Finding 2023-003: Student Financial Assistance Cluster Allowable Costs and Allowable Activities and Eligibility – Pell and SEOG
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster
Criteria: WCCC is required to have controls in place to ensure students receive the proper amount of student financial assistance funding they are entitled to based on financial need.
Condition: Our financial aid sample of 40 items tested yielded 28 students who received Pell Grant funding. Of those 28 students, we noted two instances where the student received Pell funding that they were not entitled to receive. The amounts awarded to the students were $506 and $568, when they were both entitled to receive $0. In addition, our Return of Title IV Funds sample of 25 yielded 16 students who received Pell Grant funding. We noted two of those students also received Pell grants over the amount they were entitled to. The amounts awarded to both students were $1,724, when they were both entitled to $862. Our Return of Title IV Funds sample of 25 also included one student who inadvertently received $500 of SEOG funds they were not eligible to receive.
Cause: Controls were not in place to ensure students received the proper amount of Student Financial Assistance they were entitled to.
Effect: WCCC is not in compliance with required calculations for student financial assistance funding. WCCC may be liable to return funds to the Department of Education related to the overpayments to students.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC review policies and procedures to ensure that proper procedures are in place verifying the accuracy of student eligibility for grant funding and that the proper amount is paid to the student based on financial need.
View of Responsible Officials and Planned Corrective Action: The findings noted three separate issues related to policies and procedures verifying the accuracy of the student eligibility for grant funding and the proper amount paid to the student based on financial need. After a review of Pell grants, Return To Title IV funds, and the award of SEOG after a return of Title IV calculation, it was determined that human error as a result of manual work was the root cause. To correct the root cause, an increased level of internal control via another level of review and a re-review of aid for the FY24 year was implemented. Further, for students who had an enrollment status of less than full time, we have increased the number of reviews for compliance. Moving forward, the College is implementing a new ERP system in which internal controls will be configured to alleviate manual work thus human error and increase compliance.
Finding 2023-004: Student Financial Assistance Cluster Special Tests and Provisions Return of Title IV Funds
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster
Criteria: In accordance with 34 CFR section 668.22, when a recipient of Title IV grant or loan assistance withdrawals during the payment period, the institution must have proper controls in place to determine the amount of Title IV aid earned by the student as of the student’s withdrawal date, and if the total amount earned is less than the amount of Title IV funds that were disbursed, the difference must be returned to the Title IV programs.
Condition: Our Return of Title IV Funds sample of 25 yielded two instances where the improper amount of Pell funding was returned to the Department of Education. These two students also received an initial grant amount higher than they were entitled to, as discussed in finding 2023-003 above. The first student was granted $1,724 when they were entitled to $862. A calculation of the Return of Title IV Funds based on them receiving $1,724 calculated that they had earned $434.51 based on their withdrawal date, and they were required to return $1,289.49. $858.42 was returned from the student’s account, causing an underpayment of $431.07. The second student was granted $1,724 when they were entitled to $862. A calculation of the Return of Title IV Funds based on them receiving $1,724 calculated that they had earned $438.82 based on their withdrawal date, and they were required to return $1,285.18. $854.11 was returned from the student’s account, causing an underpayment of $431.07.
Cause: The Title IV refunds in question resulted in incorrect returned amounts due to human error in mathematical calculations. There was not a process in place for calculations to be double-checked (reperformed) by an independent person, which would have likely caught the error prior to processing the refund payment.
Effect: Errors in mathematical calculations resulted in incorrect amounts returned by WCCC; resulting in noncompliance with 34 CFR section 668.22.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC develop a process for an independent review (including reperformance of the calculations) of the refund calculations to help catch human errors in the calculation process. It is our understanding a portion of the calculation is automated; however, WCCC should ensure initial grant amounts are correct prior to the calculation taking place.
View of Responsible Officials and Planned Corrective Action: As previously noted, the root cause was human error based on the manual processes. Similar to the previous finding, the College has implemented increased internal control through the review of the R2T4 calculations. Additionally, when using the automated functionality within the system for the return of funds calculation, an independent review of the calculation will be performed moving forward. In the future, the new ERP will increase the levels of control configured in the system.
Finding 2023-005: Student Financial Assistance Cluster Gramm-Leach-Bliley Act – Student Information Security
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster
Criteria: In accordance 16 CFR Part 314, institutions receiving Student Financial Assistance Cluster funding were required to be in compliance with the revised requirements of the Gramm-Leach-Bliley Act (GLBA) information safeguarding standards by June 9, 2023. Included in these standards is the institution’s requirement to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and includes the required elements included in 16 CFR 314.4.
Condition: The internal control system to ensure that that the program’s compliance with the requirements of the GLBA was not operating effectively. WCCC is in the process of creating a written information security program that addresses the required minimum elements; however, that written program was not in place prior to June 9, 2023.
Cause: Procedures in place to ensure WCCC was in compliance with the requirements of the GLBA were not adequate.
Effect: WCCC was not in compliance with the GLBA requirements for Student Financial Aid funds.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC implement a procedure to ensure that all required GLBA requirements are reviewed, and those requirements are included in the written information security program once it is completed.
View of Responsible Officials and Planned Corrective Action: WCCC created a written information security program that addresses the required minimum elements. The condition was corrected by implementing the security plan and following the guidelines of the GLBA. The plan was implemented as of 12/1/23. Moving forward we will continue to monitor the requirements of GLBA.
Finding 2023-003: Student Financial Assistance Cluster Allowable Costs and Allowable Activities and Eligibility – Pell and SEOG
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster
Criteria: WCCC is required to have controls in place to ensure students receive the proper amount of student financial assistance funding they are entitled to based on financial need.
Condition: Our financial aid sample of 40 items tested yielded 28 students who received Pell Grant funding. Of those 28 students, we noted two instances where the student received Pell funding that they were not entitled to receive. The amounts awarded to the students were $506 and $568, when they were both entitled to receive $0. In addition, our Return of Title IV Funds sample of 25 yielded 16 students who received Pell Grant funding. We noted two of those students also received Pell grants over the amount they were entitled to. The amounts awarded to both students were $1,724, when they were both entitled to $862. Our Return of Title IV Funds sample of 25 also included one student who inadvertently received $500 of SEOG funds they were not eligible to receive.
Cause: Controls were not in place to ensure students received the proper amount of Student Financial Assistance they were entitled to.
Effect: WCCC is not in compliance with required calculations for student financial assistance funding. WCCC may be liable to return funds to the Department of Education related to the overpayments to students.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC review policies and procedures to ensure that proper procedures are in place verifying the accuracy of student eligibility for grant funding and that the proper amount is paid to the student based on financial need.
View of Responsible Officials and Planned Corrective Action: The findings noted three separate issues related to policies and procedures verifying the accuracy of the student eligibility for grant funding and the proper amount paid to the student based on financial need. After a review of Pell grants, Return To Title IV funds, and the award of SEOG after a return of Title IV calculation, it was determined that human error as a result of manual work was the root cause. To correct the root cause, an increased level of internal control via another level of review and a re-review of aid for the FY24 year was implemented. Further, for students who had an enrollment status of less than full time, we have increased the number of reviews for compliance. Moving forward, the College is implementing a new ERP system in which internal controls will be configured to alleviate manual work thus human error and increase compliance.
Finding 2023-004: Student Financial Assistance Cluster Special Tests and Provisions Return of Title IV Funds
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster
Criteria: In accordance with 34 CFR section 668.22, when a recipient of Title IV grant or loan assistance withdrawals during the payment period, the institution must have proper controls in place to determine the amount of Title IV aid earned by the student as of the student’s withdrawal date, and if the total amount earned is less than the amount of Title IV funds that were disbursed, the difference must be returned to the Title IV programs.
Condition: Our Return of Title IV Funds sample of 25 yielded two instances where the improper amount of Pell funding was returned to the Department of Education. These two students also received an initial grant amount higher than they were entitled to, as discussed in finding 2023-003 above. The first student was granted $1,724 when they were entitled to $862. A calculation of the Return of Title IV Funds based on them receiving $1,724 calculated that they had earned $434.51 based on their withdrawal date, and they were required to return $1,289.49. $858.42 was returned from the student’s account, causing an underpayment of $431.07. The second student was granted $1,724 when they were entitled to $862. A calculation of the Return of Title IV Funds based on them receiving $1,724 calculated that they had earned $438.82 based on their withdrawal date, and they were required to return $1,285.18. $854.11 was returned from the student’s account, causing an underpayment of $431.07.
Cause: The Title IV refunds in question resulted in incorrect returned amounts due to human error in mathematical calculations. There was not a process in place for calculations to be double-checked (reperformed) by an independent person, which would have likely caught the error prior to processing the refund payment.
Effect: Errors in mathematical calculations resulted in incorrect amounts returned by WCCC; resulting in noncompliance with 34 CFR section 668.22.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC develop a process for an independent review (including reperformance of the calculations) of the refund calculations to help catch human errors in the calculation process. It is our understanding a portion of the calculation is automated; however, WCCC should ensure initial grant amounts are correct prior to the calculation taking place.
