Finding 2022-002: Education Stabilization Fund Reporting Federal Agency: Department of Education Program: COVID-19 Education Stabilization Fund 84.425 Criteria: In accordance with the Higher Education Emergency Relief Fund reporting requirements found in the 2 CFR Part 200, separate quarterly reports for both student and institutional portions of the grant are to be completed accurately and conspicuously posted to the institution?s primary website no later than 10 days after the end of each calendar quarter. The institutional reports are to include the aggregate amounts spent and the student reports are to include the total grants distributed, estimated total number of students eligible, total number of students who received grants, and methods used to determine which students would receive funding, and in what amount. In addition, the annual report was to be filed by May 6, 2022 including the total amount expended for both student and institutional portions of the grant through December 31, 2021. Condition: The internal control system to ensure that this program was fully in compliance with all reporting requirements was not operating effectively. WCCC did not timely post the institutional quarterly report for the quarter ending December 31, 2021 to the institution?s primary website or timely post the student quarterly report for the quarter ending September 30, 2021. In addition, the amount of institutional expenditures initially reported on the December and March reports were incorrect and subsequently updated by WCCC. The annual report also incorrectly reported the number of unduplicated students who received grant funding during calendar year 2021 and overstated the amount of institutional expense and lost revenue during 2021 by $1,542,463. Cause: Procedures in place to ensure that the annual and quarterly reports were completed accurately and that the quarterly reports were timely posted to the website were not adequate. Effect: WCCC was not in compliance with all annual reporting requirements, quarterly reporting requirements, or timely public posting of the reports on the institution?s website for the Higher Education Emergency Relief Fund federal funds. Repeat Finding: This is a repeat finding of 2021-002. Questioned costs: None Recommendation: We recommend that WCCC implement a procedure to ensure that all required Education Stabilization Fund reporting is completed accurately and timely, and verify that quarterly reports are posted and conspicuously appear on the institution?s website within the time frame required for both student and institutional portions of the grant. View of Responsible Officials and Planned Corrective Action: A calendar of activities has been created and shared with responsible parties to ensure that reports are created and posted to the website in a timely manner.
Finding 2022-003: Education Stabilization Fund Cash Management Federal Agency: Department of Education Program: COVID-19 Education Stabilization Fund: 84.425 Criteria: In accordance with the Higher Education Emergency Relief Fund cash management requirements found in the 2 CFR Part 200, institutional aid is required to be disbursed within three calendar days of the drawdown from Department of Education grants management system (G5). In addition, the obligation for lost revenue is considered to have occurred on the date that the institution completes its estimate of its amount of lost revenue after the estimation period. Condition: The internal control system to ensure that this program was fully in compliance with all cash management requirements was not operating effectively. An error occurred in WCCC?s calculation of lost revenue due to incorrectly applying the amount of lost revenue relating to fiscal year 2022 to the drawdown in March of 2022. As the obligation for lost revenue occurs after the estimation period ends, lost revenue for fiscal year 2022 should not have been drawn down until after year end and resulted in an overdraw of institutional aid of approximately $410,000 in March. The overdrawn amount was eligible to be part of the lost revenue drawn for 2022 and therefore no refund of the funds is required. WCCC did not subsequently spend this funding within three days as required. In addition, various invoice amounts totaling approximately $75,000 were also incorrectly applied toward this funding as institutional expenses and a 10% administrative cost on those invoices and on WCCC?s estimated amount of lost revenue was incorrectly applied toward this fund in the amount of approximately $382,000. Again, these amounts could have been corrected with the August 2022 draw for eligible fiscal year 2022 expenditures so no return of funds required. The overall impact of these errors was a cash management issue of drawing the funds too early. Cause: Procedures in place to ensure that funds were drawn in the proper period were not adequate. Effect: WCCC was not in compliance with all cash management requirements. The total institutional expenses included on the Schedule of Expenditures of Federal Awards is shown net of these errors and the overdraw was properly spent in fiscal year 2023. Questioned costs: None Recommendation: We recommend that WCCC implement procedures to ensure funds are drawn correctly and appropriately spent within three days of the draw. View of Responsible Officials and Planned Corrective Action: A reconciliation of all stabilization funds has taken place and will continue to take place until all funds are drawn down. A checks and balances procedure is in place to ensure calculations are accurate and reports reflect actual activity.
