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Town of Greenwich, ConnecticutLocal Government

EIN: 066002006

UEI: TZPXPH859NC1

Audited by: RSM US LLP

Oversight agency: 84 [Department of Education]

View federal awards & risk assessment →

Data as of September 2, 2026

Town of Greenwich, Connecticut10 audit years14 findings7 repeat
10
Audit Years
14
Total Findings
7
Repeat Findings
$12.9M
Federal Awards Expended (FY 2025)

FY 2025-06-30

MATERIAL NONCOMPLIANCE DISCLOSED$12,914,871 federal awards expended

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 (27 days from today).

What is a management decision? →
2025-005
Other
SIGNIFICANT DEFICIENCYREPEAT OF 2024-004OTHER MATTERS

We identified several required adjustments and corrections to the SEFA and SESFA as listed below: • Six federal programs were missing or had an incorrect assistance listing number. • One program improperly included on the SESFA that was moved to the SEFA. • One program improperly included under the incorrect oversight agency. • One program improperly reported as a direct grant. • One state program requiring adjustment to decrease the reported expenditures by $250,481. • Three programs improperly included as exempt programs. • One program had an incorrect state grant ID. Cause: Grant management and reporting is not centralized within the Town and are left to the individual departments. Grant agreements and the underlying information required to prepare the SEFA and SESFA are not maintained centrally. Effect or potential effect: This can result in an inaccurate amount reported in the SEFA, SESFA, or basic financial statements or the disallowance of expenditures / future awards by the grantor due to lack of proper reporting. Additionally, an inaccurate SEFA/SESFA can result in incorrect identification of major programs leading to further delays and inefficiencies in the audit. Recommendation: We recommend that Town management, in coordination with the departments, establish policy and procedures to help make certain all federal and state expended funds are captured timely and appropriately in the correct fiscal year in the SEFA and SESFA. Questioned costs: None Context: See condition above. Repeat finding: This is a repeat of finding 2024-001. View of responsible official: We agree with the finding. See corrective action plan.

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2025-005—Significant Deficiency and Noncompliance, Completeness and Accuracy of Schedule of Expenditures of Federal and State Awards (Repeat Finding 2024-004. Severity downgraded from material weakness to significant deficiency due to corrective actions implemented) U.S. Department of Agriculture Passed through State of Connecticut Department of Education Assistance Listing Number: 10.185 Program Name: Local Foods for Schools Incentive Program Assistance Listing Number: 10.579 Program Name: Child Nutrition Discretionary Grants Department of Homeland Security Passed through the State of Connecticut Emergency Management and Homeland Security Assistance Listing Number: 97.042 Program Name: Emergency Management Performance Grant U.S. Department of Health and Human Services Passed through the State Department of Public Health Assistance Listing Number: 93.323 Program Name: COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases U.S. Department of Transportation Assistance Listing Number: 20.939 Program Name: Safe Streets and Roads for All Passed through the State Department of Transportation Assistance Listing Number: 20.205 Program Name: Highway Planning and Construction U.S. Department of Treasury Passed through the State of Connecticut Department of Education and the State Office of Early Childhood Assistance Listing Number: 21.027 Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery FundsCriteria: Committee of Sponsoring Organizations (COSO) Framework – control activities: Proper review of the schedule of expenditures of federal awards (SEFA) and schedule of expenditure of state financial assistance (SESFA) includes the accuracy and completeness of the schedules. The SEFA and SESFA balance should be reconciled to the basic financial statements which are prepared in accordance with generally accepted accounting principles in the United States (U.S. GAAP). The Uniform Guidance 2 CFR 200.510 (b) requires the auditee (the Town) to prepare a schedule of expenditures of federal awards for the period covered by the auditee’s financial statements. The schedule must include the total federal and awards expended as determined in accordance with 2 CFR 200.502 and the Office of Policy and Management’s Compliance Supplement. Condition: We identified several required adjustments and corrections to the SEFA and SESFA as listed below: • Six federal programs were missing or had an incorrect assistance listing number. • One program improperly included on the SESFA that was moved to the SEFA. • One program improperly included under the incorrect oversight agency. • One program improperly reported as a direct grant. • One state program requiring adjustment to decrease the reported expenditures by $250,481. • Three programs improperly included as exempt programs. • One program had an incorrect state grant ID. Cause: Grant management and reporting is not centralized within the Town and are left to the individual departments. Grant agreements and the underlying information required to prepare the SEFA and SESFA are not maintained centrally. Effect or potential effect: This can result in an inaccurate amount reported in the SEFA, SESFA, or basic financial statements or the disallowance of expenditures / future awards by the grantor due to lack of proper reporting. Additionally, an inaccurate SEFA/SESFA can result in incorrect identification of major programs leading to further delays and inefficiencies in the audit. Recommendation: We recommend that Town management, in coordination with the departments, establish policy and procedures to help make certain all federal and state expended funds are captured timely and appropriately in the correct fiscal year in the SEFA and SESFA. Questioned costs: None Context: See condition above. Repeat finding: This is a repeat of finding 2024-001. View of responsible official: We agree with the finding. See corrective action plan.

Corrective Action Plan

2025-005 – Significant Deficiency and Noncompliance, Completeness and Accuracy of Schedule of Expenditures of Federal and State Awards (Repeat Finding 2024-001. Severity downgraded from material weakness to significant deficiency due to corrective actions implemented.) Audit Finding: There were several required adjustments and corrections to the Schedule of Expenditures of Federal Awards (SEFA) and the Schedule of Expenditure of State Financial Assistance (SESFA) as follows: (1) Six federal programs were missing or had an incorrect assistance listing number. (2) One program improperly included on the SESFA that was moved to the SEFA. (3) One program improperly included under the incorrect oversight agency. (4) One program improperly reported as a direct grant. (5) One state program requiring adjustment to decrease the reported expenditures by $250,481. (6) Three programs improperly included as exempt programs. (7) One program had an incorrect state grant ID. Corrective Action Taken: The Town Finance Department has placed an emphasis on timely tracking and reporting of grants, as can be seen from the improvement from material weakness to significant deficiency. The SEFA and SESFA will be prepared throughout the year by Town Finance, who will also maintain copies of all grant agreements. All positions in the BOE Finance Department and Town Finance have now been filled, and the Director of Finance at the BOE has implemented monthly reconciliation procedures. From the Town side, the reconciliations between the GAAP financial statements and amounts reported on the SEFA and SESA will be overseen by the Deputy Comptroller. The Deputy Comptroller and BOE Director of Finance meet regularly to discuss updates and issues and will reconcile the June 30, 2026 reports in the first quarter of FY2027. Anticipated Completion Date: In Process as of July 2025 Name and Phone # of Person Responsible for Implementation