View of Responsible Officials and Planned Corrective Action: As previously noted, the root cause was human error based on the manual processes. Similar to the previous finding, the College has implemented increased internal control through the review of the R2T4 calculations. Additionally, when using the automated functionality within the system for the return of funds calculation, an independent review of the calculation will be performed moving forward. In the future, the new ERP will increase the levels of control configured in the system.
Finding 2023-005: Student Financial Assistance Cluster Gramm-Leach-Bliley Act – Student Information Security
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster
Criteria: In accordance 16 CFR Part 314, institutions receiving Student Financial Assistance Cluster funding were required to be in compliance with the revised requirements of the Gramm-Leach-Bliley Act (GLBA) information safeguarding standards by June 9, 2023. Included in these standards is the institution’s requirement to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and includes the required elements included in 16 CFR 314.4.
Condition: The internal control system to ensure that that the program’s compliance with the requirements of the GLBA was not operating effectively. WCCC is in the process of creating a written information security program that addresses the required minimum elements; however, that written program was not in place prior to June 9, 2023.
Cause: Procedures in place to ensure WCCC was in compliance with the requirements of the GLBA were not adequate.
Effect: WCCC was not in compliance with the GLBA requirements for Student Financial Aid funds.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC implement a procedure to ensure that all required GLBA requirements are reviewed, and those requirements are included in the written information security program once it is completed.
View of Responsible Officials and Planned Corrective Action: WCCC created a written information security program that addresses the required minimum elements. The condition was corrected by implementing the security plan and following the guidelines of the GLBA. The plan was implemented as of 12/1/23. Moving forward we will continue to monitor the requirements of GLBA.
Finding 2023-003: Student Financial Assistance Cluster Allowable Costs and Allowable Activities and Eligibility – Pell and SEOG
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster
Criteria: WCCC is required to have controls in place to ensure students receive the proper amount of student financial assistance funding they are entitled to based on financial need.
Condition: Our financial aid sample of 40 items tested yielded 28 students who received Pell Grant funding. Of those 28 students, we noted two instances where the student received Pell funding that they were not entitled to receive. The amounts awarded to the students were $506 and $568, when they were both entitled to receive $0. In addition, our Return of Title IV Funds sample of 25 yielded 16 students who received Pell Grant funding. We noted two of those students also received Pell grants over the amount they were entitled to. The amounts awarded to both students were $1,724, when they were both entitled to $862. Our Return of Title IV Funds sample of 25 also included one student who inadvertently received $500 of SEOG funds they were not eligible to receive.
Cause: Controls were not in place to ensure students received the proper amount of Student Financial Assistance they were entitled to.
Effect: WCCC is not in compliance with required calculations for student financial assistance funding. WCCC may be liable to return funds to the Department of Education related to the overpayments to students.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC review policies and procedures to ensure that proper procedures are in place verifying the accuracy of student eligibility for grant funding and that the proper amount is paid to the student based on financial need.
View of Responsible Officials and Planned Corrective Action: The findings noted three separate issues related to policies and procedures verifying the accuracy of the student eligibility for grant funding and the proper amount paid to the student based on financial need. After a review of Pell grants, Return To Title IV funds, and the award of SEOG after a return of Title IV calculation, it was determined that human error as a result of manual work was the root cause. To correct the root cause, an increased level of internal control via another level of review and a re-review of aid for the FY24 year was implemented. Further, for students who had an enrollment status of less than full time, we have increased the number of reviews for compliance. Moving forward, the College is implementing a new ERP system in which internal controls will be configured to alleviate manual work thus human error and increase compliance.
Finding 2023-004: Student Financial Assistance Cluster Special Tests and Provisions Return of Title IV Funds
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster
Criteria: In accordance with 34 CFR section 668.22, when a recipient of Title IV grant or loan assistance withdrawals during the payment period, the institution must have proper controls in place to determine the amount of Title IV aid earned by the student as of the student’s withdrawal date, and if the total amount earned is less than the amount of Title IV funds that were disbursed, the difference must be returned to the Title IV programs.
Condition: Our Return of Title IV Funds sample of 25 yielded two instances where the improper amount of Pell funding was returned to the Department of Education. These two students also received an initial grant amount higher than they were entitled to, as discussed in finding 2023-003 above. The first student was granted $1,724 when they were entitled to $862. A calculation of the Return of Title IV Funds based on them receiving $1,724 calculated that they had earned $434.51 based on their withdrawal date, and they were required to return $1,289.49. $858.42 was returned from the student’s account, causing an underpayment of $431.07. The second student was granted $1,724 when they were entitled to $862. A calculation of the Return of Title IV Funds based on them receiving $1,724 calculated that they had earned $438.82 based on their withdrawal date, and they were required to return $1,285.18. $854.11 was returned from the student’s account, causing an underpayment of $431.07.
Cause: The Title IV refunds in question resulted in incorrect returned amounts due to human error in mathematical calculations. There was not a process in place for calculations to be double-checked (reperformed) by an independent person, which would have likely caught the error prior to processing the refund payment.
Effect: Errors in mathematical calculations resulted in incorrect amounts returned by WCCC; resulting in noncompliance with 34 CFR section 668.22.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC develop a process for an independent review (including reperformance of the calculations) of the refund calculations to help catch human errors in the calculation process. It is our understanding a portion of the calculation is automated; however, WCCC should ensure initial grant amounts are correct prior to the calculation taking place.
View of Responsible Officials and Planned Corrective Action: As previously noted, the root cause was human error based on the manual processes. Similar to the previous finding, the College has implemented increased internal control through the review of the R2T4 calculations. Additionally, when using the automated functionality within the system for the return of funds calculation, an independent review of the calculation will be performed moving forward. In the future, the new ERP will increase the levels of control configured in the system.
Finding 2023-005: Student Financial Assistance Cluster Gramm-Leach-Bliley Act – Student Information Security
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster
Criteria: In accordance 16 CFR Part 314, institutions receiving Student Financial Assistance Cluster funding were required to be in compliance with the revised requirements of the Gramm-Leach-Bliley Act (GLBA) information safeguarding standards by June 9, 2023. Included in these standards is the institution’s requirement to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and includes the required elements included in 16 CFR 314.4.
Condition: The internal control system to ensure that that the program’s compliance with the requirements of the GLBA was not operating effectively. WCCC is in the process of creating a written information security program that addresses the required minimum elements; however, that written program was not in place prior to June 9, 2023.
Cause: Procedures in place to ensure WCCC was in compliance with the requirements of the GLBA were not adequate.
Effect: WCCC was not in compliance with the GLBA requirements for Student Financial Aid funds.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC implement a procedure to ensure that all required GLBA requirements are reviewed, and those requirements are included in the written information security program once it is completed.
View of Responsible Officials and Planned Corrective Action: WCCC created a written information security program that addresses the required minimum elements. The condition was corrected by implementing the security plan and following the guidelines of the GLBA. The plan was implemented as of 12/1/23. Moving forward we will continue to monitor the requirements of GLBA.
Finding 2023-003: Student Financial Assistance Cluster Allowable Costs and Allowable Activities and Eligibility – Pell and SEOG
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster
Criteria: WCCC is required to have controls in place to ensure students receive the proper amount of student financial assistance funding they are entitled to based on financial need.
Condition: Our financial aid sample of 40 items tested yielded 28 students who received Pell Grant funding. Of those 28 students, we noted two instances where the student received Pell funding that they were not entitled to receive. The amounts awarded to the students were $506 and $568, when they were both entitled to receive $0. In addition, our Return of Title IV Funds sample of 25 yielded 16 students who received Pell Grant funding. We noted two of those students also received Pell grants over the amount they were entitled to. The amounts awarded to both students were $1,724, when they were both entitled to $862. Our Return of Title IV Funds sample of 25 also included one student who inadvertently received $500 of SEOG funds they were not eligible to receive.
Cause: Controls were not in place to ensure students received the proper amount of Student Financial Assistance they were entitled to.
Effect: WCCC is not in compliance with required calculations for student financial assistance funding. WCCC may be liable to return funds to the Department of Education related to the overpayments to students.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC review policies and procedures to ensure that proper procedures are in place verifying the accuracy of student eligibility for grant funding and that the proper amount is paid to the student based on financial need.
View of Responsible Officials and Planned Corrective Action: The findings noted three separate issues related to policies and procedures verifying the accuracy of the student eligibility for grant funding and the proper amount paid to the student based on financial need. After a review of Pell grants, Return To Title IV funds, and the award of SEOG after a return of Title IV calculation, it was determined that human error as a result of manual work was the root cause. To correct the root cause, an increased level of internal control via another level of review and a re-review of aid for the FY24 year was implemented. Further, for students who had an enrollment status of less than full time, we have increased the number of reviews for compliance. Moving forward, the College is implementing a new ERP system in which internal controls will be configured to alleviate manual work thus human error and increase compliance.