Finding 2022-002: Education Stabilization Fund Reporting Federal Agency: Department of Education Program: COVID-19 Education Stabilization Fund 84.425 Criteria: In accordance with the Higher Education Emergency Relief Fund reporting requirements found in the 2 CFR Part 200, separate quarterly reports for both student and institutional portions of the grant are to be completed accurately and conspicuously posted to the institution?s primary website no later than 10 days after the end of each calendar quarter. The institutional reports are to include the aggregate amounts spent and the student reports are to include the total grants distributed, estimated total number of students eligible, total number of students who received grants, and methods used to determine which students would receive funding, and in what amount. In addition, the annual report was to be filed by May 6, 2022 including the total amount expended for both student and institutional portions of the grant through December 31, 2021. Condition: The internal control system to ensure that this program was fully in compliance with all reporting requirements was not operating effectively. WCCC did not timely post the institutional quarterly report for the quarter ending December 31, 2021 to the institution?s primary website or timely post the student quarterly report for the quarter ending September 30, 2021. In addition, the amount of institutional expenditures initially reported on the December and March reports were incorrect and subsequently updated by WCCC. The annual report also incorrectly reported the number of unduplicated students who received grant funding during calendar year 2021 and overstated the amount of institutional expense and lost revenue during 2021 by $1,542,463. Cause: Procedures in place to ensure that the annual and quarterly reports were completed accurately and that the quarterly reports were timely posted to the website were not adequate. Effect: WCCC was not in compliance with all annual reporting requirements, quarterly reporting requirements, or timely public posting of the reports on the institution?s website for the Higher Education Emergency Relief Fund federal funds. Repeat Finding: This is a repeat finding of 2021-002. Questioned costs: None Recommendation: We recommend that WCCC implement a procedure to ensure that all required Education Stabilization Fund reporting is completed accurately and timely, and verify that quarterly reports are posted and conspicuously appear on the institution?s website within the time frame required for both student and institutional portions of the grant. View of Responsible Officials and Planned Corrective Action: A calendar of activities has been created and shared with responsible parties to ensure that reports are created and posted to the website in a timely manner.
Finding 2022-003: Education Stabilization Fund Cash Management Federal Agency: Department of Education Program: COVID-19 Education Stabilization Fund: 84.425 Criteria: In accordance with the Higher Education Emergency Relief Fund cash management requirements found in the 2 CFR Part 200, institutional aid is required to be disbursed within three calendar days of the drawdown from Department of Education grants management system (G5). In addition, the obligation for lost revenue is considered to have occurred on the date that the institution completes its estimate of its amount of lost revenue after the estimation period. Condition: The internal control system to ensure that this program was fully in compliance with all cash management requirements was not operating effectively. An error occurred in WCCC?s calculation of lost revenue due to incorrectly applying the amount of lost revenue relating to fiscal year 2022 to the drawdown in March of 2022. As the obligation for lost revenue occurs after the estimation period ends, lost revenue for fiscal year 2022 should not have been drawn down until after year end and resulted in an overdraw of institutional aid of approximately $410,000 in March. The overdrawn amount was eligible to be part of the lost revenue drawn for 2022 and therefore no refund of the funds is required. WCCC did not subsequently spend this funding within three days as required. In addition, various invoice amounts totaling approximately $75,000 were also incorrectly applied toward this funding as institutional expenses and a 10% administrative cost on those invoices and on WCCC?s estimated amount of lost revenue was incorrectly applied toward this fund in the amount of approximately $382,000. Again, these amounts could have been corrected with the August 2022 draw for eligible fiscal year 2022 expenditures so no return of funds required. The overall impact of these errors was a cash management issue of drawing the funds too early. Cause: Procedures in place to ensure that funds were drawn in the proper period were not adequate. Effect: WCCC was not in compliance with all cash management requirements. The total institutional expenses included on the Schedule of Expenditures of Federal Awards is shown net of these errors and the overdraw was properly spent in fiscal year 2023. Questioned costs: None Recommendation: We recommend that WCCC implement procedures to ensure funds are drawn correctly and appropriately spent within three days of the draw. View of Responsible Officials and Planned Corrective Action: A reconciliation of all stabilization funds has taken place and will continue to take place until all funds are drawn down. A checks and balances procedure is in place to ensure calculations are accurate and reports reflect actual activity.
