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AYER SHIRLEY REGIONAL SCHOOL DISTRICTLocal Government

EIN: 272558415

UEI: EGCMNDKKL9N4

Audited by: ROSELLI, CLARK AND ASSOCIATES

Oversight agency: 84 [Department of Education]

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Data as of August 28, 2026

AYER SHIRLEY REGIONAL SCHOOL DISTRICT10 audit years26 findings16 repeat
10
Audit Years
26
Total Findings
16
Repeat Findings
$1.8M
Federal Awards Expended (FY 2025)

FY 2025-06-30

$1,847,290 federal awards expendedNo findings recorded this year

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on March 25, 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 25, 2026 (27 days from today).

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FY 2024-06-30

$3,341,366 federal awards expendedNo findings recorded this year

FAC accepted this audit on May 1, 2025 — management decision was due November 1, 2025.

FY 2023-06-30

$3,916,442 federal awards expended

FAC accepted this audit on June 24, 2024 — management decision was due December 24, 2024.

2023-003
Reporting
MATERIAL WEAKNESS

The District recorded a duplicate deposit of $133,868 in federal funds to the general ledger. Cause: There is a lack of reconciling the general ledger activity to the final financial reporting before submission to the Department of Elementary and Secondary Education. Effect: Material audit adjustments were required to the District’s general ledger for financial reporting purposes. The client did not duplicate the deposit on the final financial report submitted to the Department of Elementary and Secondary Education. Repeat Finding from Prior Year: No. Recommendation: The District should implement a process to reconcile final financial reports to the general ledger before submission. Views of Responsible Official: Management agrees with the finding.

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2023-003 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education COVID-19 – Education Stabilization Fund – ALN 84.425, 84.425D, 84.425U, 84.425W Material Weakness in Internal Controls Over Compliance Criteria: Per 2 CFR section 200.1, proper internal controls should be implemented to ensure transactions are properly recorded and accounted for in order to permit the preparation of reliable financial statements and federal reports. Condition: The District recorded a duplicate deposit of $133,868 in federal funds to the general ledger. Cause: There is a lack of reconciling the general ledger activity to the final financial reporting before submission to the Department of Elementary and Secondary Education. Effect: Material audit adjustments were required to the District’s general ledger for financial reporting purposes. The client did not duplicate the deposit on the final financial report submitted to the Department of Elementary and Secondary Education. Repeat Finding from Prior Year: No. Recommendation: The District should implement a process to reconcile final financial reports to the general ledger before submission. Views of Responsible Official: Management agrees with the finding.

Corrective Action Plan

Condition: The District recorded a duplicate deposit of $133,868 in federal funds to the general ledger. Corrective Action Planned: The Central Office will ensure that the general ledger transactions are reconciled to the final financial reports before submission to DESE. Anticipated Completion Date: June 30, 2025 Contact: William Plunkett, Director of Finance

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FY 2022-06-30

$4,103,061 federal awards expendedNo findings recorded this year

FAC accepted this audit on August 22, 2023 — management decision was due February 22, 2024.

FY 2021-06-30

$2,852,241 federal awards expended

FAC accepted this audit on April 13, 2023 — management decision was due October 13, 2023.

2021-002
Activities Allowed or Unallowed / Cost Allowability
MODIFIED OPINIONSIGNIFICANT DEFICIENCYQUESTIONED COSTS