Finding 2023-004: Student Financial Assistance Cluster Special Tests and Provisions Return of Title IV Funds
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster
Criteria: In accordance with 34 CFR section 668.22, when a recipient of Title IV grant or loan assistance withdrawals during the payment period, the institution must have proper controls in place to determine the amount of Title IV aid earned by the student as of the student’s withdrawal date, and if the total amount earned is less than the amount of Title IV funds that were disbursed, the difference must be returned to the Title IV programs.
Condition: Our Return of Title IV Funds sample of 25 yielded two instances where the improper amount of Pell funding was returned to the Department of Education. These two students also received an initial grant amount higher than they were entitled to, as discussed in finding 2023-003 above. The first student was granted $1,724 when they were entitled to $862. A calculation of the Return of Title IV Funds based on them receiving $1,724 calculated that they had earned $434.51 based on their withdrawal date, and they were required to return $1,289.49. $858.42 was returned from the student’s account, causing an underpayment of $431.07. The second student was granted $1,724 when they were entitled to $862. A calculation of the Return of Title IV Funds based on them receiving $1,724 calculated that they had earned $438.82 based on their withdrawal date, and they were required to return $1,285.18. $854.11 was returned from the student’s account, causing an underpayment of $431.07.
Cause: The Title IV refunds in question resulted in incorrect returned amounts due to human error in mathematical calculations. There was not a process in place for calculations to be double-checked (reperformed) by an independent person, which would have likely caught the error prior to processing the refund payment.
Effect: Errors in mathematical calculations resulted in incorrect amounts returned by WCCC; resulting in noncompliance with 34 CFR section 668.22.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC develop a process for an independent review (including reperformance of the calculations) of the refund calculations to help catch human errors in the calculation process. It is our understanding a portion of the calculation is automated; however, WCCC should ensure initial grant amounts are correct prior to the calculation taking place.
View of Responsible Officials and Planned Corrective Action: As previously noted, the root cause was human error based on the manual processes. Similar to the previous finding, the College has implemented increased internal control through the review of the R2T4 calculations. Additionally, when using the automated functionality within the system for the return of funds calculation, an independent review of the calculation will be performed moving forward. In the future, the new ERP will increase the levels of control configured in the system.
Finding 2023-005: Student Financial Assistance Cluster Gramm-Leach-Bliley Act – Student Information Security
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster
Criteria: In accordance 16 CFR Part 314, institutions receiving Student Financial Assistance Cluster funding were required to be in compliance with the revised requirements of the Gramm-Leach-Bliley Act (GLBA) information safeguarding standards by June 9, 2023. Included in these standards is the institution’s requirement to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and includes the required elements included in 16 CFR 314.4.
Condition: The internal control system to ensure that that the program’s compliance with the requirements of the GLBA was not operating effectively. WCCC is in the process of creating a written information security program that addresses the required minimum elements; however, that written program was not in place prior to June 9, 2023.
Cause: Procedures in place to ensure WCCC was in compliance with the requirements of the GLBA were not adequate.
Effect: WCCC was not in compliance with the GLBA requirements for Student Financial Aid funds.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC implement a procedure to ensure that all required GLBA requirements are reviewed, and those requirements are included in the written information security program once it is completed.
View of Responsible Officials and Planned Corrective Action: WCCC created a written information security program that addresses the required minimum elements. The condition was corrected by implementing the security plan and following the guidelines of the GLBA. The plan was implemented as of 12/1/23. Moving forward we will continue to monitor the requirements of GLBA.
Finding 2023-001: 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, quarterly reports for institutional portions of the grant are to be completed and include the amounts of institutional funds spent. In addition, the annual report is to include the amount expended for both student and institutional portions of the grant and the number of students awarded student grant funds through December 31, 2022.
Condition: The internal control system to ensure that this program was fully in compliance with all reporting requirements was not operating effectively. The amount of institutional expenses reported on the quarterly reports and posted to WCCC’s website initially did not agree to the 2023 institutional funds reported on the Schedule of Expenditures of Federal Awards. Various reports, including prior year reports, were updated after being posted to WCCC’s website. WCCC was able to produce reports for all quarters of the grant period that reconciles to the institutional fund expenditures reported on the Schedule of Expenditures of Federal Awards, however, a process is not in place to ensure that the reports initially prepared and posted to WCCC’s website are accurate. The annual report also incorrectly reported the number of unduplicated students who received grant funding during calendar year 2022.
Cause: Procedures in place to ensure that the annual and quarterly reports were completed accurately were not adequate.
Effect: Westmoreland County Community College (WCCC) was not in compliance with all annual and quarterly reporting requirements.
Repeat Finding: This is a repeat finding of 2022-002.
Questioned costs: None
Recommendation: We recommend that WCCC implement a procedure to ensure that all required Education Stabilization Fund reporting is completed accurately.
View of Responsible Officials and Planned Corrective Action: All the reports were filed throughout the grant in a timely manner but not always correctly. A former employee filed these reports. Current staff have been working to get all the reports corrected and posted back to the college's web site.
The College grant writing/compliance employee unfortunately left after 1 month. WCCC continues to advertise for this position along with the Asst Controller position for Grants and Foundation.
Finding 2023-002: Education Stabilization Fund Allowable Costs and Allowable Activities
Federal Agency: Department of Education
Program: COVID-19 Education Stabilization Fund: 84.425
Criteria: The American Rescue Plan (ARP) established two required uses of the HEERF III institutional grant funds for public and private nonprofit institutions in which a portion of funds must be used to: (a) 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 HEA. This requirement was also in place for the HEERF Strengthening Institutions Program funding received by WCCC.
Condition: The internal control system to ensure WCCC’s compliance with the ARP required uses of HEERF III institutional and HEERF Strengthening Institutions Program grant funds were not operating effectively. WCCC reported on their annual reports for Years 2 and 3, encompassing the use of the aforementioned HEERF specific funds, that $0 was spent on both categories.
Cause: Controls were not in place to ensure WCCC’s compliance with the ARP allowable costs and allowable activities requirement to spend HEERF III and HEERF Strengthening Institutions funds on the above stated categories.
Effect: WCCC was not in compliance with the ARP requirements for spending a portion of HEERF III and HEERF Strengthening Institutions Program funds on the above stated categories. WCCC spent all HEERF III and HEERF Strengthening Institutions Program grant funds on revenue replacement, which is not the above stated categories.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC implement procedures to designate an individual responsible for reviewing all grant funding for allowable costs and allowable activities requirements and that the designated individual ensure that grant funding is being spent in accordance with those requirements.
View of Responsible Officials and Planned Corrective Action: WCCC continued to provide the same Covid outreach programs as they had in years one, two, and three to their Students and Employees and community.
- Vaccination clinics were continued and are still offered. However, these are at no cost to the University, student, or employee.
- Hand sanitizer, masks and other items are always available to those who require, but were paid for from prior years funds.
- When advertising for all Covid related events Westmoreland used sources which were at no cost to the College.
- The staff time to organize and manage events did not get allocated to the grant, however would have been covered under the lost revenue recognition.
Finding 2023-001: 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, quarterly reports for institutional portions of the grant are to be completed and include the amounts of institutional funds spent. In addition, the annual report is to include the amount expended for both student and institutional portions of the grant and the number of students awarded student grant funds through December 31, 2022.
Condition: The internal control system to ensure that this program was fully in compliance with all reporting requirements was not operating effectively. The amount of institutional expenses reported on the quarterly reports and posted to WCCC’s website initially did not agree to the 2023 institutional funds reported on the Schedule of Expenditures of Federal Awards. Various reports, including prior year reports, were updated after being posted to WCCC’s website. WCCC was able to produce reports for all quarters of the grant period that reconciles to the institutional fund expenditures reported on the Schedule of Expenditures of Federal Awards, however, a process is not in place to ensure that the reports initially prepared and posted to WCCC’s website are accurate. The annual report also incorrectly reported the number of unduplicated students who received grant funding during calendar year 2022.
Cause: Procedures in place to ensure that the annual and quarterly reports were completed accurately were not adequate.
Effect: Westmoreland County Community College (WCCC) was not in compliance with all annual and quarterly reporting requirements.
Repeat Finding: This is a repeat finding of 2022-002.
Questioned costs: None
Recommendation: We recommend that WCCC implement a procedure to ensure that all required Education Stabilization Fund reporting is completed accurately.
View of Responsible Officials and Planned Corrective Action: All the reports were filed throughout the grant in a timely manner but not always correctly. A former employee filed these reports. Current staff have been working to get all the reports corrected and posted back to the college's web site.
The College grant writing/compliance employee unfortunately left after 1 month. WCCC continues to advertise for this position along with the Asst Controller position for Grants and Foundation.
