Audit 299996

Criteria There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the CRRSAA 314(e) require an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. ED required an annual report from HEERF grantees to be filed in March 2023 that included reporting uses of HEERF I CARES Act funds, HEERF II CRRSAA funds, and HEERF III ARP funds for the 2022 calendar year. Additionally, beginning with the second quarter of 2022 quarterly report, institutions were required to complete and post on their websites a combined institutional and student reporting form. This form was required to be conspicuously posted on the institutions’ website no later than 10 days after the calendar quarter (January 10, April 10, July 10, October 10) as long as the institution’s HEERF grant was active. Further, in accordance with 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During the year ended June 30, 2023, the College did not publish its quarterly reporting on the College's website within the 10-day compliance requirement for the quarters ending, March 31, 2023 and June 30, 2023. Cause The College’s HEERF reporting process did not include a control designed to monitor the timeliness and accuracy of the required reporting in either of the two prior years (2021 and 2022). This was noted as a finding in both 2022 (2022-002) and 2021 (2021-001). Although the College drafted a corrective action plan in March 2023 that included implementation of a control designed to monitor the timeliness and accuracy of the required reporting, due to employee turnover, the control was not implemented prior to June 30, 2023. Effect If appropriate controls are not designed and operating effectively over the HEERF reporting process, HEERF expenditures reported on the College’s website may be incomplete, inaccurate, or not posted within the timeframe required. Questioned Costs None noted. Statistical Sampling The sample was not intended to be and was not a statistically valid sample. Prior Year Finding Yes – 2022-002 Recommendation We recommend that the College implement a more thorough and detailed process and related internal controls to ensure timely and accurate reporting required under its Federal programs. Management’s Views Subsequent to June 30, 2023, management has reviewed its reporting requirements under its Federal programs and implemented controls to ensure accuracy and timeliness of required reporting. In prior years, there has been high employee turnover in the business office, now that staffing has stabilized, the College has implemented new general controls over all federal funding received. For future funds, the Senior Accountant will be responsible for the receipt and disbursement of federal funds, and for monitoring reporting requirements. Additionally, the Associate Vice President for Finance and Controller will oversee the process and ensure that spending guidelines are followed and that all deadlines for reporting are met. Anticipated Completion Date Completed – December 15, 2023 Responsible Person Heather Martinez, Associate Vice President for Finance and Controller

Criteria There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the CRRSAA 314(e) require an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. ED required an annual report from HEERF grantees to be filed in March 2023 that included reporting uses of HEERF I CARES Act funds, HEERF II CRRSAA funds, and HEERF III ARP funds for the 2022 calendar year. Additionally, beginning with the second quarter of 2022 quarterly report, institutions were required to complete and post on their websites a combined institutional and student reporting form. This form was required to be conspicuously posted on the institutions’ website no later than 10 days after the calendar quarter (January 10, April 10, July 10, October 10) as long as the institution’s HEERF grant was active. Further, in accordance with 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During the year ended June 30, 2023, the College did not publish its quarterly reporting on the College's website within the 10-day compliance requirement for the quarters ending, March 31, 2023 and June 30, 2023. Cause The College’s HEERF reporting process did not include a control designed to monitor the timeliness and accuracy of the required reporting in either of the two prior years (2021 and 2022). This was noted as a finding in both 2022 (2022-002) and 2021 (2021-001). Although the College drafted a corrective action plan in March 2023 that included implementation of a control designed to monitor the timeliness and accuracy of the required reporting, due to employee turnover, the control was not implemented prior to June 30, 2023. Effect If appropriate controls are not designed and operating effectively over the HEERF reporting process, HEERF expenditures reported on the College’s website may be incomplete, inaccurate, or not posted within the timeframe required. Questioned Costs None noted. Statistical Sampling The sample was not intended to be and was not a statistically valid sample. Prior Year Finding Yes – 2022-002 Recommendation We recommend that the College implement a more thorough and detailed process and related internal controls to ensure timely and accurate reporting required under its Federal programs. Management’s Views Subsequent to June 30, 2023, management has reviewed its reporting requirements under its Federal programs and implemented controls to ensure accuracy and timeliness of required reporting. In prior years, there has been high employee turnover in the business office, now that staffing has stabilized, the College has implemented new general controls over all federal funding received. For future funds, the Senior Accountant will be responsible for the receipt and disbursement of federal funds, and for monitoring reporting requirements. Additionally, the Associate Vice President for Finance and Controller will oversee the process and ensure that spending guidelines are followed and that all deadlines for reporting are met. Anticipated Completion Date Completed – December 15, 2023 Responsible Person Heather Martinez, Associate Vice President for Finance and Controller