2021-002 Improve Documentation of Approvals Over Disbursements Federal Programs Information Federal Agency: U.S. Department of Treasury Cluster/Program: Coronavirus Relief Fund Federal Program(s) Name: Coronavirus Relief Fund AL Number(s): 21.019 Pass-through Entity: Massachusetts Department of Elementary and Secondary Education Award Year: 2021 Compliance Requirement: Allowable Costs/Cost Principles Federal Agency: U.S. Department of Education Cluster/Program: Elementary and Secondary School Emergency Relief Fund (ESSER) Federal Program(s) Name: Education Stabilization Fund AL Number(s): 84.425D Pass-through Entity: Massachusetts Department of Elementary and Secondary Education Award Year: 2021 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding Compliance Internal Control over Compliance ? Significant Deficiency Criteria or Specific Requirement Grantees must provide reasonable assurance that federal awards are expended only for allowable activities and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Management of the District is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context As described further in finding 2021-001, control deficiencies related to disbursements were noted as a result of testing of internal controls. Samples of vendor disbursements charged to major programs were also tested in order to determine internal control over and compliance with Allowable Costs/Cost Principles. As a result of testing of vendor disbursements, inadequate documentation of approval for certain items was identified. Cause Weaknesses in the design and implementation of internal controls. Effect or Potential Effect There is a risk that amounts charged to federal awards may not be allowable or in accordance with applicable cost principles. Questioned Costs Known or likely questioned costs consist of the following: $76,773 charged to the 21.019 Coronavirus Relief Fund $280,475 charged to the 84.425D Elementary and Secondary School Emergency Relief Fund Recommendation The District should take the steps necessary to address the weakness in internal controls noted above in order to provide reasonable assurance that federal awards are expended only for allowable activities, and that the costs of goods and services charged to federal awards are allowable and in accordance with applicable cost principles. Views of Responsible Official Management agrees with the finding. Planned Corrective Action Management?s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

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2021-002 Improve Documentation of Approvals Over Disbursements Federal Programs Information Federal Agency: U.S. Department of Treasury Cluster/Program: Coronavirus Relief Fund Federal Program(s) Name: Coronavirus Relief Fund AL Number(s): 21.019 Pass-through Entity: Massachusetts Department of Elementary and Secondary Education Award Year: 2021 Compliance Requirement: Allowable Costs/Cost Principles Federal Agency: U.S. Department of Education Cluster/Program: Elementary and Secondary School Emergency Relief Fund (ESSER) Federal Program(s) Name: Education Stabilization Fund AL Number(s): 84.425D Pass-through Entity: Massachusetts Department of Elementary and Secondary Education Award Year: 2021 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding Compliance Internal Control over Compliance ? Significant Deficiency Criteria or Specific Requirement Grantees must provide reasonable assurance that federal awards are expended only for allowable activities and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Management of the District is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context As described further in finding 2021-001, control deficiencies related to disbursements were noted as a result of testing of internal controls. Samples of vendor disbursements charged to major programs were also tested in order to determine internal control over and compliance with Allowable Costs/Cost Principles. As a result of testing of vendor disbursements, inadequate documentation of approval for certain items was identified. Cause Weaknesses in the design and implementation of internal controls. Effect or Potential Effect There is a risk that amounts charged to federal awards may not be allowable or in accordance with applicable cost principles. Questioned Costs Known or likely questioned costs consist of the following: $76,773 charged to the 21.019 Coronavirus Relief Fund $280,475 charged to the 84.425D Elementary and Secondary School Emergency Relief Fund Recommendation The District should take the steps necessary to address the weakness in internal controls noted above in order to provide reasonable assurance that federal awards are expended only for allowable activities, and that the costs of goods and services charged to federal awards are allowable and in accordance with applicable cost principles. Views of Responsible Official Management agrees with the finding. Planned Corrective Action Management?s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

Corrective Action Plan

2021-002 Improve Documentation of Approvals Over Disbursements Views of Responsible Official Management agrees with the findings. Planned Corrective Action The Ayer Shirley Regional School District's Financial Management Procedures Manual has been updated to be compliant with the Uniform Grant Guidance in 2 CFR 200.317-327. The confirmation letter from the DESE can be found here: FY22 Ayer Shirley 0616 PR Final Report MF - Copy.pdf. Suppmting documentation for vendor disbursements charged to major programs will be required and records will be kept in paper and electronic form. The Director of Finance will review expenditures from federal awards to make sure they are allowable and in accordance with applicable cost principles. Planned Implementation Date of Corrective Action: 1/5/2023 Person Responsible for Corrective Action: Finance Director, Accounts Payable Specialist.

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →

FY 2020-06-30

$1,376,647 federal awards expended

FAC accepted this audit on July 28, 2021 — management decision was due January 28, 2022.

