period. Views of Responsible Official: Management agrees with the finding.
Finding 2024-001 Condition: Costs were recorded for service periods prior to grant approval date. Corrective Action Planned: The district will implement controls to prevent the recording of costs for service periods prior to grant approval date by written guidance to all staff involved in federal grant funds. Please note, that the practice at question is not in violation of school committee policy as we have not made any expenditures outside that entity’s approval date. Anticipated Completion Date: By July 1, 2025 Contact: Ross Mulkerin, Director of Finance and Operations
Three vendors were awarded a contract without a competitive procurement process or documentation to support the rationale to limit competition. Cause: The District relied on State procurement exemptions which do not apply to Federal procurements. Effect: The District is not in compliance with Federal procurement requirements. Questioned Costs: $80,139 Repeat Finding from Prior Year: No. Recommendation: The District should implement procedures to perform procurement procedures on all applicable contracts for goods and services. Views of Responsible Official: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2024-002 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Condition: Three vendors were awarded a contract without a competitive procurement process or documentation to support the rationale to limit competition. Cause: The District relied on State procurement exemptions which do not apply to Federal procurements. Effect: The District is not in compliance with Federal procurement requirements. Questioned Costs: $80,139 Repeat Finding from Prior Year: No. Recommendation: The District should implement procedures to perform procurement procedures on all applicable contracts for goods and services. Views of Responsible Official: Management agrees with the finding.
Finding 2024-002 Condition: Three vendors were awarded a contract without a competitive procurement process. Corrective Action Planned: The district will implement controls to ensure that the all federal grants have the higher standard of the federal procurement, which is above the MGL Chapter 30B exemption to special education services, applied to federal grant spending. All efforts for quotes for contracted services will be memorialized in a memo to the Director of Finance and Operations prior to execution of contracts. Anticipated Completion Date: By July 1, 2025 Contact: Ross Mulkerin, Director of Finance and Operations
FAC accepted this audit on March 21, 2023 — management decision was due September 21, 2023.
2021-001 Improve Internal Controls and Documentation of Eligibility Determinations Federal Agency: U.S. Department of Agriculture Cluster/Program: Child Nutrition Cluster Award Name: National School Lunch Program AL Number(s): 10.555 Award Year: 2021 Compliance Requirement: Eligibility Type of Finding Compliance Internal Control over Compliance - Significant Deficiency Criteria or Specific Requirement The District is required to maintain appropriate documentation to support the determination of the students free and reduced lunch status. Management of the District is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of perform?ing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context During our testing of eligibility for a sample of 25 students participating in the District?s free and reduced lunch program we noted the following issues: ? 4 of the 25 applications selected for review could not be located. ? 1 of the 25 applications was direct certified as reduced, but the student was documented in the system as free. Cause The District has not established adequate procedures to ensure that the required documentation is retained to support the determination of students? free and reduced lunch status, nor are there adequate procedures to ensure that only eligible students are receiving free or reduced lunch. Effect or Potential Effect There are no questioned costs as a result of this finding because it was undeterminable. Recommendation All applications should be properly approved, retained, and procedures implemented to ensure that only eligible students are receiving free or reduced lunch. Views of Responsible Official and Planned Corrective Action Management?s views and corrective action plan are included at the end of this report after the schedule of prior year findings.
Show full finding ▾Hide full finding ▴2021-001 Improve Internal Controls and Documentation of Eligibility Determinations Federal Agency: U.S. Department of Agriculture Cluster/Program: Child Nutrition Cluster Award Name: National School Lunch Program AL Number(s): 10.555 Award Year: 2021 Compliance Requirement: Eligibility Type of Finding Compliance Internal Control over Compliance - Significant Deficiency Criteria or Specific Requirement The District is required to maintain appropriate documentation to support the determination of the students free and reduced lunch status. Management of the District is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of perform?ing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context During our testing of eligibility for a sample of 25 students participating in the District?s free and reduced lunch program we noted the following issues: ? 4 of the 25 applications selected for review could not be located. ? 1 of the 25 applications was direct certified as reduced, but the student was documented in the system as free. Cause The District has not established adequate procedures to ensure that the required documentation is retained to support the determination of students? free and reduced lunch status, nor are there adequate procedures to ensure that only eligible students are receiving free or reduced lunch. Effect or Potential Effect There are no questioned costs as a result of this finding because it was undeterminable. Recommendation All applications should be properly approved, retained, and procedures implemented to ensure that only eligible students are receiving free or reduced lunch. Views of Responsible Official and Planned Corrective Action Management?s views and corrective action plan are included at the end of this report after the schedule of prior year findings.
