Audit 301247

FY End
2022-06-30
Total Expended
$60.93M
Findings
2
Programs
8
Organization: Adrian College (MI)
Year: 2022 Accepted: 2024-03-30

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
390463 2022-002 Material Weakness - L
966905 2022-002 Material Weakness - L

Programs

ALN Program Spent Major Findings
10.766 Community Facilities Loans and Grants $38.97M Yes 1
84.268 Federal Direct Student Loans $12.38M Yes 0
84.063 Federal Pell Grant Program $2.59M Yes 0
84.425 Covid-19 - Education Stabilization Fund $2.18M Yes 0
84.038 Federal Perkins Loan Program $1.72M Yes 0
84.007 Federal Supplemental Educational Opportunity Grants $264,006 Yes 0
84.042 Trio_student Support Services $220,840 - 0
84.033 Federal Work-Study Program $199,976 Yes 0

Contacts

Name Title Type
J248CHZUAND3 Jerry Wright Auditee
5172643856 Ashley Schade Auditor
No contacts on file

Notes to SEFA

Title: Federal Perkins Loan Program Accounting Policies: The accompanying schedule of expenditures of federal awards (the “Schedule”) includes the federal grant activity of Adrian College (the “College”) under programs of the federal government for the year ended June 30, 2022. The information in the Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the “Uniform Guidance”). Because the Schedule presents only a selected portion of the operations of the College, it is not intended to and does not present the financial position, changes in net position, or cash flows of the College. Expenditures reported in the Schedule are reported on the same basis of accounting as the basic financial statements. Such expenditures are recognized following the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The pass through entity identifying numbers are presented where available. The College has elected not to use the 10 percent de minimis indirect cost rate to recover indirect costs, as allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: The Organization has elected not to use the 10 percent de minimis indirect cost rate to recover indirect costs, as allowed under the Uniform Guidance. The outstanding balance on the Federal Perkins Loan Program at June 30, 2022 is $999,349. The federal expenditures presented in the Schedule related to the Federal Perkins Loan Program consist of the following amounts for the fiscal year ended June 30, 2022: See the Notes to the SEFA for table.
Title: Federal Direct Student Loans Accounting Policies: The accompanying schedule of expenditures of federal awards (the “Schedule”) includes the federal grant activity of Adrian College (the “College”) under programs of the federal government for the year ended June 30, 2022. The information in the Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the “Uniform Guidance”). Because the Schedule presents only a selected portion of the operations of the College, it is not intended to and does not present the financial position, changes in net position, or cash flows of the College. Expenditures reported in the Schedule are reported on the same basis of accounting as the basic financial statements. Such expenditures are recognized following the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The pass through entity identifying numbers are presented where available. The College has elected not to use the 10 percent de minimis indirect cost rate to recover indirect costs, as allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: The Organization has elected not to use the 10 percent de minimis indirect cost rate to recover indirect costs, as allowed under the Uniform Guidance. The College acts as an intermediary for students receiving Federal Direct Student Loans (ALN 84.268), which include Direct Loans and Parent Loans for Undergraduate Students, from the federal government. The federal government is responsible for billings and collections of the loans. The College assists the federal government by processing the applications and applying the funds to student accounts from the federal government. Since this program is administered by the federal government, new loans made in the fiscal year ended June 30, 2022 related to Federal Direct Student Loans are considered current year federal expenditures, whereas the outstanding loan balances are not.
Title: Community Facilities Loan Accounting Policies: The accompanying schedule of expenditures of federal awards (the “Schedule”) includes the federal grant activity of Adrian College (the “College”) under programs of the federal government for the year ended June 30, 2022. The information in the Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the “Uniform Guidance”). Because the Schedule presents only a selected portion of the operations of the College, it is not intended to and does not present the financial position, changes in net position, or cash flows of the College. Expenditures reported in the Schedule are reported on the same basis of accounting as the basic financial statements. Such expenditures are recognized following the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The pass through entity identifying numbers are presented where available. The College has elected not to use the 10 percent de minimis indirect cost rate to recover indirect costs, as allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: The Organization has elected not to use the 10 percent de minimis indirect cost rate to recover indirect costs, as allowed under the Uniform Guidance. Loans entered into during the year are included in the federal expenditures presented in the schedule of expenditures of federal awards. There were no outstanding loans as of July 1, 2021. The balance of loans outstanding at June 30, 2022 equals the amount reported on the schedule of expenditures of federal awards of $38,970,352.

