Audit of the Executive Office for Administration and Finance (May 29, 2024)
May 29, 2024 · Executive Office for Administration and Finance · Read the full official report on mass.gov ↗
source
“A&F’s FFO could not ensure that all subrecipient expenditures and supporting documentation met the CARES Act requirements regarding how the subrecipient spent funds it received through the CvRF.”
Read the plain-English breakdown
This is a state performance audit of the Massachusetts Executive Office for Administration and Finance, covering July 1, 2020 through April 30, 2022.
“In accordance with Section 12 of Chapter 11 of the Massachusetts General Laws, the Office of the State Auditor has conducted a performance audit of the Executive Office for Administration and Finance (A&F) for the period July 1, 2020 through April 30, 2022.”
The auditor checked whether A&F properly reviewed COVID relief money sent to municipalities and whether it kept the required list of vendors that should not get state contracts.
“The purpose of our audit was to determine the following:”
If spending records are incomplete, Massachusetts could be at risk of having federal COVID relief money taken back.
“This could then lead the Federal government to recoup funds received through the CvRF.”
This involves public money that went to cities and towns for pandemic-related costs, so residents have a stake in whether it was tracked and checked properly.
“The Commonwealth used part of the CvRF to make approximately $502 million available to municipalities through the CvRF Municipal Program (CvRF-MP).”
The audit found three main problems: incomplete documentation for one sampled expense, missing formal follow-up meetings with municipalities that had review findings, and no consolidated statewide debarred vendor list with all required details.
“Below is a summary of our findings and recommendations, with links to each page listed.”
The auditor recommended better documentation collection, meetings and written guidelines for municipalities with findings, and a complete consolidated barred-vendor list; the auditor also said the office will follow up.
“As part of our post-audit review process, we will be following up on this issue in the near future.”
The report matters beyond one office because weak vendor tracking could let agencies accidentally give contracts to businesses that are supposed to be barred.
“Because state agencies must check multiple debarred vendor lists before awarding a contract, if A&F does not maintain a consolidated debarred vendor list that contains all the required information, then there is a higher-than-acceptable risk that state agencies could mistakenly award state contracts to debarred vendors.”
The CARES Act was the federal pandemic relief law, and the Coronavirus Relief Fund was the pot of federal money used here to cover COVID-19 expenses.
“According to A&F’s website, the Coronavirus Aid, Relief, and Economic Security (CARES) Act, enacted by Congress on March 27, 2020, provided Massachusetts with approximately $2.7 billion from the Coronavirus Relief Fund (CvRF) to cover expenses related to the COVID-19 pandemic.”
1 figure(s) pending source verification - not shown
What the Auditor checked
- Partially Did A&F’s Federal Funds Office (FFO) establish a desk review process of the Coronavirus Relief Fund (CvRF) Municipal Program (CvRF-MP) to ensure that all subrecipient expenditures and supporting documentation met the Coronavirus Aid, Relief, and Economic Security (CARES) Act requirements regarding how subrecipients spent funds they received through the CvRF, in accordance with the Office of the Comptroller of the Commonwealth’s “Sub-Recipient Monitoring Policy”?
- Complied Did FFO sample approximately one-third of eligible municipalities across four rounds of desk reviews, in accordance with the “Desk Review Scope and Methodology” section of FFO’s “Compliance with COVID-19 Federal Funding” policy?
- Did not comply If FFO identified desk reviews with findings related to CvRF compliance, did FFO (1) initiate a formal remediation process to ensure that municipalities with these findings employ enhanced policies and procedures moving forward and (2) recommend compliance best practices to the municipalities in question, in accordance with the “Eligibility Review” section of FFO’s “Compliance with COVID-19 Federal Funding” policy?
- Did not comply Did A&F maintain a debarred vendor list that accurately reflects vendors that should not be awarded state contracts, in accordance with Section 29F(b) of Chapter 29 of the General Laws?
What the Auditor found
Why it matters: FFO could not ensure CvRF Municipal Program expenditures complied with CARES Act requirements, creating risk that the federal government could recoup funds.
Standard: The Office of the Comptroller of the Commonwealth’s “Sub-Recipient Monitoring Policy” and Section 601(d) of Title VI of the Social Security Act. ( Office of the Comptroller of the Commonwealth’s “Sub-Recipient Monitoring Policy”; Section 601(d) of Title VI of the Social Security Act )
1 recommendation
- FFO should collect all necessary supporting documentation from the municipalities it sampled during its desk review process.
Agency response & Auditor reply
Agency: "However, if a similar program is implemented in the future, FFO will be sure to establish policies that ensure that all necessary supporting documentation for each review is collected."
Auditor: "However, FFO could not provide documentation confirming that one of the expenditures was incurred during the period March 1, 2020 through December 31, 2021, as required."
Why it matters: Municipalities may not understand or implement FFO’s recommendations, including enhanced policies and procedures.
Standard: FFO’s “Compliance with COVID-19 Federal Funding” policy and FFO’s “Desk Review Process for Coronavirus Relief Fund” document. ( “Eligibility Review” section of FFO’s “Compliance with COVID-19 Federal Funding” policy; Section II(b) of FFO’s “Desk Review Process for Coronavirus Relief Fund” document; Section 200.332(d)(2) of Title 2 of the Code of Federal Regulations )
2 recommendations
- FFO should conduct meetings with every municipality that has desk review findings.
- FFO should, as part of its formal remediation process, develop and document guidelines for conducting meetings with any municipality that has desk review findings.
Agency response & Auditor reply
Agency: "While FFO did not have a documented formal remediation process, there was follow up conducted following findings in desk audits and there was an internal process in which FFO engaged in an interactive process with municipalities when a finding arose in the desk audit."
Auditor: "As such, FFO did not provide any evidence that it conducted any meetings with municipalities that had findings resulting from desk reviews."
Why it matters: State agencies could mistakenly award state contracts to debarred vendors.
Standard: Section 29F(b) of Chapter 29 of the General Laws. ( Section 29F(b) of Chapter 29 of the General Laws )
2 recommendations
- A&F should maintain a consolidated debarred vendor list.
- A&F should develop policies, procedures, and internal controls to ensure that it maintains a consolidated debarred vendor list that contains all the required information.
Agency response & Auditor reply
Agency: "Over the next year, we will consider and develop policies, procedures and internal controls to best meet that mandate beyond current practice."
Auditor: "A&F should take measures even sooner to address our concerns on this matter, as every day that passes creates additional opportunities for state agencies and local governments to contract with debarred vendors."
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