Finding 2022-002: Education Stabilization Fund Reporting Federal Agency: Department of Education Program: COVID-19 Education Stabilization Fund 84.425 Criteria: In accordance with the Higher Education Emergency Relief Fund reporting requirements found in the 2 CFR Part 200, separate quarterly reports for both student and institutional portions of the grant are to be completed accurately and conspicuously posted to the institution?s primary website no later than 10 days after the end of each calendar quarter. The institutional reports are to include the aggregate amounts spent and the student reports are to include the total grants distributed, estimated total number of students eligible, total number of students who received grants, and methods used to determine which students would receive funding, and in what amount. In addition, the annual report was to be filed by May 6, 2022 including the total amount expended for both student and institutional portions of the grant through December 31, 2021. Condition: The internal control system to ensure that this program was fully in compliance with all reporting requirements was not operating effectively. WCCC did not timely post the institutional quarterly report for the quarter ending December 31, 2021 to the institution?s primary website or timely post the student quarterly report for the quarter ending September 30, 2021. In addition, the amount of institutional expenditures initially reported on the December and March reports were incorrect and subsequently updated by WCCC. The annual report also incorrectly reported the number of unduplicated students who received grant funding during calendar year 2021 and overstated the amount of institutional expense and lost revenue during 2021 by $1,542,463. Cause: Procedures in place to ensure that the annual and quarterly reports were completed accurately and that the quarterly reports were timely posted to the website were not adequate. Effect: WCCC was not in compliance with all annual reporting requirements, quarterly reporting requirements, or timely public posting of the reports on the institution?s website for the Higher Education Emergency Relief Fund federal funds. Repeat Finding: This is a repeat finding of 2021-002. Questioned costs: None Recommendation: We recommend that WCCC implement a procedure to ensure that all required Education Stabilization Fund reporting is completed accurately and timely, and verify that quarterly reports are posted and conspicuously appear on the institution?s website within the time frame required for both student and institutional portions of the grant. View of Responsible Officials and Planned Corrective Action: A calendar of activities has been created and shared with responsible parties to ensure that reports are created and posted to the website in a timely manner.
Finding 2022-003: Education Stabilization Fund Cash Management Federal Agency: Department of Education Program: COVID-19 Education Stabilization Fund: 84.425 Criteria: In accordance with the Higher Education Emergency Relief Fund cash management requirements found in the 2 CFR Part 200, institutional aid is required to be disbursed within three calendar days of the drawdown from Department of Education grants management system (G5). In addition, the obligation for lost revenue is considered to have occurred on the date that the institution completes its estimate of its amount of lost revenue after the estimation period. Condition: The internal control system to ensure that this program was fully in compliance with all cash management requirements was not operating effectively. An error occurred in WCCC?s calculation of lost revenue due to incorrectly applying the amount of lost revenue relating to fiscal year 2022 to the drawdown in March of 2022. As the obligation for lost revenue occurs after the estimation period ends, lost revenue for fiscal year 2022 should not have been drawn down until after year end and resulted in an overdraw of institutional aid of approximately $410,000 in March. The overdrawn amount was eligible to be part of the lost revenue drawn for 2022 and therefore no refund of the funds is required. WCCC did not subsequently spend this funding within three days as required. In addition, various invoice amounts totaling approximately $75,000 were also incorrectly applied toward this funding as institutional expenses and a 10% administrative cost on those invoices and on WCCC?s estimated amount of lost revenue was incorrectly applied toward this fund in the amount of approximately $382,000. Again, these amounts could have been corrected with the August 2022 draw for eligible fiscal year 2022 expenditures so no return of funds required. The overall impact of these errors was a cash management issue of drawing the funds too early. Cause: Procedures in place to ensure that funds were drawn in the proper period were not adequate. Effect: WCCC was not in compliance with all cash management requirements. The total institutional expenses included on the Schedule of Expenditures of Federal Awards is shown net of these errors and the overdraw was properly spent in fiscal year 2023. Questioned costs: None Recommendation: We recommend that WCCC implement procedures to ensure funds are drawn correctly and appropriately spent within three days of the draw. View of Responsible Officials and Planned Corrective Action: A reconciliation of all stabilization funds has taken place and will continue to take place until all funds are drawn down. A checks and balances procedure is in place to ensure calculations are accurate and reports reflect actual activity.