2020-002
Program Income
SIGNIFICANT DEFICIENCYREPEAT OF 2019-004OTHER MATTERS

2020-002 Improve Controls Over Program Income Federal Program(s) Information Federal Agency: U.S. Department of Agriculture ? Food and Nutrition Service Cluster: Child Nutrition Cluster Federal Program Name: School Breakfast and National School Lunch Program CFDA Number(s): 10.553/10.555 Pass-Through Entity: Massachusetts Department of Elementary and Secondary Education Award Year: 2020 Compliance Requirement: Program Income Type of Finding Internal Control Over Compliance - Significant Deficiency Criteria or Specific Requirement The requirements that apply to program income are contained in 2 CFR section 200.80 (definition of ?program income?), 2 CFR section 200.307 (program income), program legisla?tion, Federal awarding agency regulations, and the terms and conditions of the Federal award. Program income is gross income earned by a non-Federal entity that is directly generated by a supported activity or earned as a result of the Federal award during the period of performance (unless there is a requirement for disposition of program income after the end of the period of performance as provided in 2 CFR Section 200.307(f)). Program income may be used in any of three methods consistent with 2 CFR Section 200.307(e). Management of the District is responsible for establishing and maintaining effective internal control over compliance with Federal requirements that have a direct and material effect on a Federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a Federal program on a timely basis. Condition and Context The individual responsible for counting and reconciling collections to daily reports and preparing deposits and turnovers is the same individual who is involved in the initial receipt process. Additionally, we noticed that there were no signoffs documenting approval during the various steps in the cash out process, including oversight by individuals that are not involved in the receipt process to assure deposit accounts correspond to receipt records. Cause Weaknesses in the design and operation of controls. Effect or Potential Effect Due to the weaknesses in internal controls noted above, there is a risk that program income could be misappropriated and not detected and corrected on a timely basis. No questioned costs were reported because it was not quantifiable. Identification as a Repeat Finding As identified in Section IV, the Schedule of Prior Year Findings, this is a repeat of finding 2019-004. Recommendation The District should improve internal controls over program income by requiring an individual that is not involved in the receipts process verify that program income collected was properly deposited to the District?s bank account and recorded in the general ledger. This review should be documented, preferably with dual signatures of the preparer and the reviewer. Written policies and procedures should also be implemented to document this requirement and process.

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2020-002 Improve Controls Over Program Income Federal Program(s) Information Federal Agency: U.S. Department of Agriculture ? Food and Nutrition Service Cluster: Child Nutrition Cluster Federal Program Name: School Breakfast and National School Lunch Program CFDA Number(s): 10.553/10.555 Pass-Through Entity: Massachusetts Department of Elementary and Secondary Education Award Year: 2020 Compliance Requirement: Program Income Type of Finding Internal Control Over Compliance - Significant Deficiency Criteria or Specific Requirement The requirements that apply to program income are contained in 2 CFR section 200.80 (definition of ?program income?), 2 CFR section 200.307 (program income), program legisla?tion, Federal awarding agency regulations, and the terms and conditions of the Federal award. Program income is gross income earned by a non-Federal entity that is directly generated by a supported activity or earned as a result of the Federal award during the period of performance (unless there is a requirement for disposition of program income after the end of the period of performance as provided in 2 CFR Section 200.307(f)). Program income may be used in any of three methods consistent with 2 CFR Section 200.307(e). Management of the District is responsible for establishing and maintaining effective internal control over compliance with Federal requirements that have a direct and material effect on a Federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a Federal program on a timely basis. Condition and Context The individual responsible for counting and reconciling collections to daily reports and preparing deposits and turnovers is the same individual who is involved in the initial receipt process. Additionally, we noticed that there were no signoffs documenting approval during the various steps in the cash out process, including oversight by individuals that are not involved in the receipt process to assure deposit accounts correspond to receipt records. Cause Weaknesses in the design and operation of controls. Effect or Potential Effect Due to the weaknesses in internal controls noted above, there is a risk that program income could be misappropriated and not detected and corrected on a timely basis. No questioned costs were reported because it was not quantifiable. Identification as a Repeat Finding As identified in Section IV, the Schedule of Prior Year Findings, this is a repeat of finding 2019-004. Recommendation The District should improve internal controls over program income by requiring an individual that is not involved in the receipts process verify that program income collected was properly deposited to the District?s bank account and recorded in the general ledger. This review should be documented, preferably with dual signatures of the preparer and the reviewer. Written policies and procedures should also be implemented to document this requirement and process.

