Finding No. 2022-001 Federal Agency: U.S. Department of Education ALN and Title: 84.002 ? Adult Education ? Basic Grants to States Federal Award Number: V002A200061 Compliance Requirement: Activities Allowed or Unallowed Questioned Cost: $0 Criteria: In accordance with applicable activities allowed or unallowed requirements and the Guam State Plan for program years 2020-2023, the state eligible agency shall provide adult education and literacy activities, including Career and Technical Education (CTE) electives from the same career program of study area as part of the student?s approved plan of study. Condition: For 3 (or 11%) of 28 samples, aggregating $80,231 of $552,945 in total unaudited program costs, the program was charged tuition and fees for students who attended the College?s CTE Programs. In an email dated April 13, 2023, the grantor stated, ?In summary, it is not allowable for local programs to use Title II funds to pay for stand-alone CTE courses.? No evidence was provided by the College to substantiate that the CTE courses are not stand-alone courses. Details of the total tuition and fees related to the College?s CTE programs during the year, including the 3 samples tested, are summarized below. See Schedule of Findings and Questioned Costs for chart/table. No questioned cost is presented for this finding because the College subsequently returned $59,726 to the grantor on June 8, 2023 with G5 refund identification no. R2306074881. Cause: The College?s Adult Education Program - SEA personnel was of the understanding that CTE courses were allowable based on 29 USC 3274 Sec. 205, which states, ?Nothing in this title shall be construed to prohibit or discourage the use of funds provided under this title for adult education and literacy activities that help eligible individuals transition to postsecondary education and training or employment, or for concurrent enrollment activities.? Effect: The College is not in compliance with applicable activities allowed or unallowed requirements. Recommendation: Prior to charging activities to the program, the College should consider seeking clarification and approval from the grantor agency to verify compliance with the grant. Views of responsible officials: See Corrective Action Plan.
Federal Agency: U.S. Department of Education ALN and Title: 84.002 ? Adult Education ? Basic Grants to States Federal Award Number: V002A190061 Compliance Requirement: Period of Performance Questioned Cost: $0 Criteria: In accordance with applicable period of performance requirements, a non-Federal entity may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Grant award V002A190061 specifies that the period of performance is from July 1, 2019 to September 30, 2020 with additional costs that can be obligated up to September 30, 2021 and liquidated through January 28, 2022. Condition: For 5 (or 18%) of 28 samples, aggregating $80,231 of $552,945 in total unaudited program costs, the cost was incurred subsequent to September 30, 2021 and was charged to award number V002A190061 after the award?s period of performance ended on September 30, 2021. See Schedule of Findings and Questioned Costs for chart/table. No questioned cost is presented for this finding because the costs could be charged to award number V002A200061 with a period of performance from July 1, 2020 to September 30, 2021 with additional costs that can be obligated up to September 30, 2022 and liquidated through January 28, 2023. This grant award has an available balance of $120,138 as of September 30, 2022. The College provided journal voucher number J00019662, transferring the cost to the available award. Cause: The College did not enforce monitoring controls over compliance with applicable period of performance requirements. Program personnel was of the understanding that costs may be incurred through the award?s liquidation end date. Effect: The College is not in compliance with applicable period of performance requirements of the grant. Recommendation: The College?s management should enforce monitoring controls over compliance with applicable period of performance requirements. Responsible personnel should seek clarification from the grantor as to whether costs may be incurred through the award?s liquidation end date. Views of responsible officials: See Corrective Action Plan.
Finding No. 2022-001 Federal Agency: U.S. Department of Education ALN and Title: 84.002 ? Adult Education ? Basic Grants to States Federal Award Number: V002A200061 Compliance Requirement: Activities Allowed or Unallowed Questioned Cost: $0 Criteria: In accordance with applicable activities allowed or unallowed requirements and the Guam State Plan for program years 2020-2023, the state eligible agency shall provide adult education and literacy activities, including Career and Technical Education (CTE) electives from the same career program of study area as part of the student?s approved plan of study. Condition: For 3 (or 11%) of 28 samples, aggregating $80,231 of $552,945 in total unaudited program costs, the program was charged tuition and fees for students who attended the College?s CTE Programs. In an email dated April 13, 2023, the grantor stated, ?In summary, it is not allowable for local programs to use Title II funds to pay for stand-alone CTE courses.? No evidence was provided by the College to substantiate that the CTE courses are not stand-alone courses. Details of the total tuition and fees related to the College?s CTE programs during the year, including the 3 samples tested, are summarized below. See Schedule of Findings and Questioned Costs for chart/table. No questioned cost is presented for this finding because the College subsequently returned $59,726 to the grantor on June 8, 2023 with G5 refund identification no. R2306074881. Cause: The College?s Adult Education Program - SEA personnel was of the understanding that CTE courses were allowable based on 29 USC 3274 Sec. 205, which states, ?Nothing in this title shall be construed to prohibit or discourage the use of funds provided under this title for adult education and literacy activities that help eligible individuals transition to postsecondary education and training or employment, or for concurrent enrollment activities.? Effect: The College is not in compliance with applicable activities allowed or unallowed requirements. Recommendation: Prior to charging activities to the program, the College should consider seeking clarification and approval from the grantor agency to verify compliance with the grant. Views of responsible officials: See Corrective Action Plan.
Federal Agency: U.S. Department of Education ALN and Title: 84.002 ? Adult Education ? Basic Grants to States Federal Award Number: V002A190061 Compliance Requirement: Period of Performance Questioned Cost: $0 Criteria: In accordance with applicable period of performance requirements, a non-Federal entity may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance. Grant award V002A190061 specifies that the period of performance is from July 1, 2019 to September 30, 2020 with additional costs that can be obligated up to September 30, 2021 and liquidated through January 28, 2022. Condition: For 5 (or 18%) of 28 samples, aggregating $80,231 of $552,945 in total unaudited program costs, the cost was incurred subsequent to September 30, 2021 and was charged to award number V002A190061 after the award?s period of performance ended on September 30, 2021. See Schedule of Findings and Questioned Costs for chart/table. No questioned cost is presented for this finding because the costs could be charged to award number V002A200061 with a period of performance from July 1, 2020 to September 30, 2021 with additional costs that can be obligated up to September 30, 2022 and liquidated through January 28, 2023. This grant award has an available balance of $120,138 as of September 30, 2022. The College provided journal voucher number J00019662, transferring the cost to the available award. Cause: The College did not enforce monitoring controls over compliance with applicable period of performance requirements. Program personnel was of the understanding that costs may be incurred through the award?s liquidation end date. Effect: The College is not in compliance with applicable period of performance requirements of the grant. Recommendation: The College?s management should enforce monitoring controls over compliance with applicable period of performance requirements. Responsible personnel should seek clarification from the grantor as to whether costs may be incurred through the award?s liquidation end date. Views of responsible officials: See Corrective Action Plan.