Finding 2022-004: Higher Education Institutional Aid Allowable Costs and Allowable Activities Federal Agency: Department of Education Program: Higher Education Institutional Aid 84.031A Criteria: In accordance with the allowable cost and allowable activity requirements found in the 2 CFR Part 200, requirements for costs and activities allowed or unallowed are contained within federal awarding agency regulations and the terms and conditions of the federal award. According to the Higher Education Institutional Aid grant agreement, funds must be spent as specified in the grant award notifications and the approved application for allowable direct costs of the grant. Condition: The internal control system to ensure that this program was fully in compliance with all allowable cost and allowable activities requirements was not operating effectively. The initial grant application prepared by WCCC at the start of the five-year grant included a detailed budget by year that, in part, included the upgrade of the Enterprise Resource Planning (ERP) system. The annual budget in the application correlates with the budget shown on the annual reports. However, the final report in year five, which was completed in fiscal year 2022, showed several budget categories that were significantly overspent. In addition, the reported expenditures do not readily correlate to the actual expenditures charged to the grant in fiscal year 2022. The actual expenditures charged to the grant in fiscal year 2022 were substantially all related to the ERP upgrade that did occur within the period of grant performance. WCCC could not provide a clear, verifiable documentation trail from inception of the grant to finalization that correlates the amount and budget categories of spending relating to the ERP system to what was initially approved under the grant application. Cause: Several years of underspent grant funds accumulated into the final year of the grant. In addition, the ERP system upgrade costs changed significantly from the time of initial grant application and budget. As a result, significant ERP system costs were applied to the grant at the end of the period of performance, which caused costs by budget category to be significantly different than what was originally approved. In addition, the grant project director and any related finance personnel involved with the final report and the overall grant administration had all left employment with WCCC during fiscal year 2022. Effect: It is undeterminable whether the extent of the ERP costs that were applied to the grant are considered to be allowable costs and allowable activities based on the initial application and annual budget categories and any other grant documentation that could be provided by WCCC. Questioned costs: Undeterminable Recommendation: We recommend that WCCC implement procedures to ensure that grant funding is being spent in accordance with grant approval and budget category. Documentation should be maintained to support any changes from the original award budget and any necessary approvals should be obtained for significant changes in plans relating to spending. A clear documentation trail is critical to ensure the grant expenditures are supported even when there is turnover in grant related personnel. View of Responsible Officials and Planned Corrective Action: Grants will be reconciled to ensure that annual expenditures meet the grant budget and outcomes. The accounting and foundation/grants offices will work in partnership to ensure compliance. All documentation will be on file with the grants.
Finding 2022-005: Higher Education Institutional Aid Reporting Federal Agency: Department of Education Program: Higher Education Institutional Aid 84.031A Criteria: In accordance with the reporting requirements found in the 2 CFR Part 200, financial reporting requirements are contained within the conditions of the grant contract. For the Higher Education Institutional Aid program, a final performance report is required to be submitted within 90 days after the expiration or termination of grant support. Condition: The internal control system to ensure that this program was fully in compliance with all reporting requirements was not operating effectively. The five-year Higher Education Institutional Aid grant received by WCCC expired on September 30, 2021. Accordingly, a final annual performance report was filed. However, the submission date of April 1, 2022 is not within the required 90 days nor was there adequate documentation available to support how the final report was produced. Cause: Procedures in place to ensure that the required final annual performance report was submitted on time were not adequate. In addition, documentation was not maintained to support how the expenditures applied to the grant in the final reporting period correlated to what was reported by budget category. Effect: WCCC was not in compliance with the final reporting timing and report documentation requirements. Questioned costs: None Recommendation: We recommend that WCCC implement a procedure to ensure that all federal grant reporting is completed accurately and timely, and that documentation is maintained to support how the reported information was compiled. View of Responsible Officials and Planned Corrective Action: The College has created a master shared calendar in the foundation/grants office and also in the accounting office to ensure that all due dates for grants and reporting are known and submissions are made by those due dates.