Prior Finding References

2024-004

About Other →
2025-006
Procurement & Suspension/Debarment
MATERIAL WEAKNESSREPEAT OF 2024-005OTHER MATTERS

Procurement activities related to federal awards were performed by multiple departments and were not handled through a centralized procurement function. Management was unable to provide documentation demonstrating that vendors subject to suspension and debarment requirements were consistently reviewed against SAM.gov or that vendor certifications were obtained during the audit period. Cause: Procurement responsibilities were decentralized across departments, and management had not assigned responsibility, or implemented oversight procedures to ensure suspension and debarment requirements were addressed consistently for all federally funded procurements. Effect: Documentation of the requirement for suspension and debarment was not maintained. Contracts could be made with entities on the suspended and debarred list. Questioned costs: None.   2025-006—Material Weakness, Suspension and Debarment (Continued) Context: See condition above. There was no documentation for 14 selections tested. Identification as a repeat finding if applicable: 2024-005 Recommendation: We recommend the Town implement specific controls to ensure procurement files include suspension and debarment verification, where required. View of responsible officials: We agree with the finding. See corrective action plan.

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2025-006—Material Weakness, Suspension and Debarment U.S. Department of Agriculture Passed through the State of Connecticut Department of Education Child Nutrition Cluster Assistance Listing Number: 10.553 Program Name: School Breakfast Program Assistance Listing Number: 10.555 Program Name: National School Lunch Program U.S. Department of Treasury Passed through the State of Connecticut Office of Policy and Management Assistance Listing Number: 21.027 Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds U.S. Department of Education Passed through the State of Connecticut Department of Education Special Education Cluster (IDEA) Assistance Listing Number: 84.027 Program Name: Special Education Grants to States Assistance Listing Number: 84.173 Program Name: Special Education Preschool Grants U.S. Department of Transportation Passed through the State Department of Transportation Assistance Listing Number: 20.205 Program Name: Highway Planning and Construction Criteria: 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: Procurement activities related to federal awards were performed by multiple departments and were not handled through a centralized procurement function. Management was unable to provide documentation demonstrating that vendors subject to suspension and debarment requirements were consistently reviewed against SAM.gov or that vendor certifications were obtained during the audit period. Cause: Procurement responsibilities were decentralized across departments, and management had not assigned responsibility, or implemented oversight procedures to ensure suspension and debarment requirements were addressed consistently for all federally funded procurements. Effect: Documentation of the requirement for suspension and debarment was not maintained. Contracts could be made with entities on the suspended and debarred list. Questioned costs: None.   2025-006—Material Weakness, Suspension and Debarment (Continued) Context: See condition above. There was no documentation for 14 selections tested. Identification as a repeat finding if applicable: 2024-005 Recommendation: We recommend the Town implement specific controls to ensure procurement files include suspension and debarment verification, where required. View of responsible officials: We agree with the finding. See corrective action plan.

Corrective Action Plan

2025-006 Material Weakness and Noncompliance, Suspension and Debarment (Repeat Finding 2024-005) Audit Finding: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Documentation that such a verification was done must be maintained. The Town did not have documentation to support verification that three vendors were not excluded from federal contract due to debarment or suspension. Corrective Action Taken: The Town and Board of Education (BOE) have enhanced procurement controls to ensure suspension and debarment verifications are documented in accordance with 2 CFR 200.214. BOE’s Procurement Department routinely reviews SAM.gov to verify suspension and debarment status for all contracts, regardless of the funding source. Moving forward, a verification sheet will be included with all contract documentation. Additionally, BOE personnel involved in the procurement process have received training on applicable federal compliance requirements. The Procurement Department will also require vendors to complete suspension and debarment certification forms, which will be maintained within the Munis system by the Accounting Department. Anticipated Completion Date: In Process as of July 2025. Name and Phone # of Person Responsible for Implementation Joan Lynch, Comptroller, 203-622-2226

Prior Finding References

2024-005

About Procurement and Suspension and Debarment →
2025-007
Equipment & Real Property
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2024-007

The Town could not provide property records including all required information as indicated in 2 CFR section 200.313(d)(1). The Town did not perform a physical inventory of the property. Cause: The Town does not have processes and procedures in place related to equipment management, tracking and required physical inventories. Effect: The Town is not in compliance with federal grant requirements over the tracking and physical inventory of equipment. Improper equipment procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None. Context: See condition above. Identification as a repeat finding if applicable: 2024-007 Recommendation: We recommend the Town develop processes and procedures to tag and track equipment purchased with federal funding, and maintain support that physical inventories were performed as required. View of responsible officials: We agree with the finding. See corrective action plan.

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2025-007—Material Weakness and Material Noncompliance, Equipment and Real Property Management U.S. Department of Education Passed through the State of Connecticut Department of Education Education Stabilization Fund Assistance Listing Number: 84.425U Program Name: COVID-19 American Rescue Plan – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Assistance Listing Number: 84.425W Program Name: COVID-19 American Rescue Plan – Elementary and Secondary School Emergency Relief – Homeless Children and Youth Criteria: Non-federal entities other than states must follow 2 CFR sections 200.313 (c) through (e) which require that property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds the title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)) and a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)). Condition: The Town could not provide property records including all required information as indicated in 2 CFR section 200.313(d)(1). The Town did not perform a physical inventory of the property. Cause: The Town does not have processes and procedures in place related to equipment management, tracking and required physical inventories. Effect: The Town is not in compliance with federal grant requirements over the tracking and physical inventory of equipment. Improper equipment procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None. Context: See condition above. Identification as a repeat finding if applicable: 2024-007 Recommendation: We recommend the Town develop processes and procedures to tag and track equipment purchased with federal funding, and maintain support that physical inventories were performed as required. View of responsible officials: We agree with the finding. See corrective action plan.

