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OLD ROCHESTER REGIONAL SCHOOL DISTRICTLocal Government

EIN: 046006455

UEI: W37KPHRABYH4

Audited by: ROSELLI, CLARK AND ASSOCIATES

Oversight agency: 10 [Department of Agriculture]

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Data as of September 7, 2026

OLD ROCHESTER REGIONAL SCHOOL DISTRICT8 audit years8 findings2 repeat
8
Audit Years
8
Total Findings
2
Repeat Findings
$1.1M
Federal Awards Expended (FY 2025)

FY 2025-06-30

$1,090,237 federal awards expendedNo findings recorded this year

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on March 26, 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 26, 2026 (13 days from today).

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FY 2024-06-30

$1,389,435 federal awards expendedNo findings recorded this year

FAC accepted this audit on March 27, 2025 — management decision was due September 27, 2025.

FY 2023-06-30

$1,479,415 federal awards expendedNo findings recorded this year

FAC accepted this audit on April 10, 2024 — management decision was due October 10, 2024.

FY 2022-06-30

$2,144,254 federal awards expended

FAC accepted this audit on June 19, 2023 — management decision was due December 19, 2023.

2022-001
Procurement & Suspension/Debarment
REPEAT OF 2021-001OTHER MATTERS

A vendor was awarded a contract without a competitive procurement process. Cause: The District relied on a State procurement exemption which does not apply to Federal procurements. Effect: The District is not in compliance with Federal procurement requirements. Questioned Costs: None Repeat Finding from Prior Year: Yes, finding 2021-001. 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

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2022-001 U.S. Department of Education Passed-through the Commonwealth of Massachusetts? Department of Elementary and Secondary Education Special Education Cluster ? CFDA 84.027 Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Condition: A vendor was awarded a contract without a competitive procurement process. Cause: The District relied on a State procurement exemption which does not apply to Federal procurements. Effect: The District is not in compliance with Federal procurement requirements. Questioned Costs: None Repeat Finding from Prior Year: Yes, finding 2021-001. 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

Corrective Action Plan

Condition: A vendor was awarded a contract without a competitive procurement process. Corrective Action Planned: The District will implement procedures to perform procurement procedures on all applicable contracts for goods and services. Anticipated Completion Date: FY2023 Contact: Howard Barber, Assistant Superintendent of Finance and Operations

Prior Finding References

2021-001

About Procurement and Suspension and Debarment →

FY 2021-06-30

$1,374,477 federal awards expended

FAC accepted this audit on September 14, 2022 — management decision was due March 14, 2023.

2021-001
Procurement & Suspension/Debarment
MODIFIED OPINIONQUESTIONED COSTS

A vendor was awarded a contract without a competitive procurement process. Cause: The District relied on a State procurement exemption which does not apply to Federal procurements. Effect: The District is not in compliance with Federal procurement requirements. Questioned Costs: $19,125 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.

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2021-001 U.S. Department of Education Passed-through the Commonwealth of Massachusetts? Department of Elementary and Secondary Education Special Education Cluster ? CFDA 84.027 Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Condition: A vendor was awarded a contract without a competitive procurement process. Cause: The District relied on a State procurement exemption which does not apply to Federal procurements. Effect: The District is not in compliance with Federal procurement requirements. Questioned Costs: $19,125 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.

Corrective Action Plan

Finding 2021-001 Condition: A vendor was awarded a contract without a competitive procurement process. Corrective Action Planned: The District will implement procedures to perform procurement procedures on all applicable contracts for goods and services. Anticipated Completion Date: FY2023 Contact: Howard Barber, Assistant Superintendent of Finance and Operations

About Procurement and Suspension and Debarment →

FY 2020-06-30

$785,380 federal awards expended

FAC accepted this audit on June 20, 2021 — management decision was due December 20, 2021.

