(#2022-001) Cash Management ? CFDA No. 84.425E ? COVID-19 HEERF-Student Aid Portion Year Ended ? June 30, 2022 Direct Program Federal Agency ? U.S. Department of Education Criteria ?For CRRSAA HEERF II and ARP HEERF III, the Certification and Agreements and /or Supplemental Agreements require that Student Aid Portion (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from United States Department of Education?s G5 grants system. Condition ?Funds drawn down by BOCES during its fiscal year ended June 30, 2022, for emergency financial aid grants to students were not disbursed within 15 calendar days. Cause ?Draw downs were prepared and submitted to G5 when the amounts needed were determined by the Continuing Ed department, but disbursements were not processed until after the maximum number of days allowed under the grant. Effect ? BOCES did not disburse funds within the time frame required by the supplemental agreements for CRRSAA HEERF II funds. Questioned Costs ? There were no questioned costs for this finding. Context ? This finding was identified during our testing of cash draw downs and the related disbursements. We examined a sample drawdowns related to HEERF grants including 100% of those related to the Student Aid Portion. The remaining draws related to the FIPSE portion of grants were made on strictly a reimbursement basis, and as such the findings noted were consider isolated to the Student Aid Portion and no further estimating for the prevalence of this error was deemed necessary. Recommendation ? We recommend that draw down requests be provided to the Treasurer for submission on the G5 system when it is reasonably certain that the disbursements of those funds will occur within the required time frames established by the grant agreements. In addition, the Treasurer should verify with the department providing the draw down that disbursement will occur within the required time frame prior to submission to the granting agency. BOCES? Response ? BOCES will ensure that conditions for draw down are met by referencing grant compliance materials and verifying timelines with the department prior to any action.
(#2022-003) Allowable Costs? CFDA No. 84.425N ? COVID-19 HEERF-FIPSE Formula Grant Year Ended ? June 30, 2022 Direct Program Federal Agency ? U.S. Department of Education Criteria ?Institutions must follow the documentation requirements under 2 CFR ? 200.334 to retain financial records, supporting documents, statistical records, and all other institutional records pertinent to lost revenue and the administration of the HEERF grant programs generally for a period of three years from the date of submission of the final expenditure report. Condition ? Documentation to support the estimates for lost revenue was not provided to management timely for review and approval. Cause ?Adequate documentation was not maintained to support the lost revenue estimate. Effect ?Documentation supporting lost revenue estimates was not properly maintained prior to the submission of drawdowns of grant funds. Questioned Costs ? There were no questioned costs noted related to this finding. Context ?This finding was identified during our testing of lost revenues reported as allowable costs. BOCES was able to provide their calculation and method for estimating lost revenue for the program, however, management was not able to provide support for the enrollment numbers used in the estimate. Subsequent to our original request, the Continuing Education Department was able to provide enrollment documentation which supported the estimates selected for testing. Recommendation ? Documentation used in developing the estimates should be maintained in accordance with grant terms, and provided to management for their review and approval prior to the submission of drawdowns. BOCES? Response ? BOCES will ensure that clear and appropriate supporting documentation is in line with grant terms and is provided by the department and reviewed with the Finance Office prior to any submission for grant disbursement.
(#2022-002) Reporting ? CFDA No. 84.425E ? COVID-19 HEERF-Student Aid Portion CFDA No. 84.425N ? COVID-19 HEERF-FIPSE Formula Grant Year Ended ? June 30, 2022 Direct Program Federal Agency ? U.S. Department of Education Criteria ?the CARES Act 18004(e) and CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. Institutions must complete the Quarterly Budget and Expenditure Reporting form (OMB Control Number 1840-0849 V.1.1) for its Institutional Portion and any subprograms, including FIPSE. In addition, quarterly reporting of certain information related to the Student Aid Portion award is required. The Quarterly Reporting form and Student Aid Portion information must be conspicuously posted in the institution?s primary website and on the same page and are due 10 days after the end of each reporting period. The Quarterly Reporting Form is required to be completed and posted regardless of whether the institution has drawn down or disbursed any funds for the quarter. Condition ?BOCES did not prepare or upload to its website required Quarterly Reporting Forms or Student Aid Portion information timely. Cause ? Production of required reporting was not completed until after the end of the fiscal year. Effect ? Quarterly reporting forms and student aid portion information was not uploaded to BOCES?s website within the required 10 days after the end of each reporting period. Questioned Costs ? There were no questioned costs noted related to this finding. Context ?We discussed the internal controls over the preparation and publishing of required reporting with BOCES management and were informed that the reports had not been prepared and uploaded to the website as required. Management subsequently produced all required reporting and we were able to observe and test the completed reports on BOCES?s website. Recommendation ? We recommend that an individual, other than the preparer, who is familiar with grant reporting requirements be assigned to review and approve required reports for accuracy and timeliness. We also recommend that a calendar of reporting dates be developed to more effectively track timely completion of required reporting. BOCES? Response ? At the outset of grant implementation, tasks associated with grant reporting including preparation, review, and submission will be clearly identified and assigned to appropriate personnel. A shared calendar of deadlines will be created and maintained.