Corrective Action Plan

2025-007 Material Weakness and Noncompliance, Equipment and Real Property Management (Repeat Finding 2024-007) Audit Finding: Non-federal entities other than states must follow 2 CFR sections 200.313 (c) through (e) which require that property records must be maintained that include a description of the property, a serial number or other identification number; the source of funding for the property, who holds the tile, the acquisition date, cost of property and other info. The Town could not provide property records including all required information as indicated in the 2 CFR section 200.313 (d)(1). The Town did not perform a physical inventory of the property. Corrective Action Taken: Management acknowledges the requirement for periodic physical inventory of federally funded assets. Given that such purchases are infrequent and currently limited to furniture used daily, we have determined that a full-scale inventory is not costeffective at this time. The assets remain in high-use public areas, providing constant visual verification of their existence. Management will formalize a physical inventory process should the volume or value of federally funded assets reach a material threshold. Anticipated Completion Date: Not applicable. Name and Phone # of Person Responsible for Implementation Joan Lynch, Comptroller, 203-622-2226

Prior Finding References

2024-007

About Equipment and Real Property Management →
2025-008
Reporting
MATERIAL WEAKNESSREPEAT OF 2024-008OTHER MATTERS

Three of four quarterly SLFRF project and expenditure reports tested included encumbrances in amounts reported as expenditures. Encumbrances represent committed but not yet incurred costs and do not meet the SLFRF definition of an expenditure. The fourth‑quarter report tested did not include encumbrances and reflected correction of this issue. Cause: The condition occurred because the application of SLFRF expenditure definitions was interpreted differently during preparation of the quarterly reports. At the time, the Town did not have documented procedures to guide reporting or a formal review process to confirm alignment with reporting requirements. Management subsequently clarified reporting expectations and corrected the issue in the fourth quarter. Effect: As a result, three quarterly SLFRF reports submitted to the U.S. Department of the Treasury were inaccurate and did not fully comply with federal reporting requirements. Questioned costs: None. Context: Of the four quarterly SLFRF reports tested, three included encumbrances in amounts reported as expenditures. The fourth‑quarter report tested reflected management’s corrective action and excluded encumbrances. Identification as a repeat finding if applicable: 2024-008 Recommendation: We recommend that the Town continue to apply the corrected reporting methodology and formalize procedures requiring reconciliation of reported expenditures to underlying general ledger detail to ensure that only incurred costs are reported in the SLFRF portal. View of responsible officials: We agree with the finding. See corrective action plan.

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2025-008 – Material Weakness and Noncompliance, Reporting U.S. Department of Treasury Passed through the State of Connecticut Office of Policy and Management Assistance Listing Number: 21.027 Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Criteria: Per terms and conditions of the award, quarterly project and expenditure reports (1505-0271). For purposes of reporting in the SLFRF portal, an expenditure is the amount that has been incurred as a liability of the entity (the service has been rendered or the good has been delivered to the entity). Condition: Three of four quarterly SLFRF project and expenditure reports tested included encumbrances in amounts reported as expenditures. Encumbrances represent committed but not yet incurred costs and do not meet the SLFRF definition of an expenditure. The fourth‑quarter report tested did not include encumbrances and reflected correction of this issue. Cause: The condition occurred because the application of SLFRF expenditure definitions was interpreted differently during preparation of the quarterly reports. At the time, the Town did not have documented procedures to guide reporting or a formal review process to confirm alignment with reporting requirements. Management subsequently clarified reporting expectations and corrected the issue in the fourth quarter. Effect: As a result, three quarterly SLFRF reports submitted to the U.S. Department of the Treasury were inaccurate and did not fully comply with federal reporting requirements. Questioned costs: None. Context: Of the four quarterly SLFRF reports tested, three included encumbrances in amounts reported as expenditures. The fourth‑quarter report tested reflected management’s corrective action and excluded encumbrances. Identification as a repeat finding if applicable: 2024-008 Recommendation: We recommend that the Town continue to apply the corrected reporting methodology and formalize procedures requiring reconciliation of reported expenditures to underlying general ledger detail to ensure that only incurred costs are reported in the SLFRF portal. View of responsible officials: We agree with the finding. See corrective action plan.

Corrective Action Plan

2024-008 Material Weakness and Noncompliance, Reporting (Repeat Finding 2024-008) Audit Finding: The Town improperly included encumbrances in expenditures on three of four quarterly reports due to a lack of understanding of reporting requirements (ARPA). As this was identified at the end of FY25, the fourth quarter report properly excluded encumbrances and reflected correction of this issue. Corrective Action Taken: As noted above and in this report, this was corrected as soon as we became aware of the issue, for fourth quarter reporting in FY25 and continues going forward. Anticipated Completion Date: In Process as of April 2025. Name and Phone # of Person Responsible for Implementation Joan Lynch, Comptroller, 203-622-2226

Prior Finding References

2024-008

About Reporting →

FY 2024-06-30

MATERIAL NONCOMPLIANCE DISCLOSED$16,780,512 federal awards expended

FAC accepted this audit on June 30, 2025 — management decision was due December 30, 2025.

2024-003
Other
SIGNIFICANT DEFICIENCYREPEAT OF 2023-003OTHER MATTERS

The Town did not submit the 2024 or the 2023 federal reporting package with the Federal Audit Clearinghouse within the required timeline stated in the criteria above. Cause: Management did not commit adequate resources to enable submission of the audit, reporting package and data collection form in a timely manner. Effect: Failure to submit the annual audit, reporting package and data collection form to the Federal Audit Clearinghouse in a timely manner will result in the Town not being eligible to be considered a low-risk auditee. This will affect the scope of the Uniform Guidance audit for the next two fiscal years. Additionally, the Town has not complied with the requirements of the Uniform Guidance which could impact future funding. Questioned costs: Not applicable. Context: Systemic in nature. Identification as a repeat finding if applicable: 2023-003 Recommendation: We recommend the Town establish internal control policies and procedures to allow for the timely submission of the Town’s annual audit, reporting package and data collection form to the Federal Audit Clearinghouse on an ongoing basis. View of responsible officials: We agree with the finding. See corrective action plan.

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2024-003 – Significant Deficiency and Noncompliance, Data Collection Form (Repeat Finding 2023-003) All granting agencies, pass-through entities and assistance listing numbers included in the accompanying schedule of expenditures of federal awards for the year ended June 30, 2024 and 2023. Criteria: 2 CFR 200.512(a)(1) requires that the Town’s annual audit be completed and the annual audit, reporting package and data collection form be submitted to the federal audit clearinghouse with the earlier of 30 days after receipt of the auditor’s reports or 9 months after the end of the Town’s fiscal year (March 31, 2025). Condition: The Town did not submit the 2024 or the 2023 federal reporting package with the Federal Audit Clearinghouse within the required timeline stated in the criteria above. Cause: Management did not commit adequate resources to enable submission of the audit, reporting package and data collection form in a timely manner. Effect: Failure to submit the annual audit, reporting package and data collection form to the Federal Audit Clearinghouse in a timely manner will result in the Town not being eligible to be considered a low-risk auditee. This will affect the scope of the Uniform Guidance audit for the next two fiscal years. Additionally, the Town has not complied with the requirements of the Uniform Guidance which could impact future funding. Questioned costs: Not applicable. Context: Systemic in nature. Identification as a repeat finding if applicable: 2023-003 Recommendation: We recommend the Town establish internal control policies and procedures to allow for the timely submission of the Town’s annual audit, reporting package and data collection form to the Federal Audit Clearinghouse on an ongoing basis. View of responsible officials: We agree with the finding. See corrective action plan.