Finding 2023-002: Education Stabilization Fund Allowable Costs and Allowable Activities
Federal Agency: Department of Education
Program: COVID-19 Education Stabilization Fund: 84.425
Criteria: The American Rescue Plan (ARP) established two required uses of the HEERF III institutional grant funds for public and private nonprofit institutions in which a portion of funds must be used to: (a) 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 HEA. This requirement was also in place for the HEERF Strengthening Institutions Program funding received by WCCC.
Condition: The internal control system to ensure WCCC’s compliance with the ARP required uses of HEERF III institutional and HEERF Strengthening Institutions Program grant funds were not operating effectively. WCCC reported on their annual reports for Years 2 and 3, encompassing the use of the aforementioned HEERF specific funds, that $0 was spent on both categories.
Cause: Controls were not in place to ensure WCCC’s compliance with the ARP allowable costs and allowable activities requirement to spend HEERF III and HEERF Strengthening Institutions funds on the above stated categories.
Effect: WCCC was not in compliance with the ARP requirements for spending a portion of HEERF III and HEERF Strengthening Institutions Program funds on the above stated categories. WCCC spent all HEERF III and HEERF Strengthening Institutions Program grant funds on revenue replacement, which is not the above stated categories.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC implement procedures to designate an individual responsible for reviewing all grant funding for allowable costs and allowable activities requirements and that the designated individual ensure that grant funding is being spent in accordance with those requirements.
View of Responsible Officials and Planned Corrective Action: WCCC continued to provide the same Covid outreach programs as they had in years one, two, and three to their Students and Employees and community.
- Vaccination clinics were continued and are still offered. However, these are at no cost to the University, student, or employee.
- Hand sanitizer, masks and other items are always available to those who require, but were paid for from prior years funds.
- When advertising for all Covid related events Westmoreland used sources which were at no cost to the College.
- The staff time to organize and manage events did not get allocated to the grant, however would have been covered under the lost revenue recognition.
Finding 2023-001: 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, quarterly reports for institutional portions of the grant are to be completed and include the amounts of institutional funds spent. In addition, the annual report is to include the amount expended for both student and institutional portions of the grant and the number of students awarded student grant funds through December 31, 2022.
Condition: The internal control system to ensure that this program was fully in compliance with all reporting requirements was not operating effectively. The amount of institutional expenses reported on the quarterly reports and posted to WCCC’s website initially did not agree to the 2023 institutional funds reported on the Schedule of Expenditures of Federal Awards. Various reports, including prior year reports, were updated after being posted to WCCC’s website. WCCC was able to produce reports for all quarters of the grant period that reconciles to the institutional fund expenditures reported on the Schedule of Expenditures of Federal Awards, however, a process is not in place to ensure that the reports initially prepared and posted to WCCC’s website are accurate. The annual report also incorrectly reported the number of unduplicated students who received grant funding during calendar year 2022.
Cause: Procedures in place to ensure that the annual and quarterly reports were completed accurately were not adequate.
Effect: Westmoreland County Community College (WCCC) was not in compliance with all annual and quarterly reporting requirements.
Repeat Finding: This is a repeat finding of 2022-002.
Questioned costs: None
Recommendation: We recommend that WCCC implement a procedure to ensure that all required Education Stabilization Fund reporting is completed accurately.
View of Responsible Officials and Planned Corrective Action: All the reports were filed throughout the grant in a timely manner but not always correctly. A former employee filed these reports. Current staff have been working to get all the reports corrected and posted back to the college's web site.
The College grant writing/compliance employee unfortunately left after 1 month. WCCC continues to advertise for this position along with the Asst Controller position for Grants and Foundation.
Finding 2023-002: Education Stabilization Fund Allowable Costs and Allowable Activities
Federal Agency: Department of Education
Program: COVID-19 Education Stabilization Fund: 84.425
Criteria: The American Rescue Plan (ARP) established two required uses of the HEERF III institutional grant funds for public and private nonprofit institutions in which a portion of funds must be used to: (a) 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 HEA. This requirement was also in place for the HEERF Strengthening Institutions Program funding received by WCCC.
Condition: The internal control system to ensure WCCC’s compliance with the ARP required uses of HEERF III institutional and HEERF Strengthening Institutions Program grant funds were not operating effectively. WCCC reported on their annual reports for Years 2 and 3, encompassing the use of the aforementioned HEERF specific funds, that $0 was spent on both categories.
Cause: Controls were not in place to ensure WCCC’s compliance with the ARP allowable costs and allowable activities requirement to spend HEERF III and HEERF Strengthening Institutions funds on the above stated categories.
Effect: WCCC was not in compliance with the ARP requirements for spending a portion of HEERF III and HEERF Strengthening Institutions Program funds on the above stated categories. WCCC spent all HEERF III and HEERF Strengthening Institutions Program grant funds on revenue replacement, which is not the above stated categories.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC implement procedures to designate an individual responsible for reviewing all grant funding for allowable costs and allowable activities requirements and that the designated individual ensure that grant funding is being spent in accordance with those requirements.
View of Responsible Officials and Planned Corrective Action: WCCC continued to provide the same Covid outreach programs as they had in years one, two, and three to their Students and Employees and community.
- Vaccination clinics were continued and are still offered. However, these are at no cost to the University, student, or employee.
- Hand sanitizer, masks and other items are always available to those who require, but were paid for from prior years funds.
- When advertising for all Covid related events Westmoreland used sources which were at no cost to the College.
- The staff time to organize and manage events did not get allocated to the grant, however would have been covered under the lost revenue recognition.
Finding 2023-001: 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, quarterly reports for institutional portions of the grant are to be completed and include the amounts of institutional funds spent. In addition, the annual report is to include the amount expended for both student and institutional portions of the grant and the number of students awarded student grant funds through December 31, 2022.
Condition: The internal control system to ensure that this program was fully in compliance with all reporting requirements was not operating effectively. The amount of institutional expenses reported on the quarterly reports and posted to WCCC’s website initially did not agree to the 2023 institutional funds reported on the Schedule of Expenditures of Federal Awards. Various reports, including prior year reports, were updated after being posted to WCCC’s website. WCCC was able to produce reports for all quarters of the grant period that reconciles to the institutional fund expenditures reported on the Schedule of Expenditures of Federal Awards, however, a process is not in place to ensure that the reports initially prepared and posted to WCCC’s website are accurate. The annual report also incorrectly reported the number of unduplicated students who received grant funding during calendar year 2022.
Cause: Procedures in place to ensure that the annual and quarterly reports were completed accurately were not adequate.
Effect: Westmoreland County Community College (WCCC) was not in compliance with all annual and quarterly reporting requirements.
Repeat Finding: This is a repeat finding of 2022-002.
Questioned costs: None
Recommendation: We recommend that WCCC implement a procedure to ensure that all required Education Stabilization Fund reporting is completed accurately.
View of Responsible Officials and Planned Corrective Action: All the reports were filed throughout the grant in a timely manner but not always correctly. A former employee filed these reports. Current staff have been working to get all the reports corrected and posted back to the college's web site.
The College grant writing/compliance employee unfortunately left after 1 month. WCCC continues to advertise for this position along with the Asst Controller position for Grants and Foundation.
Finding 2023-002: Education Stabilization Fund Allowable Costs and Allowable Activities
Federal Agency: Department of Education
Program: COVID-19 Education Stabilization Fund: 84.425
Criteria: The American Rescue Plan (ARP) established two required uses of the HEERF III institutional grant funds for public and private nonprofit institutions in which a portion of funds must be used to: (a) 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 HEA. This requirement was also in place for the HEERF Strengthening Institutions Program funding received by WCCC.
Condition: The internal control system to ensure WCCC’s compliance with the ARP required uses of HEERF III institutional and HEERF Strengthening Institutions Program grant funds were not operating effectively. WCCC reported on their annual reports for Years 2 and 3, encompassing the use of the aforementioned HEERF specific funds, that $0 was spent on both categories.
Cause: Controls were not in place to ensure WCCC’s compliance with the ARP allowable costs and allowable activities requirement to spend HEERF III and HEERF Strengthening Institutions funds on the above stated categories.
Effect: WCCC was not in compliance with the ARP requirements for spending a portion of HEERF III and HEERF Strengthening Institutions Program funds on the above stated categories. WCCC spent all HEERF III and HEERF Strengthening Institutions Program grant funds on revenue replacement, which is not the above stated categories.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC implement procedures to designate an individual responsible for reviewing all grant funding for allowable costs and allowable activities requirements and that the designated individual ensure that grant funding is being spent in accordance with those requirements.
View of Responsible Officials and Planned Corrective Action: WCCC continued to provide the same Covid outreach programs as they had in years one, two, and three to their Students and Employees and community.
- Vaccination clinics were continued and are still offered. However, these are at no cost to the University, student, or employee.
- Hand sanitizer, masks and other items are always available to those who require, but were paid for from prior years funds.
- When advertising for all Covid related events Westmoreland used sources which were at no cost to the College.
- The staff time to organize and manage events did not get allocated to the grant, however would have been covered under the lost revenue recognition.