Corrective Action Plan

2020-002 Improve controls Over Program Income Views of Responsible Official Management agrees with the findings. Planned Corrective Action The Food Service Coordinator for the district verifies and reconciles the collections to daily and monthly deposits and is not involved in the initial receipt process. The Finance Director will assure that deposit accounts correspond to the receipt records as part of the monthly cash reconciliation. Planned Implementation Date of Corrective Action: 7/1//2021 Person Responsible for Corrective Action: Finance Director, Food Service Coordinator

Prior Finding References

2019-004

About Program Income →
2020-003
Procurement & Suspension/Debarment
MODIFIED OPINIONSIGNIFICANT DEFICIENCYQUESTIONED COSTS

2020-003 Improve Controls Over Procurement Federal Program(s) Information Federal Agency: U.S. Department of Education ? Office of Special Education and Rehabilitative Services Cluster: Special Education Cluster Federal Program Name: Special Education Grants to States and Special Education Preschool Grants CFDA Number(s): 84.027/84.173 Pass-Through Entity: Massachusetts Department of Elementary and Secondary Education Award Year: 2020 Compliance Requirement Procurement and Suspension and Debarment Type of Finding Compliance Internal Control Over Compliance - Significant Deficiency Criteria or Specific Requirement Grantees are required to comply with certain procurement standards as defined in 2 CFR section 200.318. These standards include the requirement that the grantee must use its own documented procurement procedures which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal law. In addition, the grantee must award contracts only to responsible contractors possessing the ability to perform successfully under the terms and conditions of a proposed procurement. Further, the grantee must maintain records sufficient to detail the history of procurement. Management of the District is also responsible for establishing and maintaining effective internal control over compliance with Federal requirements that have a direct and material effect on a Federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a Federal program on a timely basis. Condition and Context During out testing we noted that the District did not follow proper procurement procedures to obtain three written quotes for a purchase exceeding $10,000 for one of our selections as required by Uniform Guidance. Cause Weaknesses in the design and operation of controls. We understand that staff turnover may have contributed to this finding. Effect or Potential Effect Due to the weaknesses in internal controls noted above, there is a risk that contracts procured with Federal funds may not be awarded to suitable contractors in accordance with the require-ments of the Uniform Guidance. Known questioned costs are $26,712, which equals the purchase amount. Recommendation The District should address the weaknesses in internal controls noted above in order to ensure that Federal procurements are conducted in accordance with Federal and State requirements.

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2020-003 Improve Controls Over Procurement Federal Program(s) Information Federal Agency: U.S. Department of Education ? Office of Special Education and Rehabilitative Services Cluster: Special Education Cluster Federal Program Name: Special Education Grants to States and Special Education Preschool Grants CFDA Number(s): 84.027/84.173 Pass-Through Entity: Massachusetts Department of Elementary and Secondary Education Award Year: 2020 Compliance Requirement Procurement and Suspension and Debarment Type of Finding Compliance Internal Control Over Compliance - Significant Deficiency Criteria or Specific Requirement Grantees are required to comply with certain procurement standards as defined in 2 CFR section 200.318. These standards include the requirement that the grantee must use its own documented procurement procedures which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal law. In addition, the grantee must award contracts only to responsible contractors possessing the ability to perform successfully under the terms and conditions of a proposed procurement. Further, the grantee must maintain records sufficient to detail the history of procurement. Management of the District is also responsible for establishing and maintaining effective internal control over compliance with Federal requirements that have a direct and material effect on a Federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a Federal program on a timely basis. Condition and Context During out testing we noted that the District did not follow proper procurement procedures to obtain three written quotes for a purchase exceeding $10,000 for one of our selections as required by Uniform Guidance. Cause Weaknesses in the design and operation of controls. We understand that staff turnover may have contributed to this finding. Effect or Potential Effect Due to the weaknesses in internal controls noted above, there is a risk that contracts procured with Federal funds may not be awarded to suitable contractors in accordance with the require-ments of the Uniform Guidance. Known questioned costs are $26,712, which equals the purchase amount. Recommendation The District should address the weaknesses in internal controls noted above in order to ensure that Federal procurements are conducted in accordance with Federal and State requirements.