Corrective Action Plan

2024-003- Significant Deficiency, Data Collection Form (Repeat Finding 2023-003) Audit Finding; The Town did not submit the 2024 or 2023 federal reporting packages with the Federal Audit Clearinghouse within the required timeline of either 30 days after receipt of the auditor’s reports or nine (9) months after the end of the Town’s fiscal year as required by CFR 200.512(a)(1). Corrective Action Taken: We agree with this audit finding, resulting from turnover at the BOE. The delays should not reoccur in the future. Name and Phone # of Person Responsible for Implementation Mr. Peter Mynarski, Comptroller 203-622-2226

Prior Finding References

2023-003

About Other →
2024-004
Other
MATERIAL WEAKNESSREPEAT OF 2023-004OTHER MATTERS

We identified 16 federal programs and 9 state programs requiring adjustment to the reported expenditures. We identified 4 programs included on the SEFA under the incorrect oversight agency. We also identified 2 programs missing from the SEFA. The Town failed to adequately perform a reconciliation of the SEFA and SESA to the financial statements. In addition, during testing of allowable costs, we discovered $98,252 of costs pertaining to FY2023 transactions that were included in the FY2024 SEFA, with a projected total error of $185,755. Cause: Grant management and reporting is not centralized within the Town and are left to the individual departments. Underlying accounting records are maintained on a budgetary basis until year end-reporting. Additionally, management as well as department heads are unfamiliar with grant accounting in accordance with U.S. GAAP. Effect or potential effect: This can result in an inaccurate amount reported in the SEFA, SESA, or basic financial statements or the disallowance of expenditures / future awards by the grantor due to lack of proper reporting. Additionally, an inaccurate SEFA/SESA can result in incorrect identification of major programs leading to further delays and inefficiencies in the audit. Recommendation: We recommend that Town management, in coordination with the departments; establish policy and procedures to help to make certain all federal and state expended funds are captured timely and appropriately in the correct fiscal year in the SEFA and SESA. Questioned costs: None Context: See condition above. Repeat finding: This is a repeat of finding 2023-001. View of responsible official: We agree with the finding. See corrective action plan.

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2024-004 – Material Weakness and Noncompliance, Completeness and Accuracy of Schedule of Expenditures of Federal and State Awards (Repeat Finding 2023-004) U.S. Department of Agriculture Passed through State of Connecticut Department of Education Child Nutrition Cluster Assistance Listing Number: 10.553 Program Name: School Breakfast Program Assistance Listing Number: 10.555 Program Name: National School Lunch Program Assistance Listing Number: 10.560 Program Name: State Administrative Expenses for Child Nutrition Assistance Listing Number: 10.649 Program Name: COVID-19 Pandemic Electronic Benefit (P-EBT) Administrative Costs Department of Homeland Security Passed through the State of Connecticut Emergency Management and Homeland Security Assistance Listing Number: 97.042 Program Name: Emergency Management Performance Grant U.S. Department of Education Passed through the State of Connecticut Department of Education Assistance Listing Number: 84.010 Program Name: Title I Grants to Local Education Agencies Special Education Cluster (IDEA) Assistance Listing Number: 84.027 Program Name: Special Education Grants to States Assistance Listing Number: 84.027 Program Name: COVID-19 Special Education Grants to States Assistance Listing Number: 84.173 Program Name: Special Education Preschool Grants Assistance Listing Number: 84.173 Program Name: COVID-19 Special Education Preschool Grants Assistance Listing Number: 84.048 Program Name: Career and Technical Education – Basic Grants to States Assistance Listing Number: 84.365 Program Name: English Language Acquisition to State Grants Assistance Listing Number: 84.367 Program Name: Supporting Effective Instruction State Grants Assistance Listing Number: 84.424 Program Name: Student Support and Academic Enrichment Program Education Stabilization Fund: Assistance Listing Number: 84.425D Program Name: COVID-19 Elementary and Secondary School Relief Fund (ESSER) Assistance Listing Number: 84.425U Program Name: COVID-19 American Rescue Plan - Elementary and Secondary School Emergency Relief Fund (ARP ESSER) U.S. Department of Health and Human Services Passed through the State Department of Public Health Assistance Listing Number: 93.268 Program Name: Immunization Cooperative Agreements Assistance Listing Number: 93.323 Program Name: COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases U.S. Department of Treasury Passed through the State of Connecticut Department of Education and the State Office of Early Childhood Assistance Listing Number: 21.027 Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery FundsCriteria: Committee of Sponsoring Organizations (COSO) Framework – control activities: Proper review of the schedule of expenditures of federal awards (SEFA) and schedule of expenditure of state awards (SESA) includes the accuracy and completeness of the schedules. The SEFA and SESA balance should be reconciled to the basic financial statements which are prepared in accordance with generally accepted accounting principles in the United States (U.S. GAAP).The Uniform Guidance (2 CFR 200.510 (b) requires the auditee (the Town) to prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements. The schedule must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. Condition: We identified 16 federal programs and 9 state programs requiring adjustment to the reported expenditures. We identified 4 programs included on the SEFA under the incorrect oversight agency. We also identified 2 programs missing from the SEFA. The Town failed to adequately perform a reconciliation of the SEFA and SESA to the financial statements. In addition, during testing of allowable costs, we discovered $98,252 of costs pertaining to FY2023 transactions that were included in the FY2024 SEFA, with a projected total error of $185,755. Cause: Grant management and reporting is not centralized within the Town and are left to the individual departments. Underlying accounting records are maintained on a budgetary basis until year end-reporting. Additionally, management as well as department heads are unfamiliar with grant accounting in accordance with U.S. GAAP. Effect or potential effect: This can result in an inaccurate amount reported in the SEFA, SESA, or basic financial statements or the disallowance of expenditures / future awards by the grantor due to lack of proper reporting. Additionally, an inaccurate SEFA/SESA can result in incorrect identification of major programs leading to further delays and inefficiencies in the audit. Recommendation: We recommend that Town management, in coordination with the departments; establish policy and procedures to help to make certain all federal and state expended funds are captured timely and appropriately in the correct fiscal year in the SEFA and SESA. Questioned costs: None Context: See condition above. Repeat finding: This is a repeat of finding 2023-001. View of responsible official: We agree with the finding. See corrective action plan.

