Town of Stratford, ConnecticutLocal Government

2024-002 Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Federal Agency: Department of Housing and Urban Development Federal Program Name: Economic Development Initiative - Community Project Funding Grants Assistance Listing Number: 14.251 Federal Award Identification Number and Year: B22CPCT0195 - 2022 Award Period: June 14, 2023 through August 31, 2030 Criteria The Grantee must submit a performance report in DRGR on a semi-annual basis. The reports are required to be submitted no later than 30 calendar days after the end of the 6-month reporting periods. Condition The required report for the period January 1, 2024 through June 30, 2024 was submitted on July 31, 2024, one day after the due date. Questioned Costs None Context The required report was submitted 1 day late. Cause Minor oversight related to the timing of report due dates (end of month vs. 30 days). Effect The required reports were not submitted timely. Repeat Finding No Recommendation We recommend the Town review control procedures to ensure that all grantor required forms are submitted timely. Views of Responsible Officials Management agrees with the recommendations. The Town has taken action to prevent recurrence including adding due dates to the calendar.

2022-002 Suspension and Debarment Federal Agency Department of the Treasury Federal Program Name COVID 19 ? American Rescue Plan Act Assistance Listing Number 21.027 Federal Award Identification Number SLFRP5459 Grant Year 2021 Pass-Through Agency Connecticut Office of Policy and Management Pass-Through Number 12060-OPM20600-29669 Award Period March 3, 2021 ? December 31, 2026 Type of Finding Significant Deficiency in Internal Control over Compliance Criteria Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300. Condition The Town does not perform a review of Suspension and Debarment. Questioned Costs None Context Out of a population of seven, CliftonLarsonAllen LLP (CLA) tested five sealed bids to determine the Town included documentation noting a review of Suspension and Debarment. The sample was statistically valid. The Purchasing Agent indicated they do not perform a review, therefore, there is no documentation present. However, CLA noted none of the vendors for which ARPA expenditures were incurred were debarred per review of CT Suspension and Debarment list and SAM.gov Exclusion list. Effect The Town is at risk of entering into a transaction with a suspended or debarred entity if a proper review does not occur prior to the award of contracts with federal funds. Cause Proper controls over suspension and debarment are not in place. Recommendation CLA recommends that the Town perform a review to verify that contractors are not suspended or debarred prior to awarding them a contract. Further, it is recommended that the Town formally document that the review had been performed. A formal policy should be put into place so that this occurs on each applicable procurement. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding. The Town will include within the conditions of a sealed bid that a review over Suspension and Debarment will occur. Further, the Purchasing Agent will have a member of his team review this prior to signing any awards and the signature on the award will serve as a level of review.

2021-002 Period of Performance Federal Agency Department of Treasury Federal Program Mane Coronavirus Relief Funds Assistance Listing Number 21.019 Pass-Through Agency State of Connecticut, Department of Education Pass-Through Number 12060-SDE64370-29561-2021 Award Period 7/1/2020 ? 12/30/2020 Type of Finding Immaterial Noncompliance Criteria Payments must be made not late than 120 calendar days after end date of the period of performance. Questions Costs None Context Out of a population of 103 and sample size of 13, only one finding was present after review of purchase orders, invoices, and check disbursements. The sample selected as described above was a statistically valid sample. Effect Noncompliance Cause Unknown Recommendation CLA recommends the client make cash disbursements for grants which have a period of performance requirement in a timelier manner. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding. The department will pay close attention to those grants with period of performance requirements to ensure all payments are made in a timely manner.

2021-003 Special Tests and Provisions Federal Agency Department of Housing and Urban Development Federal Program Mane Community Development Block Grant Assistance Listing Number 14.218 Pass-Through Agency N/A Direct Grant Pass-Through Number N/A Award Period 7/1/2020 ? 6/30/2021 Type of Finding Significant Deficiency in Internal Control over Compliance Criteria When CDBG funds are used for rehabilitation, the grantee must ensure that the work is properly completed. This includes verification that pre-rehabilitation inspections are conducted describing the deficiencies to be corrected and incorporated into the rehabilitation contract. Questions Costs None Context Five out of five projects were tested. Support was not maintained for any of the projects. Effect Cannot affirm that these inspections were properly performed. Cause Vacancy in the CDBG manager position and lack of controls Recommendation CLA recommends the client develop procedures and controls to ensure they maintain pre-inspection support and contracts on file per project. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding. The Town has hired a full-time Community Development Director where in the past the predecessor had multiple roles.

2021-004 Reporting Federal Agency Department of Housing and Urban Development Federal Program Mane Community Development Block Grant Assistance Listing Number 14.218 Pass-Through Agency N/A Direct Grant Pass-Through Number N/A Award Period 7/1/2020 ? 6/30/2021 Type of Finding Significant Deficiency in Internal Control over Compliance Criteria Once per project year, the Grantee is required to submit a PR03 Activity Summary Report, a PR26 Financial Summary Report, a PR26 CARES Act Financial Summary Report, and a PR26 Activity Summary by Selected Grant report. Also, on a quarterly basis, the Grantee is required to submit SF-425 Federal Financial Report. Condition The Town did not have internal controls in place to review the information the reports contained, and they were submitted without review other than the preparer. Questions Costs None Context The program has 8 reports as listed in the Criteria section above. Effect The reporting could be inaccurate Cause Vacancy in the CDBG manager position and lack of controls over reporting Recommendation CLA recommends the Town institute proper processes and related controls over reporting process. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding. The Town has hired a full-time Community Development Director where in the past the predecessor had multiple roles. These reporting requirements are now reviewed prior to submission.