Corrective Action Plan

2020-003 Improve Controls Over Procurement Views of Responsible Official Management agrees with the findings . Planned Corrective Action The District will ensure that three (3) written quotes will be secured for any purchase exceeding $10,000 as per the Uniform Guidance required under Federal Programs. Planned Implementation Date of Corrective Action: 7/1/2021 Person Responsible for Corrective Action: Finance Director, Food Service Coordinator

About Procurement and Suspension and Debarment →

FY 2019-06-30

$1,521,589 federal awards expended

FAC accepted this audit on June 2, 2020 — management decision was due December 2, 2020.

2019-002
Activities Allowed or Unallowed / Cost Allowability / Cash Management / Period of Performance / Procurement & Suspension/Debarment
MODIFIED OPINIONSIGNIFICANT DEFICIENCYREPEAT OF 2018-012QUESTIONED COSTS

2019-002 Document Policies and Procedures Over Federal AwardsFederal Program(s) InformationFederal Agency: U.S. Department of Agriculture ? Food and Nutrition ServiceCluster: Child Nutrition ClusterFederal Program Name: School Breakfast Program and National School Lunch ProgramCFDA Number(s): 10.553/10.555Pass-through Entity: Massachusetts Department of Elementary and Secondary EducationAward Year: 2019Federal Agency: U.S. Department of Education ? Office of Special Education and Rehabilitative ServicesCluster: Special Education ClusterFederal Program Name: Special Education Grants to States and Special Education Preschool GrantsCFDA Number(s): 84.027/84.173Pass-through Entity: Massachusetts Department of Elementary and Secondary EducationAward Year: 2019Compliance RequirementAllowable Costs/Cost PrinciplesCash ManagementPeriod of PerformanceProcurement and Suspension and DebarmentType of FindingComplianceInternal Control Over Compliance - Significant DeficiencyCriteria or Specific RequirementOMB?s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) established significant new requirements related to Federal awards. The new requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following:?Determination of allowable costs?Employee travel?Cash management?Procurement?Subrecipient monitoring and managementCondition and ContextThe District has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance.CauseWeaknesses in the formal documentation of internal controls.Effect or Potential EffectThe District is not in compliance with Uniform Guidance requirements for written policies and procedures.Identification as Repeat FindingAs identified in Section IV, the Schedule of Prior Year Findings, this is a repeat of finding 2018-012.RecommendationThe District should ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with the Uniform Guidance.Views of Responsible OfficialManagement agrees with the findings.Planned Corrective ActionThe District will formalize written policies and procedures as compiled and adopted to ensure compliance with the Uniform Guidance for Federal Awards.

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2019-002 Document Policies and Procedures Over Federal AwardsFederal Program(s) InformationFederal Agency: U.S. Department of Agriculture ? Food and Nutrition ServiceCluster: Child Nutrition ClusterFederal Program Name: School Breakfast Program and National School Lunch ProgramCFDA Number(s): 10.553/10.555Pass-through Entity: Massachusetts Department of Elementary and Secondary EducationAward Year: 2019Federal Agency: U.S. Department of Education ? Office of Special Education and Rehabilitative ServicesCluster: Special Education ClusterFederal Program Name: Special Education Grants to States and Special Education Preschool GrantsCFDA Number(s): 84.027/84.173Pass-through Entity: Massachusetts Department of Elementary and Secondary EducationAward Year: 2019Compliance RequirementAllowable Costs/Cost PrinciplesCash ManagementPeriod of PerformanceProcurement and Suspension and DebarmentType of FindingComplianceInternal Control Over Compliance - Significant DeficiencyCriteria or Specific RequirementOMB?s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) established significant new requirements related to Federal awards. The new requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following:?Determination of allowable costs?Employee travel?Cash management?Procurement?Subrecipient monitoring and managementCondition and ContextThe District has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance.CauseWeaknesses in the formal documentation of internal controls.Effect or Potential EffectThe District is not in compliance with Uniform Guidance requirements for written policies and procedures.Identification as Repeat FindingAs identified in Section IV, the Schedule of Prior Year Findings, this is a repeat of finding 2018-012.RecommendationThe District should ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with the Uniform Guidance.Views of Responsible OfficialManagement agrees with the findings.Planned Corrective ActionThe District will formalize written policies and procedures as compiled and adopted to ensure compliance with the Uniform Guidance for Federal Awards.