Finding 2022-002: Education Stabilization Fund Reporting Federal Agency: Department of Education Program: COVID-19 Education Stabilization Fund 84.425 Criteria: In accordance with the Higher Education Emergency Relief Fund reporting requirements found in the 2 CFR Part 200, separate quarterly reports for both student and institutional portions of the grant are to be completed accurately and conspicuously posted to the institution?s primary website no later than 10 days after the end of each calendar quarter. The institutional reports are to include the aggregate amounts spent and the student reports are to include the total grants distributed, estimated total number of students eligible, total number of students who received grants, and methods used to determine which students would receive funding, and in what amount. In addition, the annual report was to be filed by May 6, 2022 including the total amount expended for both student and institutional portions of the grant through December 31, 2021. Condition: The internal control system to ensure that this program was fully in compliance with all reporting requirements was not operating effectively. WCCC did not timely post the institutional quarterly report for the quarter ending December 31, 2021 to the institution?s primary website or timely post the student quarterly report for the quarter ending September 30, 2021. In addition, the amount of institutional expenditures initially reported on the December and March reports were incorrect and subsequently updated by WCCC. The annual report also incorrectly reported the number of unduplicated students who received grant funding during calendar year 2021 and overstated the amount of institutional expense and lost revenue during 2021 by $1,542,463. Cause: Procedures in place to ensure that the annual and quarterly reports were completed accurately and that the quarterly reports were timely posted to the website were not adequate. Effect: WCCC was not in compliance with all annual reporting requirements, quarterly reporting requirements, or timely public posting of the reports on the institution?s website for the Higher Education Emergency Relief Fund federal funds. Repeat Finding: This is a repeat finding of 2021-002. Questioned costs: None Recommendation: We recommend that WCCC implement a procedure to ensure that all required Education Stabilization Fund reporting is completed accurately and timely, and verify that quarterly reports are posted and conspicuously appear on the institution?s website within the time frame required for both student and institutional portions of the grant. View of Responsible Officials and Planned Corrective Action: A calendar of activities has been created and shared with responsible parties to ensure that reports are created and posted to the website in a timely manner.
Finding 2022-003: Education Stabilization Fund Cash Management Federal Agency: Department of Education Program: COVID-19 Education Stabilization Fund: 84.425 Criteria: In accordance with the Higher Education Emergency Relief Fund cash management requirements found in the 2 CFR Part 200, institutional aid is required to be disbursed within three calendar days of the drawdown from Department of Education grants management system (G5). In addition, the obligation for lost revenue is considered to have occurred on the date that the institution completes its estimate of its amount of lost revenue after the estimation period. Condition: The internal control system to ensure that this program was fully in compliance with all cash management requirements was not operating effectively. An error occurred in WCCC?s calculation of lost revenue due to incorrectly applying the amount of lost revenue relating to fiscal year 2022 to the drawdown in March of 2022. As the obligation for lost revenue occurs after the estimation period ends, lost revenue for fiscal year 2022 should not have been drawn down until after year end and resulted in an overdraw of institutional aid of approximately $410,000 in March. The overdrawn amount was eligible to be part of the lost revenue drawn for 2022 and therefore no refund of the funds is required. WCCC did not subsequently spend this funding within three days as required. In addition, various invoice amounts totaling approximately $75,000 were also incorrectly applied toward this funding as institutional expenses and a 10% administrative cost on those invoices and on WCCC?s estimated amount of lost revenue was incorrectly applied toward this fund in the amount of approximately $382,000. Again, these amounts could have been corrected with the August 2022 draw for eligible fiscal year 2022 expenditures so no return of funds required. The overall impact of these errors was a cash management issue of drawing the funds too early. Cause: Procedures in place to ensure that funds were drawn in the proper period were not adequate. Effect: WCCC was not in compliance with all cash management requirements. The total institutional expenses included on the Schedule of Expenditures of Federal Awards is shown net of these errors and the overdraw was properly spent in fiscal year 2023. Questioned costs: None Recommendation: We recommend that WCCC implement procedures to ensure funds are drawn correctly and appropriately spent within three days of the draw. View of Responsible Officials and Planned Corrective Action: A reconciliation of all stabilization funds has taken place and will continue to take place until all funds are drawn down. A checks and balances procedure is in place to ensure calculations are accurate and reports reflect actual activity.