(#2022-003) Allowable Costs? CFDA No. 84.425N ? COVID-19 HEERF-FIPSE Formula Grant Year Ended ? June 30, 2022 Direct Program Federal Agency ? U.S. Department of Education Criteria ?Institutions must follow the documentation requirements under 2 CFR ? 200.334 to retain financial records, supporting documents, statistical records, and all other institutional records pertinent to lost revenue and the administration of the HEERF grant programs generally for a period of three years from the date of submission of the final expenditure report. Condition ? Documentation to support the estimates for lost revenue was not provided to management timely for review and approval. Cause ?Adequate documentation was not maintained to support the lost revenue estimate. Effect ?Documentation supporting lost revenue estimates was not properly maintained prior to the submission of drawdowns of grant funds. Questioned Costs ? There were no questioned costs noted related to this finding. Context ?This finding was identified during our testing of lost revenues reported as allowable costs. BOCES was able to provide their calculation and method for estimating lost revenue for the program, however, management was not able to provide support for the enrollment numbers used in the estimate. Subsequent to our original request, the Continuing Education Department was able to provide enrollment documentation which supported the estimates selected for testing. Recommendation ? Documentation used in developing the estimates should be maintained in accordance with grant terms, and provided to management for their review and approval prior to the submission of drawdowns. BOCES? Response ? BOCES will ensure that clear and appropriate supporting documentation is in line with grant terms and is provided by the department and reviewed with the Finance Office prior to any submission for grant disbursement.
(#2022-001) Cash Management ? CFDA No. 84.425E ? COVID-19 HEERF-Student Aid Portion Year Ended ? June 30, 2022 Direct Program Federal Agency ? U.S. Department of Education Criteria ?For CRRSAA HEERF II and ARP HEERF III, the Certification and Agreements and /or Supplemental Agreements require that Student Aid Portion (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from United States Department of Education?s G5 grants system. Condition ?Funds drawn down by BOCES during its fiscal year ended June 30, 2022, for emergency financial aid grants to students were not disbursed within 15 calendar days. Cause ?Draw downs were prepared and submitted to G5 when the amounts needed were determined by the Continuing Ed department, but disbursements were not processed until after the maximum number of days allowed under the grant. Effect ? BOCES did not disburse funds within the time frame required by the supplemental agreements for CRRSAA HEERF II funds. Questioned Costs ? There were no questioned costs for this finding. Context ? This finding was identified during our testing of cash draw downs and the related disbursements. We examined a sample drawdowns related to HEERF grants including 100% of those related to the Student Aid Portion. The remaining draws related to the FIPSE portion of grants were made on strictly a reimbursement basis, and as such the findings noted were consider isolated to the Student Aid Portion and no further estimating for the prevalence of this error was deemed necessary. Recommendation ? We recommend that draw down requests be provided to the Treasurer for submission on the G5 system when it is reasonably certain that the disbursements of those funds will occur within the required time frames established by the grant agreements. In addition, the Treasurer should verify with the department providing the draw down that disbursement will occur within the required time frame prior to submission to the granting agency. BOCES? Response ? BOCES will ensure that conditions for draw down are met by referencing grant compliance materials and verifying timelines with the department prior to any action.