2020-001
Period of Performance
MODIFIED OPINIONREPEAT OF 2019-001QUESTIONED COSTS

Payroll was charged to the 2020 grant award for pay periods prior to the approval date by the pass-through agency. Cause: The approval date was later than in prior years and the District did not adequately plan grant expenditures as a result. Effect: The District expended funds outside of the period of performance which resulted in questioned costs. Questioned Costs: $38,780 of identified payroll costs outside of the period of performance. Repeat Finding from Prior Year: Yes; Finding 2019-001. Recommendation: The District should implement procedures to properly monitor award approval dates to ensure that goods and services charged to federal grants occur during the period of performance. Views of Responsible Official: Management agrees with the finding.

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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. Condition: Payroll was charged to the 2020 grant award for pay periods prior to the approval date by the pass-through agency. Cause: The approval date was later than in prior years and the District did not adequately plan grant expenditures as a result. Effect: The District expended funds outside of the period of performance which resulted in questioned costs. Questioned Costs: $38,780 of identified payroll costs outside of the period of performance. Repeat Finding from Prior Year: Yes; Finding 2019-001. Recommendation: The District should implement procedures to properly monitor award approval dates to ensure that goods and services charged to federal grants occur during the period of performance. Views of Responsible Official: Management agrees with the finding.

Corrective Action Plan

Condition: Payroll was charged to the 2020 grant award for pay periods prior to the approval date by the pass-through agency. Corrective Action Planned: Working with Mass State Agent to validate the corrective action plan relating to the FY19 finding and allowing for FY21 going forward is being accomplished. Anticipated Completion Date: FY2021 Contact: Howard Barber, Assistant Superintendent of Finance and Operations

Prior Finding References

2019-001

About Period of Performance →
2020-002
Cost Allowability
OTHER MATTERS

Required monthly time and effort certifications were not maintained for all applicable months of the school year for 7 of 25 grant employees selected for testing. Cause: The District did not stay current on time and effort certifications during the pandemic shutdown. Effect: The School is not in compliance with applicable cost principles related to salaries and wages. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The School should implement procedures to obtain time and effort certifications from grant employees whose wages are not supported with detailed time records. Time and effort certifications should be obtained on a semi-annual basis for employees whose work is solely for a single grant and monthly for employees whose work involves more than one grant or activity. Views of Responsible Official: Management agrees with the finding.

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Criteria: Per 2 CFR section 200.430(i) of the Uniform Guidance, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Semiannual or monthly time and effort certifications are to be utilized if the non-federal entity?s records do not meet the related standards described in the Uniform Guidance. Condition: Required monthly time and effort certifications were not maintained for all applicable months of the school year for 7 of 25 grant employees selected for testing. Cause: The District did not stay current on time and effort certifications during the pandemic shutdown. Effect: The School is not in compliance with applicable cost principles related to salaries and wages. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The School should implement procedures to obtain time and effort certifications from grant employees whose wages are not supported with detailed time records. Time and effort certifications should be obtained on a semi-annual basis for employees whose work is solely for a single grant and monthly for employees whose work involves more than one grant or activity. Views of Responsible Official: Management agrees with the finding.

Corrective Action Plan

Condition: Required monthly time and effort certifications were not maintained for all applicable months of the school year for 7 of 25 grant employees selected for testing. Corrective Action Planned: Management agrees with the finding and is working with payroll coordinator to establish a more efficient timeline to ensure completion. Majority of grant funded staff are now 100% funded under federal funds allowing a reduced number of time and effort certifications to assist in completion times. Anticipated Completion Date: Howard Barber, Assistant Superintendent of Finance and Operations Contact: Howard Barber, Assistant Superintendent of Finance and Operations

About Allowable Costs / Cost Principles →

FY 2019-06-30

$786,120 federal awards expended

FAC accepted this audit on March 31, 2020 — management decision was due October 1, 2020.

2019-001
Period of Performance
MODIFIED OPINIONQUESTIONED COSTS

Payroll was charged to the 2019 grant award for pay periods prior to the approval date by the pass-through agency. Cause: The approval date was later than in prior years and the District did not adequately plan grant expenditures as a result. Effect: The District expended funds outside of the period of performance which resulted in questioned costs. Questioned Costs: $26,766 of identified payroll costs outside of the period of performance Repeat Finding from Prior Year: No Recommendation: The District should implement procedures to properly monitor award approval dates to ensure that goods and services charged to federal grants occur during the period of performance. Views of Responsible Official: Management agrees with the finding.