March 15, 2023 Corrective Action Plan (CAP) for Section III- Federal Awards Findings and Questioned Costs Type of Finding Compliance 2021-001 Improve Internal Controls and Documentation of Eligibility Planned Corrective Action: The Nashoba Regional School District will update our systems to maintain appropriate documentation to support the determination of the students free and reduced status as soon as possible. All applications will be subject to proper approval and maintained moving forward. Impacts to staffing and uncertainties surrounding the procurement, production, and services of school meals took precedent during this time of the district charging no cost for school meals due to federal programs. Therefore, there were impacts to paperwork collection and retention systems. John Overcash, Director of Food and Nutrition, will be responsible for addressing the finding within the department and anticipates correction by July 1, 2023. Mr. Overcash?s contact information is the same as district office information at the bottom of this page. Ross Mulkerin Business and Operations Manager
2021-002 Improve Controls and Documentation over Required Verifications Federal Agency: U.S. Department of Agriculture Cluster/Program: Child Nutrition Cluster Award Name: National School Lunch Program AL Number(s): 10.553/10.555 Award Year: 2021 Compliance Requirement: Special Tests and Provisions Type of Finding Compliance Internal Control over Compliance - Significant Deficiency Criteria or Specific Requirement By November 15 of each school year, verification of free and reduced-price eligibility of household income from a sample of approved applications must be performed. Documentation that this verification took place is required to be maintained to support the process and any changes required in student eligibility status as a result. Management of the District is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of perform?ing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context The District was unable to locate the support for the fiscal 2021 income verification requests that were sent out. Cause The District has not established adequate procedures to ensure compliance with the provisions of this federal requirement. Effect or Potential Effect Due to the weaknesses in internal controls noted above, there is a risk that ineligible students could receive free or reduced-price lunches. No questioned costs are reported, as it is not quantifiable. Recommendation The District should address the weaknesses in internal controls noted above in order to comply with Federal guidelines related to verification of applications for the National School Lunch and Breakfast Program. Views of Responsible Official and Planned Corrective Action Management?s views and corrective action plan are included at the end of this report after the schedule of prior year findings.
Show full finding ▾Hide full finding ▴2021-002 Improve Controls and Documentation over Required Verifications Federal Agency: U.S. Department of Agriculture Cluster/Program: Child Nutrition Cluster Award Name: National School Lunch Program AL Number(s): 10.553/10.555 Award Year: 2021 Compliance Requirement: Special Tests and Provisions Type of Finding Compliance Internal Control over Compliance - Significant Deficiency Criteria or Specific Requirement By November 15 of each school year, verification of free and reduced-price eligibility of household income from a sample of approved applications must be performed. Documentation that this verification took place is required to be maintained to support the process and any changes required in student eligibility status as a result. Management of the District is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of perform?ing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context The District was unable to locate the support for the fiscal 2021 income verification requests that were sent out. Cause The District has not established adequate procedures to ensure compliance with the provisions of this federal requirement. Effect or Potential Effect Due to the weaknesses in internal controls noted above, there is a risk that ineligible students could receive free or reduced-price lunches. No questioned costs are reported, as it is not quantifiable. Recommendation The District should address the weaknesses in internal controls noted above in order to comply with Federal guidelines related to verification of applications for the National School Lunch and Breakfast Program. Views of Responsible Official and Planned Corrective Action Management?s views and corrective action plan are included at the end of this report after the schedule of prior year findings.
March 15, 2023 Corrective Action Plan (CAP) for 2021-002 Improve Controls and Documentation over Required Verifications Type of Finding Compliance Internal Control over Compliance- Significant Deficiency Planned Corrective Action: The Nashoba Regional School District will update our systems to maintain appropriate documentation to support the determination of the students free and reduced status as soon as possible. All applications will be subject to proper approval and maintained moving forward. Impacts to staffing and uncertainties surrounding the procurement, production, and services of school meals took precedent during this time of the district charging no cost for school meals due to federal programs. Therefore, there were impacts to paperwork collection and retention systems. John Overcash, Director of Food and Nutrition, will be responsible for addressing the finding within the department and anticipates correction by July 1, 2023. Mr. Overcash?s contact information is the same as district office information at the bottom of this page. Ross Mulkerin Business and Operations Manager
FAC accepted this audit on June 8, 2021 — management decision was due December 8, 2021.
2020-001 Improve Controls Over Allowable Costs and Period of Availability Over Federal Awards (Significant Deficiency) Federal Agency: U.S. Department of Education Cluster/Program: Special Education Cluster Award Name: Special Education ? Grants to States CFDA Number(s): 84.027/84.173 Award Year: 2020 Compliance Requirement: H Type of Finding Compliance Internal Control over Compliance - Significant Deficiency Criteria or Specific Requirement Grantees must provide reasonable assurance that Federal awards are obligated during the stated period of performance per the grant agreement and that no expenses are charged to the grant outside of the period of performance. Management of the District is also responsible for establishing and maintaining effective internal controls over compliance with Federal requirements that have a direct and material effect on a Federal program. Condition and Context During our testing of expenses charged to the grant, we found transportation expenses charged to the grant that occurred prior to the start of the grants period of performance. Cause The District has not established adequate procedures to assure expenses charged to the grant were within the period of performance. Effect Due to inadequate procedures and lack of appropriate oversight over expenses, known questioned costs are $86,515. Recommendation We recommend the District establish a process to ensure all expenses charged to the grant occur within the period of performance. Views of Responsible Official and Planned Corrective Action Management?s views and corrective action plan is included in the separate Corrective Action Plan.