Finding 2023-003: Student Financial Assistance Cluster Allowable Costs and Allowable Activities and Eligibility – Pell and SEOG
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster
Criteria: WCCC is required to have controls in place to ensure students receive the proper amount of student financial assistance funding they are entitled to based on financial need.
Condition: Our financial aid sample of 40 items tested yielded 28 students who received Pell Grant funding. Of those 28 students, we noted two instances where the student received Pell funding that they were not entitled to receive. The amounts awarded to the students were $506 and $568, when they were both entitled to receive $0. In addition, our Return of Title IV Funds sample of 25 yielded 16 students who received Pell Grant funding. We noted two of those students also received Pell grants over the amount they were entitled to. The amounts awarded to both students were $1,724, when they were both entitled to $862. Our Return of Title IV Funds sample of 25 also included one student who inadvertently received $500 of SEOG funds they were not eligible to receive.
Cause: Controls were not in place to ensure students received the proper amount of Student Financial Assistance they were entitled to.
Effect: WCCC is not in compliance with required calculations for student financial assistance funding. WCCC may be liable to return funds to the Department of Education related to the overpayments to students.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC review policies and procedures to ensure that proper procedures are in place verifying the accuracy of student eligibility for grant funding and that the proper amount is paid to the student based on financial need.
View of Responsible Officials and Planned Corrective Action: The findings noted three separate issues related to policies and procedures verifying the accuracy of the student eligibility for grant funding and the proper amount paid to the student based on financial need. After a review of Pell grants, Return To Title IV funds, and the award of SEOG after a return of Title IV calculation, it was determined that human error as a result of manual work was the root cause. To correct the root cause, an increased level of internal control via another level of review and a re-review of aid for the FY24 year was implemented. Further, for students who had an enrollment status of less than full time, we have increased the number of reviews for compliance. Moving forward, the College is implementing a new ERP system in which internal controls will be configured to alleviate manual work thus human error and increase compliance.
Finding 2023-004: Student Financial Assistance Cluster Special Tests and Provisions Return of Title IV Funds
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster
Criteria: In accordance with 34 CFR section 668.22, when a recipient of Title IV grant or loan assistance withdrawals during the payment period, the institution must have proper controls in place to determine the amount of Title IV aid earned by the student as of the student’s withdrawal date, and if the total amount earned is less than the amount of Title IV funds that were disbursed, the difference must be returned to the Title IV programs.
Condition: Our Return of Title IV Funds sample of 25 yielded two instances where the improper amount of Pell funding was returned to the Department of Education. These two students also received an initial grant amount higher than they were entitled to, as discussed in finding 2023-003 above. The first student was granted $1,724 when they were entitled to $862. A calculation of the Return of Title IV Funds based on them receiving $1,724 calculated that they had earned $434.51 based on their withdrawal date, and they were required to return $1,289.49. $858.42 was returned from the student’s account, causing an underpayment of $431.07. The second student was granted $1,724 when they were entitled to $862. A calculation of the Return of Title IV Funds based on them receiving $1,724 calculated that they had earned $438.82 based on their withdrawal date, and they were required to return $1,285.18. $854.11 was returned from the student’s account, causing an underpayment of $431.07.
Cause: The Title IV refunds in question resulted in incorrect returned amounts due to human error in mathematical calculations. There was not a process in place for calculations to be double-checked (reperformed) by an independent person, which would have likely caught the error prior to processing the refund payment.
Effect: Errors in mathematical calculations resulted in incorrect amounts returned by WCCC; resulting in noncompliance with 34 CFR section 668.22.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC develop a process for an independent review (including reperformance of the calculations) of the refund calculations to help catch human errors in the calculation process. It is our understanding a portion of the calculation is automated; however, WCCC should ensure initial grant amounts are correct prior to the calculation taking place.
View of Responsible Officials and Planned Corrective Action: As previously noted, the root cause was human error based on the manual processes. Similar to the previous finding, the College has implemented increased internal control through the review of the R2T4 calculations. Additionally, when using the automated functionality within the system for the return of funds calculation, an independent review of the calculation will be performed moving forward. In the future, the new ERP will increase the levels of control configured in the system.
Finding 2023-005: Student Financial Assistance Cluster Gramm-Leach-Bliley Act – Student Information Security
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster
Criteria: In accordance 16 CFR Part 314, institutions receiving Student Financial Assistance Cluster funding were required to be in compliance with the revised requirements of the Gramm-Leach-Bliley Act (GLBA) information safeguarding standards by June 9, 2023. Included in these standards is the institution’s requirement to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and includes the required elements included in 16 CFR 314.4.
Condition: The internal control system to ensure that that the program’s compliance with the requirements of the GLBA was not operating effectively. WCCC is in the process of creating a written information security program that addresses the required minimum elements; however, that written program was not in place prior to June 9, 2023.
Cause: Procedures in place to ensure WCCC was in compliance with the requirements of the GLBA were not adequate.
Effect: WCCC was not in compliance with the GLBA requirements for Student Financial Aid funds.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC implement a procedure to ensure that all required GLBA requirements are reviewed, and those requirements are included in the written information security program once it is completed.
View of Responsible Officials and Planned Corrective Action: WCCC created a written information security program that addresses the required minimum elements. The condition was corrected by implementing the security plan and following the guidelines of the GLBA. The plan was implemented as of 12/1/23. Moving forward we will continue to monitor the requirements of GLBA.
Finding 2023-003: Student Financial Assistance Cluster Allowable Costs and Allowable Activities and Eligibility – Pell and SEOG
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster
Criteria: WCCC is required to have controls in place to ensure students receive the proper amount of student financial assistance funding they are entitled to based on financial need.
Condition: Our financial aid sample of 40 items tested yielded 28 students who received Pell Grant funding. Of those 28 students, we noted two instances where the student received Pell funding that they were not entitled to receive. The amounts awarded to the students were $506 and $568, when they were both entitled to receive $0. In addition, our Return of Title IV Funds sample of 25 yielded 16 students who received Pell Grant funding. We noted two of those students also received Pell grants over the amount they were entitled to. The amounts awarded to both students were $1,724, when they were both entitled to $862. Our Return of Title IV Funds sample of 25 also included one student who inadvertently received $500 of SEOG funds they were not eligible to receive.
Cause: Controls were not in place to ensure students received the proper amount of Student Financial Assistance they were entitled to.
Effect: WCCC is not in compliance with required calculations for student financial assistance funding. WCCC may be liable to return funds to the Department of Education related to the overpayments to students.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC review policies and procedures to ensure that proper procedures are in place verifying the accuracy of student eligibility for grant funding and that the proper amount is paid to the student based on financial need.
View of Responsible Officials and Planned Corrective Action: The findings noted three separate issues related to policies and procedures verifying the accuracy of the student eligibility for grant funding and the proper amount paid to the student based on financial need. After a review of Pell grants, Return To Title IV funds, and the award of SEOG after a return of Title IV calculation, it was determined that human error as a result of manual work was the root cause. To correct the root cause, an increased level of internal control via another level of review and a re-review of aid for the FY24 year was implemented. Further, for students who had an enrollment status of less than full time, we have increased the number of reviews for compliance. Moving forward, the College is implementing a new ERP system in which internal controls will be configured to alleviate manual work thus human error and increase compliance.
Finding 2023-004: Student Financial Assistance Cluster Special Tests and Provisions Return of Title IV Funds
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster
Criteria: In accordance with 34 CFR section 668.22, when a recipient of Title IV grant or loan assistance withdrawals during the payment period, the institution must have proper controls in place to determine the amount of Title IV aid earned by the student as of the student’s withdrawal date, and if the total amount earned is less than the amount of Title IV funds that were disbursed, the difference must be returned to the Title IV programs.
Condition: Our Return of Title IV Funds sample of 25 yielded two instances where the improper amount of Pell funding was returned to the Department of Education. These two students also received an initial grant amount higher than they were entitled to, as discussed in finding 2023-003 above. The first student was granted $1,724 when they were entitled to $862. A calculation of the Return of Title IV Funds based on them receiving $1,724 calculated that they had earned $434.51 based on their withdrawal date, and they were required to return $1,289.49. $858.42 was returned from the student’s account, causing an underpayment of $431.07. The second student was granted $1,724 when they were entitled to $862. A calculation of the Return of Title IV Funds based on them receiving $1,724 calculated that they had earned $438.82 based on their withdrawal date, and they were required to return $1,285.18. $854.11 was returned from the student’s account, causing an underpayment of $431.07.
Cause: The Title IV refunds in question resulted in incorrect returned amounts due to human error in mathematical calculations. There was not a process in place for calculations to be double-checked (reperformed) by an independent person, which would have likely caught the error prior to processing the refund payment.
Effect: Errors in mathematical calculations resulted in incorrect amounts returned by WCCC; resulting in noncompliance with 34 CFR section 668.22.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC develop a process for an independent review (including reperformance of the calculations) of the refund calculations to help catch human errors in the calculation process. It is our understanding a portion of the calculation is automated; however, WCCC should ensure initial grant amounts are correct prior to the calculation taking place.
