Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the Institution’s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Institutions were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required.
Condition: The College did not report the correct amount for total quarterly expenditures for one of the quarterly reports tested.
Questioned costs: None
Context: One of two HEERF quarterly reports tested included data that did not agree to supporting documentation.
Cause: The control system put in place for review of these reports is not operating effectively.
Effect: The College reported an incorrect amount for total quarterly expenditures.
Repeat Finding: No
Recommendation: CLA recommends SOCC reviews its review process for these reports and implements a reconciling process between the report and the supporting documentation to make sure these things match before being signed off as reviewed. CLA also recommends a second reviewer of these reports.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.320 and 200.318(i); a non-federal entity must have procedures that document the rationale for the method of procurement, selection of the contract type, basis for contractor selection, and the basis for the contract price. In addition, Uniform Grant Guidance (2 CFR 20.303) requires nonfederal entities receiving Federal awards establish and maintain controls designed to reasonable ensure compliance with Federal laws, regulations, and program compliance requirements.
Condition: During our testing of the procurement process, we noted that college was not in compliance with the federal procurement regulations.
Questioned costs: None
Context: In our sample of three procurement transactions, one transaction did not have the required procurement documentation.
Cause: The College had an existing contract with a vendor and thought the transaction was covered under the original procurement.
Effect: The College is not in compliance with procurement requirements to properly document the procurement rationale for the method of procurement.
Repeat Finding: No
Recommendation: We recommend the College revise their processes to establish procedures that will ensure procurement policies are properly followed and documented for all general disbursements paid for by federal funds.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Under section 2003(5) of the American Rescue Plan Act of 2021 (ARP) (Pub. L. 117-2) (supplemental award or grant) by the U.S. Department of Education, Recipient must use a portion of their institutional funds received under this supplemental award to (a) to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the Higher Education Act of 1965, as amended (HEA) (20 USC § 1087tt). In addition, Uniform Grant Guidance (2 CFR 20.303) requires nonfederal entities receiving Federal awards establish and maintain controls designed to reasonable ensure compliance with Federal laws, regulations, and program compliance requirements.
Condition: During our testing, we noted there was no amount allocated to the earmarking requirement.
Questioned costs: None
Context: During our testing, we noted the College was not in compliance with the annual reporting requirements because the College did not report ARP funds expended to conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student or other circumstances, described in section 479A of the HEA.
Cause: The policies and procedures of the College did not ensure that annual reporting requirements to report amounts spent for earmarking requirements were accurately met.
Effect: The College inaccurately reported the amount spent under earmarking requirements. Non-compliance with federal regulations could lead to funds being required to be returned or refunded in order to meet the reporting requirement.
Repeat Finding: No
Recommendation: We recommend the College revise their report to properly show the amount spent under earmarking requirements. In addition, we recommend the College put procedures in place to review earmarking requirements and properly track them for reporting purposes.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the Institution’s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Institutions were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required.
Condition: The College did not report the correct amount for total quarterly expenditures for one of the quarterly reports tested.
Questioned costs: None
Context: One of two HEERF quarterly reports tested included data that did not agree to supporting documentation.
Cause: The control system put in place for review of these reports is not operating effectively.
Effect: The College reported an incorrect amount for total quarterly expenditures.
Repeat Finding: No
Recommendation: CLA recommends SOCC reviews its review process for these reports and implements a reconciling process between the report and the supporting documentation to make sure these things match before being signed off as reviewed. CLA also recommends a second reviewer of these reports.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the Institution’s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Institutions were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required.
Condition: The College did not report the correct amount for total quarterly expenditures for one of the quarterly reports tested.
Questioned costs: None
Context: One of two HEERF quarterly reports tested included data that did not agree to supporting documentation.
Cause: The control system put in place for review of these reports is not operating effectively.
Effect: The College reported an incorrect amount for total quarterly expenditures.
Repeat Finding: No
Recommendation: CLA recommends SOCC reviews its review process for these reports and implements a reconciling process between the report and the supporting documentation to make sure these things match before being signed off as reviewed. CLA also recommends a second reviewer of these reports.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.320 and 200.318(i); a non-federal entity must have procedures that document the rationale for the method of procurement, selection of the contract type, basis for contractor selection, and the basis for the contract price. In addition, Uniform Grant Guidance (2 CFR 20.303) requires nonfederal entities receiving Federal awards establish and maintain controls designed to reasonable ensure compliance with Federal laws, regulations, and program compliance requirements.
Condition: During our testing of the procurement process, we noted that college was not in compliance with the federal procurement regulations.
Questioned costs: None
Context: In our sample of three procurement transactions, one transaction did not have the required procurement documentation.
Cause: The College had an existing contract with a vendor and thought the transaction was covered under the original procurement.
Effect: The College is not in compliance with procurement requirements to properly document the procurement rationale for the method of procurement.
Repeat Finding: No
Recommendation: We recommend the College revise their processes to establish procedures that will ensure procurement policies are properly followed and documented for all general disbursements paid for by federal funds.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Under section 2003(5) of the American Rescue Plan Act of 2021 (ARP) (Pub. L. 117-2) (supplemental award or grant) by the U.S. Department of Education, Recipient must use a portion of their institutional funds received under this supplemental award to (a) to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the Higher Education Act of 1965, as amended (HEA) (20 USC § 1087tt). In addition, Uniform Grant Guidance (2 CFR 20.303) requires nonfederal entities receiving Federal awards establish and maintain controls designed to reasonable ensure compliance with Federal laws, regulations, and program compliance requirements.
Condition: During our testing, we noted there was no amount allocated to the earmarking requirement.
Questioned costs: None
Context: During our testing, we noted the College was not in compliance with the annual reporting requirements because the College did not report ARP funds expended to conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student or other circumstances, described in section 479A of the HEA.
Cause: The policies and procedures of the College did not ensure that annual reporting requirements to report amounts spent for earmarking requirements were accurately met.
Effect: The College inaccurately reported the amount spent under earmarking requirements. Non-compliance with federal regulations could lead to funds being required to be returned or refunded in order to meet the reporting requirement.
Repeat Finding: No
Recommendation: We recommend the College revise their report to properly show the amount spent under earmarking requirements. In addition, we recommend the College put procedures in place to review earmarking requirements and properly track them for reporting purposes.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the Institution’s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Institutions were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required.
Condition: The College did not report the correct amount for total quarterly expenditures for one of the quarterly reports tested.
Questioned costs: None
Context: One of two HEERF quarterly reports tested included data that did not agree to supporting documentation.
Cause: The control system put in place for review of these reports is not operating effectively.
Effect: The College reported an incorrect amount for total quarterly expenditures.
Repeat Finding: No
Recommendation: CLA recommends SOCC reviews its review process for these reports and implements a reconciling process between the report and the supporting documentation to make sure these things match before being signed off as reviewed. CLA also recommends a second reviewer of these reports.
Views of responsible officials: There is no disagreement with the audit finding.