Corrective Action Plan

2019-002 Document Policies and Procedures Over Federal AwardsViews of Responsible OfficialManagement agrees with the findings.Planned Corrective ActionThe District will formalize written policies and procedures are compiled and adopted to ensure compliance with the Uniform Guidance for Federal AwardsPlanned Implementation Date of Corrective Action: 7/1//2020Person Responsible for Corrective Action: Finance Director, SpEd Director, Food Service Coordinator

Prior Finding References

2018-012

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles, Cash Management, Period of Performance, Procurement and Suspension and Debarment →
2019-003
Period of Performance
MODIFIED OPINIONSIGNIFICANT DEFICIENCYQUESTIONED COSTS

2019-003 Comply with Period of Performance RequirementsFederal Program(s) InformationFederal Agency: U.S. Department of Education ? Office of Special Education and Rehabilitative ServicesCluster: Special Education ClusterFederal Program Name: Special Education Grants to States and Special Education Preschool GrantsCFDA Number(s): 84.027/84.173Pass-through Entity: Massachusetts Department of Elementary and Secondary EducationAward Year: 2019Compliance RequirementPeriod of PerformanceType of FindingComplianceInternal Control Over Compliance - Significant DeficiencyCriteria or Specific RequirementFederal grants are subject to period of performance requirements. Specifically, funds are not to be expended until the grant is approved.Condition or ContextWe noted that expenditures were charged to the grant prior to the award notification dated October 22, 2018. Our audit found that grant activity continued beyond these dates.CauseWeaknesses in the formal documentation of internal controls.Effect and Questioned CostsThe District was not in compliance with the period of performance requirements. Due to the lack of compliance, questioned costs in the amount of $45,760 are reported.RecommendationWe recommend that the District comply with period of performance requirements in the future.Views of Responsible OfficialManagement agrees with the findings.Planned Corrective ActionThe District will ensure that no expenditures are charged to a grant prior to receiving the award notification.

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2019-003 Comply with Period of Performance RequirementsFederal Program(s) InformationFederal Agency: U.S. Department of Education ? Office of Special Education and Rehabilitative ServicesCluster: Special Education ClusterFederal Program Name: Special Education Grants to States and Special Education Preschool GrantsCFDA Number(s): 84.027/84.173Pass-through Entity: Massachusetts Department of Elementary and Secondary EducationAward Year: 2019Compliance RequirementPeriod of PerformanceType of FindingComplianceInternal Control Over Compliance - Significant DeficiencyCriteria or Specific RequirementFederal grants are subject to period of performance requirements. Specifically, funds are not to be expended until the grant is approved.Condition or ContextWe noted that expenditures were charged to the grant prior to the award notification dated October 22, 2018. Our audit found that grant activity continued beyond these dates.CauseWeaknesses in the formal documentation of internal controls.Effect and Questioned CostsThe District was not in compliance with the period of performance requirements. Due to the lack of compliance, questioned costs in the amount of $45,760 are reported.RecommendationWe recommend that the District comply with period of performance requirements in the future.Views of Responsible OfficialManagement agrees with the findings.Planned Corrective ActionThe District will ensure that no expenditures are charged to a grant prior to receiving the award notification.

Corrective Action Plan

2019-003 Comply with Period of Performance RequirementsViews of Responsible OfficialManagement agrees with the findings.Planned Corrective ActionThe District will ensure that no expenditures are charged to a Grant prior to receiving the award notification.Planned Implementation Date of Corrective Action: 7/1/2020Person Responsible for Corrective Action: Finance Director, SpEd Director

About Period of Performance →
2019-004
Program Income
SIGNIFICANT DEFICIENCYREPEAT OF 2018-009