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2019-001 U.S. Department of Education Passed-through the Commonwealth of Massachusetts? Department of Elementary and Secondary Education Special Education Cluster ? CFDA 84.027 & 84.173 Criteria: Grant funds may only be obligated upon the date of approval by the awarding agency through the end of the grant period. Condition: Payroll was charged to the 2019 grant award for pay periods prior to the approval date by the pass-through agency. Cause: The approval date was later than in prior years and the District did not adequately plan grant expenditures as a result. Effect: The District expended funds outside of the period of performance which resulted in questioned costs. Questioned Costs: $26,766 of identified payroll costs outside of the period of performance Repeat Finding from Prior Year: No Recommendation: The District should implement procedures to properly monitor award approval dates to ensure that goods and services charged to federal grants occur during the period of performance. Views of Responsible Official: Management agrees with the finding.

Corrective Action Plan

Condition: Payroll was charged to the 2019 grant award for pay periods prior to the approval date by the pass-through agency. Corrective Action Planned: The District will implement procedures to properly monitor award approval dates to ensure that goods and services charged to federal grants occur during the period of performance. Anticipated Completion Date: June 30, 2020 Contact: Michael Nelson, Assistant Superintendent, 508-758-2772 ext. 1945

About Period of Performance →
2019-002
Procurement & Suspension/Debarment
MODIFIED OPINIONQUESTIONED COSTS

A vendor was awarded a contract without a competitive procurement process. Cause: The District relied on a State procurement exemption which do not apply to Federal procurements. Effect: The District is not in compliance with Federal procurement requirements. Questioned Costs: $25,001 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.

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2019-002 U.S. Department of Education Passed-through the Commonwealth of Massachusetts? Department of Elementary and Secondary Education Special Education Cluster ? CFDA 84.027 & 84.173 Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Condition: A vendor was awarded a contract without a competitive procurement process. Cause: The District relied on a State procurement exemption which do not apply to Federal procurements. Effect: The District is not in compliance with Federal procurement requirements. Questioned Costs: $25,001 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.

Corrective Action Plan

Condition: A vendor was awarded a contract without a competitive procurement process. Corrective Action Planned: The District will implement procedures to perform procurement procedures on all applicable contracts for goods and services. Anticipated Completion Date: June 30, 2020 Contact: Michael Nelson, Assistant Superintendent, 508-758-2772 ext. 1945

About Procurement and Suspension and Debarment →
2019-003
Procurement & Suspension/Debarment
OTHER MATTERS

A suspension and debarment check was not performed for covered transactions before payments were made for services provided. The vendor was ultimately determined to be in compliance with suspension and debarment requirements during our audit testing. Cause: Lack of appropriate oversight resulted in required suspension and debarment check not being performed. Effect: Contracts could be entered into with vendors that are suspended or debarred from participating in federal grant awards. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The District should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred. Views of Responsible Official: Management agrees with the finding.

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2019-003 U.S. Department of Education Passed-through the Commonwealth of Massachusetts? Department of Elementary and Secondary Education Special Education Cluster ? CFDA 84.027 & 84.173 Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: A suspension and debarment check was not performed for covered transactions before payments were made for services provided. The vendor was ultimately determined to be in compliance with suspension and debarment requirements during our audit testing. Cause: Lack of appropriate oversight resulted in required suspension and debarment check not being performed. Effect: Contracts could be entered into with vendors that are suspended or debarred from participating in federal grant awards. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The District should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred. Views of Responsible Official: Management agrees with the finding.

Corrective Action Plan

Condition: A suspension and debarment check was not performed for covered transactions before payments were made for services provided. The vendor was ultimately determined to be in compliance with suspension and debarment requirements during our audit testing. Correction Action Planned: The District will implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred. Anticipated Completion Date: June 30, 2020 Contact: Michael Nelson, Assistant Superintendent, 508-758-2772 ext. 1945

About Procurement and Suspension and Debarment →

FY 2017-06-30

$753,618 federal awards expended

FAC accepted this audit on April 1, 2018 — management decision was due October 1, 2018.

2017-003
Other
OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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