Corrective Action Plan

2024-001 - Material Weakness and Noncompliance, Completeness and Accuracy of Schedule of Expenditures of Federal and State Awards (Repeat Finding 2023-001) Audit Finding: There were several adjustments to the basic financial statements, Schedule of Expenditure of Federal Awards (SEFA) and Schedule of Expenditures of State Awards (SESA) as originally provided by the Town. The SEFA and SESA balances are required to be reconciled to the basic financial statements prepared in accordance with generally accepted accounting principles in the United States (US GAAP). The Town has failed to adequately perform such reconciliation and as a result of procedures performed by RSM a number of adjustments to expenditures reported on the SEFA and SESA as well as to intergovernmental Revenues reported on the basic financial statements had to be performed. Corrective Action Taken: The Town Finance Department has placed an emphasis on educational meetings with the Board of Education within the area of receiving grants. These issues have resulted from the continual problem of employee turnover of personnel working within the areas of responsibility of grants accounting. All positions in the BOE Finance Department have now been filled, and the Director of Finance at the BOE has implemented monthly reconciliation procedures. From the Town side, the reconciliations between the GAAP financial statements and amounts reported on the SEFA and SESA will be overseen by the Town Comptroller. The Deputy Comptroller and BOE Director of Finance meet regularly to discuss updates and issues and will reconcile the June 30, 2025 reports in the first quarter of FY2026. Name and Phone # of Person Responsible for Implementation Mr. Peter Mynarski, Comptroller 203-622-2226

Prior Finding References

2023-004

About Other →
2024-005
Procurement & Suspension/Debarment
MATERIAL WEAKNESSQUESTIONED COSTSOTHER MATTERS

The Town did not have documentation to support verification that seven vendors were not excluded from federal contracts due to debarment or suspension. Cause: Due to significant staff turnover within the Greenwich Public Schools finance function during the audit period, established controls related to procurement were not consistently applied or effectively monitored. Effect: Documentation of the requirement for suspension and debarment was not maintained. Contracts could be made with entities on the suspended and debarred list. Questioned costs: None. Context: See condition above. There was no documentation for 3 out of 9 selections tested. Identification as a repeat finding if applicable: N/A Recommendation: We recommend the Town implement specific controls to ensure procurement files include suspension and debarment verification, where required. View of responsible officials: We agree with the finding. See corrective action plan.

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2024-005 Material Weakness and Noncompliance, Suspension and Debarment U.S. Department of Treasury Passed through the State of Connecticut Office of Policy and Management Assistance Listing Number: 21.027 Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds U.S. Department of Education Passed through the State of Connecticut Department of Education Special Education Cluster (IDEA) Assistance Listing Number: 84.027 Program Name: Special Education Grants to States Assistance Listing Number: 84.027 Program Name: COVID-19 Special Education Grants to State Grants Assistance Listing Number: 84.173 Program Name: Special Education Preschool Grants Assistance Listing Number: 84.173 Program Name: COVID-19 Special Education Preschool Grants Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The Town did not have documentation to support verification that seven vendors were not excluded from federal contracts due to debarment or suspension. Cause: Due to significant staff turnover within the Greenwich Public Schools finance function during the audit period, established controls related to procurement were not consistently applied or effectively monitored. Effect: Documentation of the requirement for suspension and debarment was not maintained. Contracts could be made with entities on the suspended and debarred list. Questioned costs: None. Context: See condition above. There was no documentation for 3 out of 9 selections tested. Identification as a repeat finding if applicable: N/A Recommendation: We recommend the Town implement specific controls to ensure procurement files include suspension and debarment verification, where required. View of responsible officials: We agree with the finding. See corrective action plan.

Corrective Action Plan

2024-005 Material Weakness and Noncompliance, Suspension and Debarment Audit Finding: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Documentation that such a verification was done must be maintained. The Town did not have documentation to support verification that three vendors were not excluded from federal contract due to debarment or suspension. Corrective Action Taken: We agree with this finding and will implement and document such a process going forward. Name and Phone # of Person Responsible for Implementation Mr. Peter Mynarski, Comptroller 203-622-2226

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2024-006
Reporting
MATERIAL WEAKNESS

The Town did not have documentation to support review of the annual report before submission. Cause: No documentation maintained for review of the annual reporting is a result of turnover in finance for the Greenwich Public Schools Effect: Annual reporting could be incorrect and require resubmission. Questioned costs: None. Context: See condition above. There was no documentation for the one annual report. Identification as a repeat finding if applicable: N/A Recommendation: We recommend the Town implement documentation requirements for reviews of reporting required by federal awards. View of responsible officials: We agree with the finding. See corrective action plan.

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2024-006 Material Weakness, Reporting U.S. Department of Education Passed through the State of Connecticut Department of Education Education Stabilization Fund Assistance Listing Number: 84.425D Program Name: COVID-19 Elementary and Secondary School Relief Fund (ESSER) Assistance Listing Number: 84.425U Program Name: COVID-19 American Rescue Plan - Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Criteria: Per terms and conditions of the award, Local Education Agencies (LEAs) must report annually on activities funded by the ESSER funds, and the Connecticut Department of Education utilizes the Electronic Grants Management System (eGMS) to collect this reporting. Condition: The Town did not have documentation to support review of the annual report before submission. Cause: No documentation maintained for review of the annual reporting is a result of turnover in finance for the Greenwich Public Schools Effect: Annual reporting could be incorrect and require resubmission. Questioned costs: None. Context: See condition above. There was no documentation for the one annual report. Identification as a repeat finding if applicable: N/A Recommendation: We recommend the Town implement documentation requirements for reviews of reporting required by federal awards. View of responsible officials: We agree with the finding. See corrective action plan.