2019-004 Improve Controls Over Program IncomeFederal Program(s) InformationFederal Agency: U.S. Department of Agriculture ? Food and Nutrition ServiceCluster: Child Nutrition ClusterFederal Program Name: School Breakfast and National School Lunch ProgramCFDA Number(s): 10.553/10.555Pass-through Entity: Massachusetts Department of Elementary and Secondary EducationAward Year: 2019Compliance RequirementProgram IncomeType of FindingInternal Control Over Compliance - Significant DeficiencyCriteria or Specific RequirementThe requirements that apply to program income are contained in 2 CFR section 200.80 (definition of ?program income?), 2 CFR section 200.307 (program income), program legislation, Federal awarding agency regulations, and the terms and conditions of the Federal award. Program income is gross income earned by a non-Federal entity that is directly generated by a supported activity or earned as a result of the Federal award during the period of performance (unless there is a requirement for disposition of program income after the end of the period of performance as provided in 2 CFR Section 200.307(f)). Program income may be used in any of three methods consistent with 2 CFR Section 200.307(e).Management of the District is responsible for establishing and maintaining effective internal control over compliance with Federal requirements that have a direct and material effect on a Federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a Federal program on a timely basis.Condition and ContextAlthough the District has implemented certain policies and procedures over program income, there was no documented evidence that individuals not involved in the receipts process verified that amounts collected were properly deposited to the District?s bank account. Additionally, reports do not provide a break out between cash and checks.CauseWeaknesses in the design and operation of controls.Effect or Potential EffectDue to the weaknesses in internal controls noted above, there is a risk that program income could be misappropriated and not detected and corrected on a timely basis. No questioned costs were reported because it was not quantifiable.Identification as a Repeat FindingAs identified in Section IV, the Schedule of Prior Year Findings, this is a repeat of finding 2018-009.RecommendationThe District should improve internal controls over program income by requiring an individual that is not involved in the receipts process to verify that program income collected was properly deposited to the District?s bank account and recorded in the general ledger. This review should be documented, preferably with dual signatures of the preparer and the reviewer. Written policies and procedures should also be implemented to document this requirement and process as well as requiring a break out of cash and checks.Views of Responsible OfficialManagement agrees with the findings.Planned Corrective ActionThe District will require that an individual outside of the receipts process will verify that program income collected is properly deposited to the District?s bank account and recorded in the general ledger. The District will compile and adopt written policies and procedures regarding program income and cash management.

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2019-004 Improve Controls Over Program IncomeFederal Program(s) InformationFederal Agency: U.S. Department of Agriculture ? Food and Nutrition ServiceCluster: Child Nutrition ClusterFederal Program Name: School Breakfast and National School Lunch ProgramCFDA Number(s): 10.553/10.555Pass-through Entity: Massachusetts Department of Elementary and Secondary EducationAward Year: 2019Compliance RequirementProgram IncomeType of FindingInternal Control Over Compliance - Significant DeficiencyCriteria or Specific RequirementThe requirements that apply to program income are contained in 2 CFR section 200.80 (definition of ?program income?), 2 CFR section 200.307 (program income), program legislation, Federal awarding agency regulations, and the terms and conditions of the Federal award. Program income is gross income earned by a non-Federal entity that is directly generated by a supported activity or earned as a result of the Federal award during the period of performance (unless there is a requirement for disposition of program income after the end of the period of performance as provided in 2 CFR Section 200.307(f)). Program income may be used in any of three methods consistent with 2 CFR Section 200.307(e).Management of the District is responsible for establishing and maintaining effective internal control over compliance with Federal requirements that have a direct and material effect on a Federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a Federal program on a timely basis.Condition and ContextAlthough the District has implemented certain policies and procedures over program income, there was no documented evidence that individuals not involved in the receipts process verified that amounts collected were properly deposited to the District?s bank account. Additionally, reports do not provide a break out between cash and checks.CauseWeaknesses in the design and operation of controls.Effect or Potential EffectDue to the weaknesses in internal controls noted above, there is a risk that program income could be misappropriated and not detected and corrected on a timely basis. No questioned costs were reported because it was not quantifiable.Identification as a Repeat FindingAs identified in Section IV, the Schedule of Prior Year Findings, this is a repeat of finding 2018-009.RecommendationThe District should improve internal controls over program income by requiring an individual that is not involved in the receipts process to verify that program income collected was properly deposited to the District?s bank account and recorded in the general ledger. This review should be documented, preferably with dual signatures of the preparer and the reviewer. Written policies and procedures should also be implemented to document this requirement and process as well as requiring a break out of cash and checks.Views of Responsible OfficialManagement agrees with the findings.Planned Corrective ActionThe District will require that an individual outside of the receipts process will verify that program income collected is properly deposited to the District?s bank account and recorded in the general ledger. The District will compile and adopt written policies and procedures regarding program income and cash management.