Finding Details

Assistance Listing, Federal Agency, and Program Name - ALN 10.766, Department of Agriculture, Community Facilities Loans and Grants Federal Award Identification Number and Year - N/A Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Prior to issuance of the 2022 Compliance Supplement the USDA instructed borrowers that loans under ALN 10.766 did not have continuing compliance requirements and thus were not required to be audited under 2 CFR Part 200 Subpart F in the years after project completion. However, with the issuance of the 2022 Compliance Supplement the USDA changed this position and determined these loans have continuing compliance requirements and thus are subject to audit under 2 CFR Part 200 Subpart F. Condition - The schedule of expenditures of federal awards (SEFA) as originally issued did not include loans with continuing compliance requirements. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Prior to the June 30, 2022 fiscal year end, the USDA did not classify loans outstanding under ALN 10.766 as having continuing compliance requirements. The USDA changed its position and began treating these loans as having continuing compliance and issued a notice to loan recipients that they must report the loan balances on their schedule of expenditures of federal awards beginning with fiscal years ending June 30, 2022. The College did not identify this change in policy and incorrectly excluded the loan entered into during the year ($38,970,352) from the originally issued schedule of expenditures of federal awards. Cause and Effect - Controls in place did not ensure the SEFA was complete and accurate. The resulting error had the following impact: $38,970,352 received under ALN 10.766 was excluded from the total expenditures reported on the SEFA, resulting in the initial major program determination being incorrect. Recommendation - The College should implement process to ensure that the SEFA is complete and accurate. Views of Responsible Officials and Corrective Action Plan - In December 2023 management identified that with its participation as borrower on a Community Facilities Loan, guaranteed by the USDA, that it had a compliance obligation to include the loan program in the SEFA. The College has designed and implemented controls that require the VP of Business Affairs (or designee) to identify new and modified compliance and reporting obligations under the currently enrolled programs or for any new programs in which the College may participate.
Assistance Listing, Federal Agency, and Program Name - ALN 10.766, Department of Agriculture, Community Facilities Loans and Grants Federal Award Identification Number and Year - N/A Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Prior to issuance of the 2022 Compliance Supplement the USDA instructed borrowers that loans under ALN 10.766 did not have continuing compliance requirements and thus were not required to be audited under 2 CFR Part 200 Subpart F in the years after project completion. However, with the issuance of the 2022 Compliance Supplement the USDA changed this position and determined these loans have continuing compliance requirements and thus are subject to audit under 2 CFR Part 200 Subpart F. Condition - The schedule of expenditures of federal awards (SEFA) as originally issued did not include loans with continuing compliance requirements. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Prior to the June 30, 2022 fiscal year end, the USDA did not classify loans outstanding under ALN 10.766 as having continuing compliance requirements. The USDA changed its position and began treating these loans as having continuing compliance and issued a notice to loan recipients that they must report the loan balances on their schedule of expenditures of federal awards beginning with fiscal years ending June 30, 2022. The College did not identify this change in policy and incorrectly excluded the loan entered into during the year ($38,970,352) from the originally issued schedule of expenditures of federal awards. Cause and Effect - Controls in place did not ensure the SEFA was complete and accurate. The resulting error had the following impact: $38,970,352 received under ALN 10.766 was excluded from the total expenditures reported on the SEFA, resulting in the initial major program determination being incorrect. Recommendation - The College should implement process to ensure that the SEFA is complete and accurate. Views of Responsible Officials and Corrective Action Plan - In December 2023 management identified that with its participation as borrower on a Community Facilities Loan, guaranteed by the USDA, that it had a compliance obligation to include the loan program in the SEFA. The College has designed and implemented controls that require the VP of Business Affairs (or designee) to identify new and modified compliance and reporting obligations under the currently enrolled programs or for any new programs in which the College may participate.