View of Responsible Officials and Planned Corrective Action: As previously noted, the root cause was human error based on the manual processes. Similar to the previous finding, the College has implemented increased internal control through the review of the R2T4 calculations. Additionally, when using the automated functionality within the system for the return of funds calculation, an independent review of the calculation will be performed moving forward. In the future, the new ERP will increase the levels of control configured in the system.
Finding 2023-005: Student Financial Assistance Cluster Gramm-Leach-Bliley Act – Student Information Security
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster
Criteria: In accordance 16 CFR Part 314, institutions receiving Student Financial Assistance Cluster funding were required to be in compliance with the revised requirements of the Gramm-Leach-Bliley Act (GLBA) information safeguarding standards by June 9, 2023. Included in these standards is the institution’s requirement to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and includes the required elements included in 16 CFR 314.4.
Condition: The internal control system to ensure that that the program’s compliance with the requirements of the GLBA was not operating effectively. WCCC is in the process of creating a written information security program that addresses the required minimum elements; however, that written program was not in place prior to June 9, 2023.
Cause: Procedures in place to ensure WCCC was in compliance with the requirements of the GLBA were not adequate.
Effect: WCCC was not in compliance with the GLBA requirements for Student Financial Aid funds.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC implement a procedure to ensure that all required GLBA requirements are reviewed, and those requirements are included in the written information security program once it is completed.
View of Responsible Officials and Planned Corrective Action: WCCC created a written information security program that addresses the required minimum elements. The condition was corrected by implementing the security plan and following the guidelines of the GLBA. The plan was implemented as of 12/1/23. Moving forward we will continue to monitor the requirements of GLBA.
Finding 2023-003: Student Financial Assistance Cluster Allowable Costs and Allowable Activities and Eligibility – Pell and SEOG
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster
Criteria: WCCC is required to have controls in place to ensure students receive the proper amount of student financial assistance funding they are entitled to based on financial need.
Condition: Our financial aid sample of 40 items tested yielded 28 students who received Pell Grant funding. Of those 28 students, we noted two instances where the student received Pell funding that they were not entitled to receive. The amounts awarded to the students were $506 and $568, when they were both entitled to receive $0. In addition, our Return of Title IV Funds sample of 25 yielded 16 students who received Pell Grant funding. We noted two of those students also received Pell grants over the amount they were entitled to. The amounts awarded to both students were $1,724, when they were both entitled to $862. Our Return of Title IV Funds sample of 25 also included one student who inadvertently received $500 of SEOG funds they were not eligible to receive.
Cause: Controls were not in place to ensure students received the proper amount of Student Financial Assistance they were entitled to.
Effect: WCCC is not in compliance with required calculations for student financial assistance funding. WCCC may be liable to return funds to the Department of Education related to the overpayments to students.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC review policies and procedures to ensure that proper procedures are in place verifying the accuracy of student eligibility for grant funding and that the proper amount is paid to the student based on financial need.
View of Responsible Officials and Planned Corrective Action: The findings noted three separate issues related to policies and procedures verifying the accuracy of the student eligibility for grant funding and the proper amount paid to the student based on financial need. After a review of Pell grants, Return To Title IV funds, and the award of SEOG after a return of Title IV calculation, it was determined that human error as a result of manual work was the root cause. To correct the root cause, an increased level of internal control via another level of review and a re-review of aid for the FY24 year was implemented. Further, for students who had an enrollment status of less than full time, we have increased the number of reviews for compliance. Moving forward, the College is implementing a new ERP system in which internal controls will be configured to alleviate manual work thus human error and increase compliance.
Finding 2023-004: Student Financial Assistance Cluster Special Tests and Provisions Return of Title IV Funds
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster
Criteria: In accordance with 34 CFR section 668.22, when a recipient of Title IV grant or loan assistance withdrawals during the payment period, the institution must have proper controls in place to determine the amount of Title IV aid earned by the student as of the student’s withdrawal date, and if the total amount earned is less than the amount of Title IV funds that were disbursed, the difference must be returned to the Title IV programs.
Condition: Our Return of Title IV Funds sample of 25 yielded two instances where the improper amount of Pell funding was returned to the Department of Education. These two students also received an initial grant amount higher than they were entitled to, as discussed in finding 2023-003 above. The first student was granted $1,724 when they were entitled to $862. A calculation of the Return of Title IV Funds based on them receiving $1,724 calculated that they had earned $434.51 based on their withdrawal date, and they were required to return $1,289.49. $858.42 was returned from the student’s account, causing an underpayment of $431.07. The second student was granted $1,724 when they were entitled to $862. A calculation of the Return of Title IV Funds based on them receiving $1,724 calculated that they had earned $438.82 based on their withdrawal date, and they were required to return $1,285.18. $854.11 was returned from the student’s account, causing an underpayment of $431.07.
Cause: The Title IV refunds in question resulted in incorrect returned amounts due to human error in mathematical calculations. There was not a process in place for calculations to be double-checked (reperformed) by an independent person, which would have likely caught the error prior to processing the refund payment.
Effect: Errors in mathematical calculations resulted in incorrect amounts returned by WCCC; resulting in noncompliance with 34 CFR section 668.22.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC develop a process for an independent review (including reperformance of the calculations) of the refund calculations to help catch human errors in the calculation process. It is our understanding a portion of the calculation is automated; however, WCCC should ensure initial grant amounts are correct prior to the calculation taking place.
View of Responsible Officials and Planned Corrective Action: As previously noted, the root cause was human error based on the manual processes. Similar to the previous finding, the College has implemented increased internal control through the review of the R2T4 calculations. Additionally, when using the automated functionality within the system for the return of funds calculation, an independent review of the calculation will be performed moving forward. In the future, the new ERP will increase the levels of control configured in the system.
Finding 2023-005: Student Financial Assistance Cluster Gramm-Leach-Bliley Act – Student Information Security
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster
Criteria: In accordance 16 CFR Part 314, institutions receiving Student Financial Assistance Cluster funding were required to be in compliance with the revised requirements of the Gramm-Leach-Bliley Act (GLBA) information safeguarding standards by June 9, 2023. Included in these standards is the institution’s requirement to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and includes the required elements included in 16 CFR 314.4.
Condition: The internal control system to ensure that that the program’s compliance with the requirements of the GLBA was not operating effectively. WCCC is in the process of creating a written information security program that addresses the required minimum elements; however, that written program was not in place prior to June 9, 2023.
Cause: Procedures in place to ensure WCCC was in compliance with the requirements of the GLBA were not adequate.
Effect: WCCC was not in compliance with the GLBA requirements for Student Financial Aid funds.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC implement a procedure to ensure that all required GLBA requirements are reviewed, and those requirements are included in the written information security program once it is completed.
View of Responsible Officials and Planned Corrective Action: WCCC created a written information security program that addresses the required minimum elements. The condition was corrected by implementing the security plan and following the guidelines of the GLBA. The plan was implemented as of 12/1/23. Moving forward we will continue to monitor the requirements of GLBA.
Finding 2023-003: Student Financial Assistance Cluster Allowable Costs and Allowable Activities and Eligibility – Pell and SEOG
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster
Criteria: WCCC is required to have controls in place to ensure students receive the proper amount of student financial assistance funding they are entitled to based on financial need.
Condition: Our financial aid sample of 40 items tested yielded 28 students who received Pell Grant funding. Of those 28 students, we noted two instances where the student received Pell funding that they were not entitled to receive. The amounts awarded to the students were $506 and $568, when they were both entitled to receive $0. In addition, our Return of Title IV Funds sample of 25 yielded 16 students who received Pell Grant funding. We noted two of those students also received Pell grants over the amount they were entitled to. The amounts awarded to both students were $1,724, when they were both entitled to $862. Our Return of Title IV Funds sample of 25 also included one student who inadvertently received $500 of SEOG funds they were not eligible to receive.
Cause: Controls were not in place to ensure students received the proper amount of Student Financial Assistance they were entitled to.
Effect: WCCC is not in compliance with required calculations for student financial assistance funding. WCCC may be liable to return funds to the Department of Education related to the overpayments to students.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC review policies and procedures to ensure that proper procedures are in place verifying the accuracy of student eligibility for grant funding and that the proper amount is paid to the student based on financial need.
View of Responsible Officials and Planned Corrective Action: The findings noted three separate issues related to policies and procedures verifying the accuracy of the student eligibility for grant funding and the proper amount paid to the student based on financial need. After a review of Pell grants, Return To Title IV funds, and the award of SEOG after a return of Title IV calculation, it was determined that human error as a result of manual work was the root cause. To correct the root cause, an increased level of internal control via another level of review and a re-review of aid for the FY24 year was implemented. Further, for students who had an enrollment status of less than full time, we have increased the number of reviews for compliance. Moving forward, the College is implementing a new ERP system in which internal controls will be configured to alleviate manual work thus human error and increase compliance.