Finding 2022-002: Education Stabilization Fund Reporting Federal Agency: Department of Education Program: COVID-19 Education Stabilization Fund 84.425 Criteria: In accordance with the Higher Education Emergency Relief Fund reporting requirements found in the 2 CFR Part 200, separate quarterly reports for both student and institutional portions of the grant are to be completed accurately and conspicuously posted to the institution?s primary website no later than 10 days after the end of each calendar quarter. The institutional reports are to include the aggregate amounts spent and the student reports are to include the total grants distributed, estimated total number of students eligible, total number of students who received grants, and methods used to determine which students would receive funding, and in what amount. In addition, the annual report was to be filed by May 6, 2022 including the total amount expended for both student and institutional portions of the grant through December 31, 2021. Condition: The internal control system to ensure that this program was fully in compliance with all reporting requirements was not operating effectively. WCCC did not timely post the institutional quarterly report for the quarter ending December 31, 2021 to the institution?s primary website or timely post the student quarterly report for the quarter ending September 30, 2021. In addition, the amount of institutional expenditures initially reported on the December and March reports were incorrect and subsequently updated by WCCC. The annual report also incorrectly reported the number of unduplicated students who received grant funding during calendar year 2021 and overstated the amount of institutional expense and lost revenue during 2021 by $1,542,463. Cause: Procedures in place to ensure that the annual and quarterly reports were completed accurately and that the quarterly reports were timely posted to the website were not adequate. Effect: WCCC was not in compliance with all annual reporting requirements, quarterly reporting requirements, or timely public posting of the reports on the institution?s website for the Higher Education Emergency Relief Fund federal funds. Repeat Finding: This is a repeat finding of 2021-002. Questioned costs: None Recommendation: We recommend that WCCC implement a procedure to ensure that all required Education Stabilization Fund reporting is completed accurately and timely, and verify that quarterly reports are posted and conspicuously appear on the institution?s website within the time frame required for both student and institutional portions of the grant. View of Responsible Officials and Planned Corrective Action: A calendar of activities has been created and shared with responsible parties to ensure that reports are created and posted to the website in a timely manner.
Finding 2022-003: Education Stabilization Fund Cash Management Federal Agency: Department of Education Program: COVID-19 Education Stabilization Fund: 84.425 Criteria: In accordance with the Higher Education Emergency Relief Fund cash management requirements found in the 2 CFR Part 200, institutional aid is required to be disbursed within three calendar days of the drawdown from Department of Education grants management system (G5). In addition, the obligation for lost revenue is considered to have occurred on the date that the institution completes its estimate of its amount of lost revenue after the estimation period. Condition: The internal control system to ensure that this program was fully in compliance with all cash management requirements was not operating effectively. An error occurred in WCCC?s calculation of lost revenue due to incorrectly applying the amount of lost revenue relating to fiscal year 2022 to the drawdown in March of 2022. As the obligation for lost revenue occurs after the estimation period ends, lost revenue for fiscal year 2022 should not have been drawn down until after year end and resulted in an overdraw of institutional aid of approximately $410,000 in March. The overdrawn amount was eligible to be part of the lost revenue drawn for 2022 and therefore no refund of the funds is required. WCCC did not subsequently spend this funding within three days as required. In addition, various invoice amounts totaling approximately $75,000 were also incorrectly applied toward this funding as institutional expenses and a 10% administrative cost on those invoices and on WCCC?s estimated amount of lost revenue was incorrectly applied toward this fund in the amount of approximately $382,000. Again, these amounts could have been corrected with the August 2022 draw for eligible fiscal year 2022 expenditures so no return of funds required. The overall impact of these errors was a cash management issue of drawing the funds too early. Cause: Procedures in place to ensure that funds were drawn in the proper period were not adequate. Effect: WCCC was not in compliance with all cash management requirements. The total institutional expenses included on the Schedule of Expenditures of Federal Awards is shown net of these errors and the overdraw was properly spent in fiscal year 2023. Questioned costs: None Recommendation: We recommend that WCCC implement procedures to ensure funds are drawn correctly and appropriately spent within three days of the draw. View of Responsible Officials and Planned Corrective Action: A reconciliation of all stabilization funds has taken place and will continue to take place until all funds are drawn down. A checks and balances procedure is in place to ensure calculations are accurate and reports reflect actual activity.