Corrective Action Plan

2024-006 Material Weakness, Reporting Audit Finding: Per terms and conditions of the award, Local Education Agencies (LEAs) must report annually on activities funded by the ESSER funds, and the Connecticut Department of Education utilizes the Electronic Grants Management System (eGMS) to collect this reporting. The Town did not have documentation to support review of the annual report before submission. Corrective Action Taken: We agree with the finding and will review the annual report before submission going forward. This will be overseen by the BOE Director of Finance. Name and Phone # of Person Responsible for Implementation Mr. Peter Mynarski, Comptroller 203-622-2226

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2024-007
Equipment & Real Property
MATERIAL WEAKNESSMODIFIED OPINION

The Town could not provide property records including all required information as indicated in 2 CFR section 200.313(d)(1). The Town did not perform a physical inventory of the property. Cause: The Town does not have processes and procedures in place related to equipment management, tracking and required physical inventories. Effect: The Town is not in compliance with federal grant requirements over the tracking and physical inventory of equipment. Improper equipment procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None. Context: See condition above. Identification as a repeat finding if applicable: N/A Recommendation: We recommend the Town develop processes and procedures to tag and track equipment purchased with federal funding, and maintain support that physical inventory inventories were performed as required. View of responsible officials: We agree with the finding. See corrective action plan.

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2024-007 Material Weakness and Noncompliance, Equipment and Real Property Management U.S. Department of Education Passed through the State of Connecticut Department of Education Education Stabilization Fund Assistance Listing Number: 84.425D Program Name: COVID-19 Elementary and Secondary School Relief Fund (ESSER) Assistance Listing Number: 84.425U Program Name: COVID-19 American Rescue Plan - Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Criteria: Non-federal entities other than states must follow 2 CFR sections 200.313 (c) through (e) which require that property records must be maintained that include a description of the property, a serial number or other identification number; the source of funding for the property (including the federal award identification number), who holds the title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)) and a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)). Condition: The Town could not provide property records including all required information as indicated in 2 CFR section 200.313(d)(1). The Town did not perform a physical inventory of the property. Cause: The Town does not have processes and procedures in place related to equipment management, tracking and required physical inventories. Effect: The Town is not in compliance with federal grant requirements over the tracking and physical inventory of equipment. Improper equipment procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None. Context: See condition above. Identification as a repeat finding if applicable: N/A Recommendation: We recommend the Town develop processes and procedures to tag and track equipment purchased with federal funding, and maintain support that physical inventory inventories were performed as required. View of responsible officials: We agree with the finding. See corrective action plan.

Corrective Action Plan

2024-007 Material Weakness and Noncompliance, Equipment and Real Property Management Audit Finding: Non-federal entities other than states must follow 2 CFR sections 200.313 (c) through (e) which require that property records must be maintained that include a description of the property, a serial number or other identification number; the source of funding for the property, who holds the tile, the acquisition date, cost of property and other info. The Town could not provide property records including all required information as indicated in the 2 CFR section 200.313 (d)(1). The Town did not perform a physical inventory of the property. Corrective Action Taken: The Town maintains a list of physical inventory by capital project. While it is not cost-efficient to take a full physical inventory, the Town will develop a process to track equipment purchased with federal funding and will maintain support that physical inventories were performed as required. Name and Phone # of Person Responsible for Implementation Mr. Peter Mynarski, Comptroller 203-622-2226

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2024-008
Reporting
MATERIAL WEAKNESSOTHER MATTERS

One of four quarterly reports included encumbrances in reporting of expenditures. Encumbrances do not meet the definition of an expenditure as noted in the criteria above. Cause: The Town improperly included encumbrances in expenditures on one of four quarterly reports due to a clerical error. Effect: Reports submitted were inaccurate. Questioned costs: None. Context: See condition above. 1 of the 4 quarterly reports tested included encumbrances. Identification as a repeat finding if applicable: N/A Recommendation: We recommend the Town review reporting requirements and develop procedures to reconcile expenditure figures to the underlying general ledger detail. View of responsible officials: We agree with the finding. See corrective action plan.

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2024-008 Material Weakness and Noncompliance, Reporting U.S. Department of Treasury Passed through the State of Connecticut Office of Policy and Management Assistance Listing Number: 21.027 Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Criteria: Per terms and conditions of the award, quarterly project and expenditure reports (1505-0271). For purposes of reporting in the SLFRF portal, an expenditure is the amount that has been incurred as a liability of the entity (the service has been rendered or the good has been delivered to the entity). Condition: One of four quarterly reports included encumbrances in reporting of expenditures. Encumbrances do not meet the definition of an expenditure as noted in the criteria above. Cause: The Town improperly included encumbrances in expenditures on one of four quarterly reports due to a clerical error. Effect: Reports submitted were inaccurate. Questioned costs: None. Context: See condition above. 1 of the 4 quarterly reports tested included encumbrances. Identification as a repeat finding if applicable: N/A Recommendation: We recommend the Town review reporting requirements and develop procedures to reconcile expenditure figures to the underlying general ledger detail. View of responsible officials: We agree with the finding. See corrective action plan.

Corrective Action Plan

2024-008 Material Weakness and Noncompliance, Reporting Audit Finding: The Town improperly included encumbrances in expenditures on one of four quarterly reports due to a lack of understanding of reporting requirements (ARPA). Corrective Action Taken: We agree with this finding and will not include encumbrances in expenditures for these purposes going forward. Name and Phone # of Person Responsible for Implementation Mr. Peter Mynarski, Comptroller 203-622-2226

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2024-009
Procurement & Suspension/Debarment
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

The Town did not have documentation to support they complied with their purchasing policy or Uniform Guidance procurement requirements for three out of six selections. The Town did not have documentation to support it verified four vendors were not suspended or debarred for 4 out of 4 selections. Cause: Due to significant staff turnover within the Greenwich Public Schools finance function during the audit period, established controls related to procurement were not consistently applied or effectively monitored. Effect: Documentation of the requirement for procurement was not maintained. Questioned costs: $119,367 Context: See condition above. Identification as a repeat finding is applicable: N/A Recommendation: We recommend the Town develop and implement a comprehensive plan to address key personnel turnover. This plan should include clearly documented policies and procedures and appropriate cross-training to ensure continuity of operations and maintain adequate internal controls and retention of records. View of Responsible Officials: We agree with the finding. See corrective action plan.