Finding 2023-004: Student Financial Assistance Cluster Special Tests and Provisions Return of Title IV Funds
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster
Criteria: In accordance with 34 CFR section 668.22, when a recipient of Title IV grant or loan assistance withdrawals during the payment period, the institution must have proper controls in place to determine the amount of Title IV aid earned by the student as of the student’s withdrawal date, and if the total amount earned is less than the amount of Title IV funds that were disbursed, the difference must be returned to the Title IV programs.
Condition: Our Return of Title IV Funds sample of 25 yielded two instances where the improper amount of Pell funding was returned to the Department of Education. These two students also received an initial grant amount higher than they were entitled to, as discussed in finding 2023-003 above. The first student was granted $1,724 when they were entitled to $862. A calculation of the Return of Title IV Funds based on them receiving $1,724 calculated that they had earned $434.51 based on their withdrawal date, and they were required to return $1,289.49. $858.42 was returned from the student’s account, causing an underpayment of $431.07. The second student was granted $1,724 when they were entitled to $862. A calculation of the Return of Title IV Funds based on them receiving $1,724 calculated that they had earned $438.82 based on their withdrawal date, and they were required to return $1,285.18. $854.11 was returned from the student’s account, causing an underpayment of $431.07.
Cause: The Title IV refunds in question resulted in incorrect returned amounts due to human error in mathematical calculations. There was not a process in place for calculations to be double-checked (reperformed) by an independent person, which would have likely caught the error prior to processing the refund payment.
Effect: Errors in mathematical calculations resulted in incorrect amounts returned by WCCC; resulting in noncompliance with 34 CFR section 668.22.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC develop a process for an independent review (including reperformance of the calculations) of the refund calculations to help catch human errors in the calculation process. It is our understanding a portion of the calculation is automated; however, WCCC should ensure initial grant amounts are correct prior to the calculation taking place.
View of Responsible Officials and Planned Corrective Action: As previously noted, the root cause was human error based on the manual processes. Similar to the previous finding, the College has implemented increased internal control through the review of the R2T4 calculations. Additionally, when using the automated functionality within the system for the return of funds calculation, an independent review of the calculation will be performed moving forward. In the future, the new ERP will increase the levels of control configured in the system.
Finding 2023-005: Student Financial Assistance Cluster Gramm-Leach-Bliley Act – Student Information Security
Federal Agency: Department of Education
Program: Student Financial Assistance Cluster
Criteria: In accordance 16 CFR Part 314, institutions receiving Student Financial Assistance Cluster funding were required to be in compliance with the revised requirements of the Gramm-Leach-Bliley Act (GLBA) information safeguarding standards by June 9, 2023. Included in these standards is the institution’s requirement to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and includes the required elements included in 16 CFR 314.4.
Condition: The internal control system to ensure that that the program’s compliance with the requirements of the GLBA was not operating effectively. WCCC is in the process of creating a written information security program that addresses the required minimum elements; however, that written program was not in place prior to June 9, 2023.
Cause: Procedures in place to ensure WCCC was in compliance with the requirements of the GLBA were not adequate.
Effect: WCCC was not in compliance with the GLBA requirements for Student Financial Aid funds.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC implement a procedure to ensure that all required GLBA requirements are reviewed, and those requirements are included in the written information security program once it is completed.
View of Responsible Officials and Planned Corrective Action: WCCC created a written information security program that addresses the required minimum elements. The condition was corrected by implementing the security plan and following the guidelines of the GLBA. The plan was implemented as of 12/1/23. Moving forward we will continue to monitor the requirements of GLBA.
Finding 2023-001: 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, quarterly reports for institutional portions of the grant are to be completed and include the amounts of institutional funds spent. In addition, the annual report is to include the amount expended for both student and institutional portions of the grant and the number of students awarded student grant funds through December 31, 2022.
Condition: The internal control system to ensure that this program was fully in compliance with all reporting requirements was not operating effectively. The amount of institutional expenses reported on the quarterly reports and posted to WCCC’s website initially did not agree to the 2023 institutional funds reported on the Schedule of Expenditures of Federal Awards. Various reports, including prior year reports, were updated after being posted to WCCC’s website. WCCC was able to produce reports for all quarters of the grant period that reconciles to the institutional fund expenditures reported on the Schedule of Expenditures of Federal Awards, however, a process is not in place to ensure that the reports initially prepared and posted to WCCC’s website are accurate. The annual report also incorrectly reported the number of unduplicated students who received grant funding during calendar year 2022.
Cause: Procedures in place to ensure that the annual and quarterly reports were completed accurately were not adequate.
Effect: Westmoreland County Community College (WCCC) was not in compliance with all annual and quarterly reporting requirements.
Repeat Finding: This is a repeat finding of 2022-002.
Questioned costs: None
Recommendation: We recommend that WCCC implement a procedure to ensure that all required Education Stabilization Fund reporting is completed accurately.
View of Responsible Officials and Planned Corrective Action: All the reports were filed throughout the grant in a timely manner but not always correctly. A former employee filed these reports. Current staff have been working to get all the reports corrected and posted back to the college's web site.
The College grant writing/compliance employee unfortunately left after 1 month. WCCC continues to advertise for this position along with the Asst Controller position for Grants and Foundation.
Finding 2023-002: Education Stabilization Fund Allowable Costs and Allowable Activities
Federal Agency: Department of Education
Program: COVID-19 Education Stabilization Fund: 84.425
Criteria: The American Rescue Plan (ARP) established two required uses of the HEERF III institutional grant funds for public and private nonprofit institutions in which a portion of funds must be used to: (a) 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 HEA. This requirement was also in place for the HEERF Strengthening Institutions Program funding received by WCCC.
Condition: The internal control system to ensure WCCC’s compliance with the ARP required uses of HEERF III institutional and HEERF Strengthening Institutions Program grant funds were not operating effectively. WCCC reported on their annual reports for Years 2 and 3, encompassing the use of the aforementioned HEERF specific funds, that $0 was spent on both categories.
Cause: Controls were not in place to ensure WCCC’s compliance with the ARP allowable costs and allowable activities requirement to spend HEERF III and HEERF Strengthening Institutions funds on the above stated categories.
Effect: WCCC was not in compliance with the ARP requirements for spending a portion of HEERF III and HEERF Strengthening Institutions Program funds on the above stated categories. WCCC spent all HEERF III and HEERF Strengthening Institutions Program grant funds on revenue replacement, which is not the above stated categories.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC implement procedures to designate an individual responsible for reviewing all grant funding for allowable costs and allowable activities requirements and that the designated individual ensure that grant funding is being spent in accordance with those requirements.
View of Responsible Officials and Planned Corrective Action: WCCC continued to provide the same Covid outreach programs as they had in years one, two, and three to their Students and Employees and community.
- Vaccination clinics were continued and are still offered. However, these are at no cost to the University, student, or employee.
- Hand sanitizer, masks and other items are always available to those who require, but were paid for from prior years funds.
- When advertising for all Covid related events Westmoreland used sources which were at no cost to the College.
- The staff time to organize and manage events did not get allocated to the grant, however would have been covered under the lost revenue recognition.
Finding 2023-001: 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, quarterly reports for institutional portions of the grant are to be completed and include the amounts of institutional funds spent. In addition, the annual report is to include the amount expended for both student and institutional portions of the grant and the number of students awarded student grant funds through December 31, 2022.
Condition: The internal control system to ensure that this program was fully in compliance with all reporting requirements was not operating effectively. The amount of institutional expenses reported on the quarterly reports and posted to WCCC’s website initially did not agree to the 2023 institutional funds reported on the Schedule of Expenditures of Federal Awards. Various reports, including prior year reports, were updated after being posted to WCCC’s website. WCCC was able to produce reports for all quarters of the grant period that reconciles to the institutional fund expenditures reported on the Schedule of Expenditures of Federal Awards, however, a process is not in place to ensure that the reports initially prepared and posted to WCCC’s website are accurate. The annual report also incorrectly reported the number of unduplicated students who received grant funding during calendar year 2022.
Cause: Procedures in place to ensure that the annual and quarterly reports were completed accurately were not adequate.
Effect: Westmoreland County Community College (WCCC) was not in compliance with all annual and quarterly reporting requirements.
Repeat Finding: This is a repeat finding of 2022-002.
Questioned costs: None
Recommendation: We recommend that WCCC implement a procedure to ensure that all required Education Stabilization Fund reporting is completed accurately.
View of Responsible Officials and Planned Corrective Action: All the reports were filed throughout the grant in a timely manner but not always correctly. A former employee filed these reports. Current staff have been working to get all the reports corrected and posted back to the college's web site.
The College grant writing/compliance employee unfortunately left after 1 month. WCCC continues to advertise for this position along with the Asst Controller position for Grants and Foundation.