Show full finding ▾Hide full finding ▴2020-001 Improve Controls Over Allowable Costs and Period of Availability Over Federal Awards (Significant Deficiency) Federal Agency: U.S. Department of Education Cluster/Program: Special Education Cluster Award Name: Special Education ? Grants to States CFDA Number(s): 84.027/84.173 Award Year: 2020 Compliance Requirement: H Type of Finding Compliance Internal Control over Compliance - Significant Deficiency Criteria or Specific Requirement Grantees must provide reasonable assurance that Federal awards are obligated during the stated period of performance per the grant agreement and that no expenses are charged to the grant outside of the period of performance. Management of the District is also responsible for establishing and maintaining effective internal controls over compliance with Federal requirements that have a direct and material effect on a Federal program. Condition and Context During our testing of expenses charged to the grant, we found transportation expenses charged to the grant that occurred prior to the start of the grants period of performance. Cause The District has not established adequate procedures to assure expenses charged to the grant were within the period of performance. Effect Due to inadequate procedures and lack of appropriate oversight over expenses, known questioned costs are $86,515. Recommendation We recommend the District establish a process to ensure all expenses charged to the grant occur within the period of performance. Views of Responsible Official and Planned Corrective Action Management?s views and corrective action plan is included in the separate Corrective Action Plan.
Planned Corrective Action: The Nashoba Regional School District will reclassify the expenditures made to the Special Education Grant IDEA Grant by 6/30/2021. Internal controls are in place to make sure that the expenditures line up with the grant time line. This error would not normally happen. Staffing restrictions due to the Covid-19 Virus disrupted timely evaluations of processing bills and uncertainty in regards to transportation costs. Patricia Marone Director of Business and Operations
FAC accepted this audit on June 28, 2020 — management decision was due December 28, 2020.
2019-001 Document Policies and Procedures Over Federal Awards Federal Program(s) Information Cluster/Program: All Federal Programs Type of Finding Compliance ? Other Matters Criteria or Specific Requirement OMB?s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) established significant new requirements related to Federal awards. The new requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following: ? Cash management ? Determination of allowable costs ? Employee travel ? Procurement ? Subrecipient monitoring and management Condition and Context The District has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance. Cause Weaknesses in the formal documentation of internal controls. Effect or Potential Effect There are no questioned costs as a result of this finding, as there are no costs directly associated with this compliance requirement. Identification as Repeat Finding As identified in Section IV, the Schedule of Prior Year Findings, this is a repeat of finding 2018 004. The implementation of corrective action did not occur during fiscal year 2019 due to the timing of the reported findings until late in the fiscal year. Recommendation We recommend the District ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with the Uniform Guidance. Views of Responsible Official Management agrees with the findings. Planned Corrective Action The District approved the EDGAR Manual at the April 8, 2020 NRSD School Committee meeting. Person Responsible for Corrective Action: Business and Operations Manager
Show full finding ▾Hide full finding ▴2019-001 Document Policies and Procedures Over Federal Awards Federal Program(s) Information Cluster/Program: All Federal Programs Type of Finding Compliance ? Other Matters Criteria or Specific Requirement OMB?s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) established significant new requirements related to Federal awards. The new requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following: ? Cash management ? Determination of allowable costs ? Employee travel ? Procurement ? Subrecipient monitoring and management Condition and Context The District has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance. Cause Weaknesses in the formal documentation of internal controls. Effect or Potential Effect There are no questioned costs as a result of this finding, as there are no costs directly associated with this compliance requirement. Identification as Repeat Finding As identified in Section IV, the Schedule of Prior Year Findings, this is a repeat of finding 2018 004. The implementation of corrective action did not occur during fiscal year 2019 due to the timing of the reported findings until late in the fiscal year. Recommendation We recommend the District ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with the Uniform Guidance. Views of Responsible Official Management agrees with the findings. Planned Corrective Action The District approved the EDGAR Manual at the April 8, 2020 NRSD School Committee meeting. Person Responsible for Corrective Action: Business and Operations Manager
Planned Corrective Action The District approved the EDGAR Manual at the April 8, 2020 NRSD School Committee meeting. Person Responsible for Corrective Action: Business and Operations Manager
2018-004
FAC accepted this audit on August 28, 2019 — management decision was due February 28, 2020.
GSA_MIGRATION
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2017-004
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2017-005
GSA_MIGRATION
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GSA_MIGRATION
2017-006
FAC accepted this audit on September 4, 2018 — management decision was due March 4, 2019.
GSA_MIGRATION
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