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2024-009 – Material Weakness and Material Noncompliance – Procurement and Suspension and Debarment U.S. Department of Agriculture Passed through State of Connecticut Department of Education Child Nutrition Cluster Assistance Listing Number: 10.553 Program Name: School Breakfast Program Assistance Listing Number: 10.555 Program Name: National School Lunch Program Criteria: Per 2 CFR Part 200.320, “There are three types of procurement methods described in this section: informal procurement methods (for micro-purchases and simplified acquisitions); formal procurement methods (through sealed bids or proposals); and noncompetitive procurement methods. For any of these methods, the recipient or subrecipient must maintain and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319.” 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The Town did not have documentation to support they complied with their purchasing policy or Uniform Guidance procurement requirements for three out of six selections. The Town did not have documentation to support it verified four vendors were not suspended or debarred for 4 out of 4 selections. Cause: Due to significant staff turnover within the Greenwich Public Schools finance function during the audit period, established controls related to procurement were not consistently applied or effectively monitored. Effect: Documentation of the requirement for procurement was not maintained. Questioned costs: $119,367 Context: See condition above. Identification as a repeat finding is applicable: N/A Recommendation: We recommend the Town develop and implement a comprehensive plan to address key personnel turnover. This plan should include clearly documented policies and procedures and appropriate cross-training to ensure continuity of operations and maintain adequate internal controls and retention of records. View of Responsible Officials: We agree with the finding. See corrective action plan.

Corrective Action Plan

2024-009 Material Weakness and Material Noncompliance - Procurement and Suspension and Debarment Audit Finding: The Town did not have documentation to support following their purchasing policy for two out of six selections. The Town did not have documentation to support verification that four vendors were not excluded from federal contracts due to debarment or suspension. Corrective Action Taken: Procurement findings: 1. Performance Foodservice had two (2) invoices dated May 2023 (FY23) paid in FY24. For FY23 the BOE had a contract with Performance. The invoices were for prior year. No purchases were made in FY24, only payment from FY23 purchases. BOE believes the purchasing policy was followed. 2. Sardilli Produce, had 3 PO’s entered in FY24. One PO was for $80,000 for yearly invoices. 58 invoices were charged to PO. Average invoice total was $1,289. The approved PO did not follow purchasing policy. Suspension and Debarment addressed in 2024-005. Name and Phone # of Person Responsible for Implementation Mr. Peter Mynarski, Comptroller 203-622-2226

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FY 2023-06-30

$22,333,092 federal awards expended

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

2023-003
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Town did not submit the 2022 or 2023 federal reporting package with the Federal Audit Clearinghouse within the required timeline stated in the criteria above. Cause: Management did not commit adequate resources to enable submission of the financial statements in a timely manner. Effect: Failure to submit the annual audit package and data collection form to the Federal Audit Clearinghouse in a timely manner will result in the Town not being eligible to be considered a low-risk auditee. This will affect the scope of the Uniform Guidance audit for the next two fiscal years. Questioned costs: Not applicable. Context: Systemic in nature. Identification as a repeat finding if applicable: Not applicable. Recommendation: We recommend the Town establish internal control policies and procedures to allow for the timely submission of the Town’s annual audit package and data collection form to the Federal Audit Clearinghouse on an ongoing basis. View of responsible officials: We agree with the finding.

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2023-003 – Data Collection Form All assistance listing numbers included in the accompanying schedule of expenditures of federal awards for the year ended June 30, 2023 and 2022. Criteria: Section 200.512 of the Uniform Guidance requires that the Town’s annual audit be completed and the annual audit package and data collection form be submitted to the federal audit clearinghouse with the earlier of 30 days after receipt of the auditor’s reports or 9 months after the end of the Town’s fiscal year. Condition: The Town did not submit the 2022 or 2023 federal reporting package with the Federal Audit Clearinghouse within the required timeline stated in the criteria above. Cause: Management did not commit adequate resources to enable submission of the financial statements in a timely manner. Effect: Failure to submit the annual audit package and data collection form to the Federal Audit Clearinghouse in a timely manner will result in the Town not being eligible to be considered a low-risk auditee. This will affect the scope of the Uniform Guidance audit for the next two fiscal years. Questioned costs: Not applicable. Context: Systemic in nature. Identification as a repeat finding if applicable: Not applicable. Recommendation: We recommend the Town establish internal control policies and procedures to allow for the timely submission of the Town’s annual audit package and data collection form to the Federal Audit Clearinghouse on an ongoing basis. View of responsible officials: We agree with the finding.

Corrective Action Plan

Identifying #: 2023-001 and 2023-004 Finding: The finding refers to a number of adjustments to the SEFA and SESA as originally provided by the Town of Greenwich. Fifteen (15) federal programs and five (5) state programs required adjustments to the reported expenditures. Two (2) programs included on the SEFA did not have assistance listing numbers, which resulted in the programs being reported as being from the incorrect oversight agency. One program was missing from the SEFA. One program was reported as a state program that was a passthrough of a federal program. The SEFA and SESA balances are required to be reconciled to the basic financial statements prepared in accordance with generally accepted accounting principles in the United States (U.S. GAAP). The Town has failed to adequately perform such reconciliation. Corrective Actions Taken or Planned: Due to a large turnover rate at the Greenwich Public Schools over recent years in key positions, a lack of adequate oversight existed. The Town’s Finance Department was working with the new Chief Operations Officer (COO) at the Greenwich Public Schools and was in the process of assuming more responsibility and oversight in the reconciliation of the SEFA and SESA to the Town’s financial systems (MUINIS). Unfortunately, the staff turnover continues, and the new COO has resigned leaving another potential void in accurate accounting and reporting. The Town Finance Department is still striving to centralize grants accounting to ensure proper accounting and reporting. Name and Phone # of Person Responsible for Implementation:Mr. Peter Mynarski, Comptroller 203-622-2226

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2023-004
Reporting
MATERIAL WEAKNESSREPEAT OF 2022-001OTHER MATTERS

We identified 15 federal programs and five state programs requiring adjustment to the reported expenditures. We identified two programs included on the SEFA without an assistance listing number, which resulted in the programs being reported as from the incorrect oversight agency. We identified one program was missing from the SEFA. One program was reported as a state program that was a passthrough of a federal program. The SEFA and SESA balance is required to be reconciled to the basic financial statements prepared in accordance with generally accepted accounting principles in the United States (U.S. GAAP). The Town has failed to adequately perform such reconciliation. Cause: Grant management and reporting is not centralized within the Town and are left to the individual departments. Additionally, management as well as department heads are unfamiliar with grant accounting in accordance with U.S. GAAP. Effect or Potential Effect: This can result in an inaccurate amount reported in the SEFA, SESA, or basic financial statements or the disallowance of expenditures / future awards by the grantor due to lack of proper reporting. Recommendation: We recommend that Town management, in coordination with the departments; establish policy and procedures to help to make certain all federal and state expended funds are captured timely and appropriately in the correct fiscal year in the SEFA and SESA. Questioned Costs: None Context: See condition above. Repeat Finding: This is a repeat of finding 2022-001. View of Responsible Official: Due to turnover at the Greenwich Public Schools in key positions in recent years, the Town’s Finance Department has come to realize the grants reporting needs to be centralized. Initially, the Finance Department will assume more responsibility in the SEFA and SESA reconciliations of the reports to the Town’s financial software (MUNIS) until a Town-wide centralized grants reporting unit can be established. See corrective action plan.