Finding 2023-002: Education Stabilization Fund Allowable Costs and Allowable Activities
Federal Agency: Department of Education
Program: COVID-19 Education Stabilization Fund: 84.425
Criteria: The American Rescue Plan (ARP) established two required uses of the HEERF III institutional grant funds for public and private nonprofit institutions in which a portion of funds must be used to: (a) 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 HEA. This requirement was also in place for the HEERF Strengthening Institutions Program funding received by WCCC.
Condition: The internal control system to ensure WCCC’s compliance with the ARP required uses of HEERF III institutional and HEERF Strengthening Institutions Program grant funds were not operating effectively. WCCC reported on their annual reports for Years 2 and 3, encompassing the use of the aforementioned HEERF specific funds, that $0 was spent on both categories.
Cause: Controls were not in place to ensure WCCC’s compliance with the ARP allowable costs and allowable activities requirement to spend HEERF III and HEERF Strengthening Institutions funds on the above stated categories.
Effect: WCCC was not in compliance with the ARP requirements for spending a portion of HEERF III and HEERF Strengthening Institutions Program funds on the above stated categories. WCCC spent all HEERF III and HEERF Strengthening Institutions Program grant funds on revenue replacement, which is not the above stated categories.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC implement procedures to designate an individual responsible for reviewing all grant funding for allowable costs and allowable activities requirements and that the designated individual ensure that grant funding is being spent in accordance with those requirements.
View of Responsible Officials and Planned Corrective Action: WCCC continued to provide the same Covid outreach programs as they had in years one, two, and three to their Students and Employees and community.
- Vaccination clinics were continued and are still offered. However, these are at no cost to the University, student, or employee.
- Hand sanitizer, masks and other items are always available to those who require, but were paid for from prior years funds.
- When advertising for all Covid related events Westmoreland used sources which were at no cost to the College.
- The staff time to organize and manage events did not get allocated to the grant, however would have been covered under the lost revenue recognition.
Finding 2023-001: 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, quarterly reports for institutional portions of the grant are to be completed and include the amounts of institutional funds spent. In addition, the annual report is to include the amount expended for both student and institutional portions of the grant and the number of students awarded student grant funds through December 31, 2022.
Condition: The internal control system to ensure that this program was fully in compliance with all reporting requirements was not operating effectively. The amount of institutional expenses reported on the quarterly reports and posted to WCCC’s website initially did not agree to the 2023 institutional funds reported on the Schedule of Expenditures of Federal Awards. Various reports, including prior year reports, were updated after being posted to WCCC’s website. WCCC was able to produce reports for all quarters of the grant period that reconciles to the institutional fund expenditures reported on the Schedule of Expenditures of Federal Awards, however, a process is not in place to ensure that the reports initially prepared and posted to WCCC’s website are accurate. The annual report also incorrectly reported the number of unduplicated students who received grant funding during calendar year 2022.
Cause: Procedures in place to ensure that the annual and quarterly reports were completed accurately were not adequate.
Effect: Westmoreland County Community College (WCCC) was not in compliance with all annual and quarterly reporting requirements.
Repeat Finding: This is a repeat finding of 2022-002.
Questioned costs: None
Recommendation: We recommend that WCCC implement a procedure to ensure that all required Education Stabilization Fund reporting is completed accurately.
View of Responsible Officials and Planned Corrective Action: All the reports were filed throughout the grant in a timely manner but not always correctly. A former employee filed these reports. Current staff have been working to get all the reports corrected and posted back to the college's web site.
The College grant writing/compliance employee unfortunately left after 1 month. WCCC continues to advertise for this position along with the Asst Controller position for Grants and Foundation.
Finding 2023-002: Education Stabilization Fund Allowable Costs and Allowable Activities
Federal Agency: Department of Education
Program: COVID-19 Education Stabilization Fund: 84.425
Criteria: The American Rescue Plan (ARP) established two required uses of the HEERF III institutional grant funds for public and private nonprofit institutions in which a portion of funds must be used to: (a) 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 HEA. This requirement was also in place for the HEERF Strengthening Institutions Program funding received by WCCC.
Condition: The internal control system to ensure WCCC’s compliance with the ARP required uses of HEERF III institutional and HEERF Strengthening Institutions Program grant funds were not operating effectively. WCCC reported on their annual reports for Years 2 and 3, encompassing the use of the aforementioned HEERF specific funds, that $0 was spent on both categories.
Cause: Controls were not in place to ensure WCCC’s compliance with the ARP allowable costs and allowable activities requirement to spend HEERF III and HEERF Strengthening Institutions funds on the above stated categories.
Effect: WCCC was not in compliance with the ARP requirements for spending a portion of HEERF III and HEERF Strengthening Institutions Program funds on the above stated categories. WCCC spent all HEERF III and HEERF Strengthening Institutions Program grant funds on revenue replacement, which is not the above stated categories.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC implement procedures to designate an individual responsible for reviewing all grant funding for allowable costs and allowable activities requirements and that the designated individual ensure that grant funding is being spent in accordance with those requirements.
View of Responsible Officials and Planned Corrective Action: WCCC continued to provide the same Covid outreach programs as they had in years one, two, and three to their Students and Employees and community.
- Vaccination clinics were continued and are still offered. However, these are at no cost to the University, student, or employee.
- Hand sanitizer, masks and other items are always available to those who require, but were paid for from prior years funds.
- When advertising for all Covid related events Westmoreland used sources which were at no cost to the College.
- The staff time to organize and manage events did not get allocated to the grant, however would have been covered under the lost revenue recognition.
Finding 2023-001: 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, quarterly reports for institutional portions of the grant are to be completed and include the amounts of institutional funds spent. In addition, the annual report is to include the amount expended for both student and institutional portions of the grant and the number of students awarded student grant funds through December 31, 2022.
Condition: The internal control system to ensure that this program was fully in compliance with all reporting requirements was not operating effectively. The amount of institutional expenses reported on the quarterly reports and posted to WCCC’s website initially did not agree to the 2023 institutional funds reported on the Schedule of Expenditures of Federal Awards. Various reports, including prior year reports, were updated after being posted to WCCC’s website. WCCC was able to produce reports for all quarters of the grant period that reconciles to the institutional fund expenditures reported on the Schedule of Expenditures of Federal Awards, however, a process is not in place to ensure that the reports initially prepared and posted to WCCC’s website are accurate. The annual report also incorrectly reported the number of unduplicated students who received grant funding during calendar year 2022.
Cause: Procedures in place to ensure that the annual and quarterly reports were completed accurately were not adequate.
Effect: Westmoreland County Community College (WCCC) was not in compliance with all annual and quarterly reporting requirements.
Repeat Finding: This is a repeat finding of 2022-002.
Questioned costs: None
Recommendation: We recommend that WCCC implement a procedure to ensure that all required Education Stabilization Fund reporting is completed accurately.
View of Responsible Officials and Planned Corrective Action: All the reports were filed throughout the grant in a timely manner but not always correctly. A former employee filed these reports. Current staff have been working to get all the reports corrected and posted back to the college's web site.
The College grant writing/compliance employee unfortunately left after 1 month. WCCC continues to advertise for this position along with the Asst Controller position for Grants and Foundation.
Finding 2023-002: Education Stabilization Fund Allowable Costs and Allowable Activities
Federal Agency: Department of Education
Program: COVID-19 Education Stabilization Fund: 84.425
Criteria: The American Rescue Plan (ARP) established two required uses of the HEERF III institutional grant funds for public and private nonprofit institutions in which a portion of funds must be used to: (a) 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 HEA. This requirement was also in place for the HEERF Strengthening Institutions Program funding received by WCCC.
Condition: The internal control system to ensure WCCC’s compliance with the ARP required uses of HEERF III institutional and HEERF Strengthening Institutions Program grant funds were not operating effectively. WCCC reported on their annual reports for Years 2 and 3, encompassing the use of the aforementioned HEERF specific funds, that $0 was spent on both categories.
Cause: Controls were not in place to ensure WCCC’s compliance with the ARP allowable costs and allowable activities requirement to spend HEERF III and HEERF Strengthening Institutions funds on the above stated categories.
Effect: WCCC was not in compliance with the ARP requirements for spending a portion of HEERF III and HEERF Strengthening Institutions Program funds on the above stated categories. WCCC spent all HEERF III and HEERF Strengthening Institutions Program grant funds on revenue replacement, which is not the above stated categories.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC implement procedures to designate an individual responsible for reviewing all grant funding for allowable costs and allowable activities requirements and that the designated individual ensure that grant funding is being spent in accordance with those requirements.
View of Responsible Officials and Planned Corrective Action: WCCC continued to provide the same Covid outreach programs as they had in years one, two, and three to their Students and Employees and community.
- Vaccination clinics were continued and are still offered. However, these are at no cost to the University, student, or employee.
- Hand sanitizer, masks and other items are always available to those who require, but were paid for from prior years funds.
- When advertising for all Covid related events Westmoreland used sources which were at no cost to the College.
- The staff time to organize and manage events did not get allocated to the grant, however would have been covered under the lost revenue recognition.