Corrective Action Plan

2019-004 Improve Controls over Program Income Views of Responsible OfficialManagement agrees with the findings.Planned Corrective ActionThe District will require that an individual outside of the receipts process will verify that program income collected is properly deposited to the District's bank account and recorded in the general ledger. The District will compile and adopt written policies and procedures regarding program income and cash management.Planned Implementation Date of Corrective Action: 7/1/2020Person Responsible for Corrective Action: Finance Director, Food Service Coordinator

Prior Finding References

2018-009

About Program Income →

FY 2018-06-30

$1,382,778 federal awards expended

FAC accepted this audit on September 12, 2019 — management decision was due March 12, 2020.

2018-004
Cost Allowability
MODIFIED OPINIONSIGNIFICANT DEFICIENCYREPEAT OF 2017-004QUESTIONED COSTS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

Prior Finding References

2017-004

About Allowable Costs / Cost Principles →
2018-005
Cash Management
MODIFIED OPINIONSIGNIFICANT DEFICIENCYREPEAT OF 2017-005

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-005

About Cash Management →
2018-006
Procurement & Suspension/Debarment
MODIFIED OPINIONSIGNIFICANT DEFICIENCYREPEAT OF 2017-006

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-006

About Procurement and Suspension and Debarment →
2018-007
Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2017-007

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-007

About Special Tests and Provisions →
2018-008
Special Tests & Provisions
MODIFIED OPINIONSIGNIFICANT DEFICIENCY

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

About Special Tests and Provisions →
2018-009
Program Income
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

About Program Income →
2018-010
Reporting
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-011
Eligibility
MODIFIED OPINIONSIGNIFICANT DEFICIENCY

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

About Eligibility →
2018-012
Other
REPEAT OF 2017-008OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

Prior Finding References

2017-008

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FY 2017-06-30

$1,358,385 federal awards expended

FAC accepted this audit on August 12, 2018 — management decision was due February 12, 2019.

2017-004
Cost Allowability
MODIFIED OPINIONSIGNIFICANT DEFICIENCYREPEAT OF 2016-004QUESTIONED COSTS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

Prior Finding References

2016-004

About Allowable Costs / Cost Principles →
2017-005
Cash Management
MODIFIED OPINIONSIGNIFICANT DEFICIENCYREPEAT OF 2016-005

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-005

About Cash Management →
2017-006
Procurement & Suspension/Debarment
MODIFIED OPINIONSIGNIFICANT DEFICIENCYREPEAT OF 2016-007

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

Prior Finding References

2016-007

About Procurement and Suspension and Debarment →
2017-007
Special Tests & Provisions
MODIFIED OPINIONSIGNIFICANT DEFICIENCYREPEAT OF 2016-008

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-008

About Special Tests and Provisions →
2017-008
Other
OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

About Other →

FY 2016-06-30

$1,266,306 federal awards expended

FAC accepted this audit on May 31, 2017 — management decision was due December 1, 2017.

2016-004
Cost Allowability / Cash Management
MODIFIED OPINIONSIGNIFICANT DEFICIENCYREPEAT OF 2015-004QUESTIONED COSTS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

Prior Finding References

2015-004

About Allowable Costs / Cost Principles, Cash Management →
2016-005
Cost Allowability / Cash Management
MODIFIED OPINIONSIGNIFICANT DEFICIENCYREPEAT OF 2015-004QUESTIONED COSTS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2015-004

About Allowable Costs / Cost Principles, Cash Management →
2016-006
Eligibility
MODIFIED OPINIONSIGNIFICANT DEFICIENCYREPEAT OF 2015-005

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2015-005

About Eligibility →
2016-007
Procurement & Suspension/Debarment
MODIFIED OPINIONSIGNIFICANT DEFICIENCY

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Procurement and Suspension and Debarment →
2016-008
Special Tests & Provisions
MODIFIED OPINIONSIGNIFICANT DEFICIENCYREPEAT OF 2015-008

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2015-008

About Special Tests and Provisions →

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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