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2023-001 – Material Weakness, Completeness and Accuracy of Schedule of Expenditures of Federal and State Awards (Repeat Finding 2022-001) Criteria: Committee of Sponsoring Organizations (COSO) Framework – control activities: Proper review of the schedule of expenditures of federal awards (SEFA) and schedule of expenditure of state awards (SESA) includes the accuracy and completeness of the schedules. Condition: We identified 15 federal programs and five state programs requiring adjustment to the reported expenditures. We identified two programs included on the SEFA without an assistance listing number, which resulted in the programs being reported as from the incorrect oversight agency. We identified one program was missing from the SEFA. One program was reported as a state program that was a passthrough of a federal program. The SEFA and SESA balance is required to be reconciled to the basic financial statements prepared in accordance with generally accepted accounting principles in the United States (U.S. GAAP). The Town has failed to adequately perform such reconciliation. Cause: Grant management and reporting is not centralized within the Town and are left to the individual departments. Additionally, management as well as department heads are unfamiliar with grant accounting in accordance with U.S. GAAP. Effect or Potential Effect: This can result in an inaccurate amount reported in the SEFA, SESA, or basic financial statements or the disallowance of expenditures / future awards by the grantor due to lack of proper reporting. Recommendation: We recommend that Town management, in coordination with the departments; establish policy and procedures to help to make certain all federal and state expended funds are captured timely and appropriately in the correct fiscal year in the SEFA and SESA. Questioned Costs: None Context: See condition above. Repeat Finding: This is a repeat of finding 2022-001. View of Responsible Official: Due to turnover at the Greenwich Public Schools in key positions in recent years, the Town’s Finance Department has come to realize the grants reporting needs to be centralized. Initially, the Finance Department will assume more responsibility in the SEFA and SESA reconciliations of the reports to the Town’s financial software (MUNIS) until a Town-wide centralized grants reporting unit can be established. See corrective action plan.

Corrective Action Plan

Identifying #: 2023-003 Finding: The Town did not submit the 2022 or 2023 federal reporting package with the Federal Audit Clearinghouse within the required timeline stated in the criteria above. Corrective Actions Taken or Planned: The Town has been unable to file in a timely manner, due to the implementation of GASB 87 and GASB 96. After going through this learning experience, the Town does not expect to exceed the filing requirements in future years. Name and Phone # of Person Responsible for Implementation: Mr. Peter Mynarski, Comptroller 203-622-2226

Prior Finding References

2022-001

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FY 2022-06-30

$23,138,167 federal awards expendedNo findings recorded this year

FAC accepted this audit on July 9, 2023 — management decision was due January 9, 2024.

FY 2021-06-30

LOW-RISK AUDITEE$15,450,966 federal awards expended

FAC accepted this audit on April 28, 2022 — management decision was due October 28, 2022.

2021-002
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Town did not perform a risk assessment on subrecipients or have a formal plan for monitoring subrecipients. Cause: While the Town held periodic meetings with subrecipients, they were unable to provide documentation to support compliance with parts of subrecipient monitoring requirements. Effect: The Town?s subrecipients could not comply with all requirements in accordance with the federal award. Questioned Costs: None. Context: The Town had made one subaward of approximately $64,000 to one subrecipient. Recommendation: We recommend performing and documenting a risk assessment for each subrecipient and a documented plan for subrecipient monitoring. View of Responsible Officials: The Town agrees with the finding. The Town has engaged an outside accounting firm to perform an audit and review of the entire Grants Management functions for the Town and the Public-School System.

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Criteria: 2 CFR section 200.331(a)(1) requires the passthrough entity to clearly identify all requirements imposed by the passthrough entity on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award. 2 CFR section 200.332(b) require the passthrough entity to evaluate each subrecipient?s risk of noncompliance for the purposes of determining appropriate subrecipient monitoring related to the subaward. 2 CFR sections 200.332(d) through (f) require the passthrough entity to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with terms and conditions of the subaward, and achieves performance goals. Condition: The Town did not perform a risk assessment on subrecipients or have a formal plan for monitoring subrecipients. Cause: While the Town held periodic meetings with subrecipients, they were unable to provide documentation to support compliance with parts of subrecipient monitoring requirements. Effect: The Town?s subrecipients could not comply with all requirements in accordance with the federal award. Questioned Costs: None. Context: The Town had made one subaward of approximately $64,000 to one subrecipient. Recommendation: We recommend performing and documenting a risk assessment for each subrecipient and a documented plan for subrecipient monitoring. View of Responsible Officials: The Town agrees with the finding. The Town has engaged an outside accounting firm to perform an audit and review of the entire Grants Management functions for the Town and the Public-School System.

Corrective Action Plan

The finding was the result of a failure to properly perform and document a risk assessment for subrecipients and to document a plan for subrecipient monitoring. The Town has engaged an outside accounting firm to perform an audit and review of the entire Grants Managementfunctions for the Town and the Public-School System. The Town plans to implement these procedures for the fiscal year ending June 30, 2022

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FY 2020-06-30

LOW-RISK AUDITEE$6,450,424 federal awards expendedNo findings recorded this year

FAC accepted this audit on February 25, 2021 — management decision was due August 25, 2021.

FY 2019-06-30

LOW-RISK AUDITEE$7,815,260 federal awards expendedNo findings recorded this year

FAC accepted this audit on January 1, 2020 — management decision was due July 1, 2020.

FY 2018-06-30

LOW-RISK AUDITEE$5,981,745 federal awards expendedNo findings recorded this year

FAC accepted this audit on January 7, 2019 — management decision was due July 7, 2019.

FY 2017-06-30

LOW-RISK AUDITEE$5,165,021 federal awards expendedNo findings recorded this year

FAC accepted this audit on January 10, 2018 — management decision was due July 10, 2018.

FY 2016-06-30

LOW-RISK AUDITEE$6,704,415 federal awards expendedNo findings recorded this year

FAC accepted this audit on January 10, 2017 — management decision was due July 10, 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.

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