Finding 2022-002: Education Stabilization Fund Reporting Federal Agency: Department of Education Program: COVID-19 Education Stabilization Fund 84.425 Criteria: In accordance with the Higher Education Emergency Relief Fund reporting requirements found in the 2 CFR Part 200, separate quarterly reports for both student and institutional portions of the grant are to be completed accurately and conspicuously posted to the institution?s primary website no later than 10 days after the end of each calendar quarter. The institutional reports are to include the aggregate amounts spent and the student reports are to include the total grants distributed, estimated total number of students eligible, total number of students who received grants, and methods used to determine which students would receive funding, and in what amount. In addition, the annual report was to be filed by May 6, 2022 including the total amount expended for both student and institutional portions of the grant through December 31, 2021. Condition: The internal control system to ensure that this program was fully in compliance with all reporting requirements was not operating effectively. WCCC did not timely post the institutional quarterly report for the quarter ending December 31, 2021 to the institution?s primary website or timely post the student quarterly report for the quarter ending September 30, 2021. In addition, the amount of institutional expenditures initially reported on the December and March reports were incorrect and subsequently updated by WCCC. The annual report also incorrectly reported the number of unduplicated students who received grant funding during calendar year 2021 and overstated the amount of institutional expense and lost revenue during 2021 by $1,542,463. Cause: Procedures in place to ensure that the annual and quarterly reports were completed accurately and that the quarterly reports were timely posted to the website were not adequate. Effect: WCCC was not in compliance with all annual reporting requirements, quarterly reporting requirements, or timely public posting of the reports on the institution?s website for the Higher Education Emergency Relief Fund federal funds. Repeat Finding: This is a repeat finding of 2021-002. Questioned costs: None Recommendation: We recommend that WCCC implement a procedure to ensure that all required Education Stabilization Fund reporting is completed accurately and timely, and verify that quarterly reports are posted and conspicuously appear on the institution?s website within the time frame required for both student and institutional portions of the grant. View of Responsible Officials and Planned Corrective Action: A calendar of activities has been created and shared with responsible parties to ensure that reports are created and posted to the website in a timely manner.
Finding 2022-003: Education Stabilization Fund Cash Management Federal Agency: Department of Education Program: COVID-19 Education Stabilization Fund: 84.425 Criteria: In accordance with the Higher Education Emergency Relief Fund cash management requirements found in the 2 CFR Part 200, institutional aid is required to be disbursed within three calendar days of the drawdown from Department of Education grants management system (G5). In addition, the obligation for lost revenue is considered to have occurred on the date that the institution completes its estimate of its amount of lost revenue after the estimation period. Condition: The internal control system to ensure that this program was fully in compliance with all cash management requirements was not operating effectively. An error occurred in WCCC?s calculation of lost revenue due to incorrectly applying the amount of lost revenue relating to fiscal year 2022 to the drawdown in March of 2022. As the obligation for lost revenue occurs after the estimation period ends, lost revenue for fiscal year 2022 should not have been drawn down until after year end and resulted in an overdraw of institutional aid of approximately $410,000 in March. The overdrawn amount was eligible to be part of the lost revenue drawn for 2022 and therefore no refund of the funds is required. WCCC did not subsequently spend this funding within three days as required. In addition, various invoice amounts totaling approximately $75,000 were also incorrectly applied toward this funding as institutional expenses and a 10% administrative cost on those invoices and on WCCC?s estimated amount of lost revenue was incorrectly applied toward this fund in the amount of approximately $382,000. Again, these amounts could have been corrected with the August 2022 draw for eligible fiscal year 2022 expenditures so no return of funds required. The overall impact of these errors was a cash management issue of drawing the funds too early. Cause: Procedures in place to ensure that funds were drawn in the proper period were not adequate. Effect: WCCC was not in compliance with all cash management requirements. The total institutional expenses included on the Schedule of Expenditures of Federal Awards is shown net of these errors and the overdraw was properly spent in fiscal year 2023. Questioned costs: None Recommendation: We recommend that WCCC implement procedures to ensure funds are drawn correctly and appropriately spent within three days of the draw. View of Responsible Officials and Planned Corrective Action: A reconciliation of all stabilization funds has taken place and will continue to take place until all funds are drawn down. A checks and balances procedure is in place to ensure calculations are accurate and reports reflect actual activity.