(#2022-003) Allowable Costs? CFDA No. 84.425N ? COVID-19 HEERF-FIPSE Formula Grant Year Ended ? June 30, 2022 Direct Program Federal Agency ? U.S. Department of Education Criteria ?Institutions must follow the documentation requirements under 2 CFR ? 200.334 to retain financial records, supporting documents, statistical records, and all other institutional records pertinent to lost revenue and the administration of the HEERF grant programs generally for a period of three years from the date of submission of the final expenditure report. Condition ? Documentation to support the estimates for lost revenue was not provided to management timely for review and approval. Cause ?Adequate documentation was not maintained to support the lost revenue estimate. Effect ?Documentation supporting lost revenue estimates was not properly maintained prior to the submission of drawdowns of grant funds. Questioned Costs ? There were no questioned costs noted related to this finding. Context ?This finding was identified during our testing of lost revenues reported as allowable costs. BOCES was able to provide their calculation and method for estimating lost revenue for the program, however, management was not able to provide support for the enrollment numbers used in the estimate. Subsequent to our original request, the Continuing Education Department was able to provide enrollment documentation which supported the estimates selected for testing. Recommendation ? Documentation used in developing the estimates should be maintained in accordance with grant terms, and provided to management for their review and approval prior to the submission of drawdowns. BOCES? Response ? BOCES will ensure that clear and appropriate supporting documentation is in line with grant terms and is provided by the department and reviewed with the Finance Office prior to any submission for grant disbursement.
(#2022-002) Reporting ? CFDA No. 84.425E ? COVID-19 HEERF-Student Aid Portion CFDA No. 84.425N ? COVID-19 HEERF-FIPSE Formula Grant Year Ended ? June 30, 2022 Direct Program Federal Agency ? U.S. Department of Education Criteria ?the CARES Act 18004(e) and CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. Institutions must complete the Quarterly Budget and Expenditure Reporting form (OMB Control Number 1840-0849 V.1.1) for its Institutional Portion and any subprograms, including FIPSE. In addition, quarterly reporting of certain information related to the Student Aid Portion award is required. The Quarterly Reporting form and Student Aid Portion information must be conspicuously posted in the institution?s primary website and on the same page and are due 10 days after the end of each reporting period. The Quarterly Reporting Form is required to be completed and posted regardless of whether the institution has drawn down or disbursed any funds for the quarter. Condition ?BOCES did not prepare or upload to its website required Quarterly Reporting Forms or Student Aid Portion information timely. Cause ? Production of required reporting was not completed until after the end of the fiscal year. Effect ? Quarterly reporting forms and student aid portion information was not uploaded to BOCES?s website within the required 10 days after the end of each reporting period. Questioned Costs ? There were no questioned costs noted related to this finding. Context ?We discussed the internal controls over the preparation and publishing of required reporting with BOCES management and were informed that the reports had not been prepared and uploaded to the website as required. Management subsequently produced all required reporting and we were able to observe and test the completed reports on BOCES?s website. Recommendation ? We recommend that an individual, other than the preparer, who is familiar with grant reporting requirements be assigned to review and approve required reports for accuracy and timeliness. We also recommend that a calendar of reporting dates be developed to more effectively track timely completion of required reporting. BOCES? Response ? At the outset of grant implementation, tasks associated with grant reporting including preparation, review, and submission will be clearly identified and assigned to appropriate personnel. A shared calendar of deadlines will be created and maintained.
(#2022-003) Allowable Costs? CFDA No. 84.425N ? COVID-19 HEERF-FIPSE Formula Grant Year Ended ? June 30, 2022 Direct Program Federal Agency ? U.S. Department of Education Criteria ?Institutions must follow the documentation requirements under 2 CFR ? 200.334 to retain financial records, supporting documents, statistical records, and all other institutional records pertinent to lost revenue and the administration of the HEERF grant programs generally for a period of three years from the date of submission of the final expenditure report. Condition ? Documentation to support the estimates for lost revenue was not provided to management timely for review and approval. Cause ?Adequate documentation was not maintained to support the lost revenue estimate. Effect ?Documentation supporting lost revenue estimates was not properly maintained prior to the submission of drawdowns of grant funds. Questioned Costs ? There were no questioned costs noted related to this finding. Context ?This finding was identified during our testing of lost revenues reported as allowable costs. BOCES was able to provide their calculation and method for estimating lost revenue for the program, however, management was not able to provide support for the enrollment numbers used in the estimate. Subsequent to our original request, the Continuing Education Department was able to provide enrollment documentation which supported the estimates selected for testing. Recommendation ? Documentation used in developing the estimates should be maintained in accordance with grant terms, and provided to management for their review and approval prior to the submission of drawdowns. BOCES? Response ? BOCES will ensure that clear and appropriate supporting documentation is in line with grant terms and is provided by the department and reviewed with the Finance Office prior to any submission for grant disbursement.