2021-005 Special Tests and Provisions Federal Agency Department of Housing and Urban Development Federal Program Mane Community Development Block Grant Assistance Listing Number 14.218 Pass-Through Agency N/A Direct Grant Pass-Through Number N/A Award Period 7/1/2020 ? 6/30/2021 Type of Finding Significant Deficiency in Internal Control over Compliance Criteria When Community Development Block Grant funds are used for the rehabilitation of residential property, wage rate requirements are applicable and this should be indicated in the project contract. Condition The Town could not locate the contracts for these projects to show that wage rate requirements were included. Questions Costs None Context The Town had 18 projects that were subject to wage rate requirements. Effect Wage rate requirements may not have been followed. Cause Vacancy in the CDBG manager position and lack of controls over reporting Recommendation CLA recommends the Town institute proper processes and related controls over reporting process. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding. The Town has hired a full-time Community Development Director where in the past the predecessor had multiple roles.

2020-002 Activities Allowed or Unallowed Type of Finding: Material Noncompliance (Modified Opinion) Material Weakness in Internal Control over Compliance Program Special Education Cluster (IDEA) - 84.173/84.027 and Title I Grants to Local Educational Agencies - 84.010 Pass-Through Agency Passed through the State of Connecticut, Department of Education: IDEA - 12060-SDE64370-20977-2019/2020 and 12060-SDE64370-20983-2019/2020 Title I - 12060-SDE64370-20679-2019/2020 Criteria Program regulations specify payrate documentation is maintained to provide evidence of payrate approval. Condition Of 20 participants tested for payrate approval, all 20 were found to not have applicable documentation within their personnel files. Questioned Costs None Context Payroll expenditures make up 80% of total grant expenditures. The sample selected as described above was a statistically valid sample. Effect Due to lack of documentation, it is unknown if payrates used to compensate personnel are accurate and approved accordingly. Cause Lack of documentation within personnel files. Recommendation It is recommended that an approved master file be maintained of all employees payrates along with approved payrate documentation maintained within each individual?s personnel file. Views of Responsible Officials and Planned Corrective Actions Management agrees with the recommendations. The Board of Education has developed a procedure to provide a formal pay rate approval process for its employees each year. This procedure will include the Finance Department advancing salaries based on contractual agreements in the Alio system. A master report by Union will be provided to the Human Resource Department for review and approval.

2020-003 Program Eligibility - repeat finding 2019-001 Type of Finding - Material Weakness in Internal Control Over Compliance, Other Matters Program Child Nutrition Cluster CFDA #10.555/10.553 Pass-Through Agency Passed through the State of Connecticut, Department of Education: 12060-SDE64370-20560, 12060-SDE64370-29572, 12060-SDE64370-29576, 12060-SDE64370-20508 Criteria Program regulations specify that a student is eligible based on income, direct certification or SNAP/Food Stamp (free if <130% of federal poverty level, reduced if <185%). Condition Of the 25 students tested for eligibility, an application could not be found for one. Questioned Costs None Context Although 1 missing application is not deemed a significant issue on its own, this is the 3rd year in a row a finding in this program has occurred. The sample selected as described above was a statistically valid sample. Effect Ineligible participants are potentially being served by the program. Cause The Town believes the student was added to the list of eligible students in error, and that an application never actually existed. Recommendation The Town has since hired an employee to oversee this program. In addition, the Town has gone to universal free meals for year 20/21 eliminating the need for applications. Views of Responsible Officials and Planned Corrective Actions Management agrees with the recommendations. The Board of Education has since hired an employee to oversee this program. In addition, the Board of Education implemented the state recommended software, NutriKids, to manage the lunch programs and applications. In year 20/21, the Board of Education is participating in USDA Seamless Summer Option free meals program.

2019-001 Program Eligibility Program Child Nutrition Cluster CFDA #10.555/10.553 Pass-Through Agency Passed through the State of Connecticut, Department of Education. Criteria Program regulations specify that a student is eligible based on income, direct certification or SNAP/Food Stamp (free if <130% of federal poverty level, reduced if <185%). Condition The applications for students attending Franklin Elementary School could not be located. Questioned Costs None Context Approximately 4,000 free and reduced meals are served at Franklin Elementary School each month. Effect Due to the lack of applications, it is unknown if ineligible participants are being served by the program. Cause The employee in charge of applications at Franklin Elementary School is no longer an employee of the Stratford Board of Education, and the applications could not be located in her absence. Recommendation In future years, applications should be properly filed and retained. Views of Responsible Officials and Planned Corrective Actions Management agrees with the recommendations. Corrective action will be taken to ensure applications are properly maintained in the future.

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