Finding 2022-004: Higher Education Institutional Aid Allowable Costs and Allowable Activities Federal Agency: Department of Education Program: Higher Education Institutional Aid 84.031A Criteria: In accordance with the allowable cost and allowable activity requirements found in the 2 CFR Part 200, requirements for costs and activities allowed or unallowed are contained within federal awarding agency regulations and the terms and conditions of the federal award. According to the Higher Education Institutional Aid grant agreement, funds must be spent as specified in the grant award notifications and the approved application for allowable direct costs of the grant. Condition: The internal control system to ensure that this program was fully in compliance with all allowable cost and allowable activities requirements was not operating effectively. The initial grant application prepared by WCCC at the start of the five-year grant included a detailed budget by year that, in part, included the upgrade of the Enterprise Resource Planning (ERP) system. The annual budget in the application correlates with the budget shown on the annual reports. However, the final report in year five, which was completed in fiscal year 2022, showed several budget categories that were significantly overspent. In addition, the reported expenditures do not readily correlate to the actual expenditures charged to the grant in fiscal year 2022. The actual expenditures charged to the grant in fiscal year 2022 were substantially all related to the ERP upgrade that did occur within the period of grant performance. WCCC could not provide a clear, verifiable documentation trail from inception of the grant to finalization that correlates the amount and budget categories of spending relating to the ERP system to what was initially approved under the grant application. Cause: Several years of underspent grant funds accumulated into the final year of the grant. In addition, the ERP system upgrade costs changed significantly from the time of initial grant application and budget. As a result, significant ERP system costs were applied to the grant at the end of the period of performance, which caused costs by budget category to be significantly different than what was originally approved. In addition, the grant project director and any related finance personnel involved with the final report and the overall grant administration had all left employment with WCCC during fiscal year 2022. Effect: It is undeterminable whether the extent of the ERP costs that were applied to the grant are considered to be allowable costs and allowable activities based on the initial application and annual budget categories and any other grant documentation that could be provided by WCCC. Questioned costs: Undeterminable Recommendation: We recommend that WCCC implement procedures to ensure that grant funding is being spent in accordance with grant approval and budget category. Documentation should be maintained to support any changes from the original award budget and any necessary approvals should be obtained for significant changes in plans relating to spending. A clear documentation trail is critical to ensure the grant expenditures are supported even when there is turnover in grant related personnel. View of Responsible Officials and Planned Corrective Action: Grants will be reconciled to ensure that annual expenditures meet the grant budget and outcomes. The accounting and foundation/grants offices will work in partnership to ensure compliance. All documentation will be on file with the grants.
Finding 2022-005: Higher Education Institutional Aid Reporting Federal Agency: Department of Education Program: Higher Education Institutional Aid 84.031A Criteria: In accordance with the reporting requirements found in the 2 CFR Part 200, financial reporting requirements are contained within the conditions of the grant contract. For the Higher Education Institutional Aid program, a final performance report is required to be submitted within 90 days after the expiration or termination of grant support. Condition: The internal control system to ensure that this program was fully in compliance with all reporting requirements was not operating effectively. The five-year Higher Education Institutional Aid grant received by WCCC expired on September 30, 2021. Accordingly, a final annual performance report was filed. However, the submission date of April 1, 2022 is not within the required 90 days nor was there adequate documentation available to support how the final report was produced. Cause: Procedures in place to ensure that the required final annual performance report was submitted on time were not adequate. In addition, documentation was not maintained to support how the expenditures applied to the grant in the final reporting period correlated to what was reported by budget category. Effect: WCCC was not in compliance with the final reporting timing and report documentation requirements. Questioned costs: None Recommendation: We recommend that WCCC implement a procedure to ensure that all federal grant reporting is completed accurately and timely, and that documentation is maintained to support how the reported information was compiled. View of Responsible Officials and Planned Corrective Action: The College has created a master shared calendar in the foundation/grants office and also in the accounting office to ensure that all due dates for grants and reporting are known and submissions are made by those due dates.