2022-011 ? Procurement ? Small Purchases ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College did not apply the correct micro purchase threshold and were not obtaining quotes for purchases that should have been subjected to the small purchase threshold. The population between $10k and $20k that were improperly treated as micro purchases consisted of four transactions totaling $50,373. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. Questioned Costs - Not applicable. Effect - The College may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. Cause - The College adopted to follow the NM Procurement Policy in 2018 but failed to update its policy employees still followed with incorrect threshold for micro purchases.
2022-012 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Material Weakness and Material Noncompliance Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - For nine of nine salaried employees tested, there was no time and effort documentation provided for the period under review. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1)(vii) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed, which includes support for the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. In addition, 2 CFR 200.430(i)(1)(viii) indicates that budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that (B) significant changes in the corresponding work activity are identified and entered into the records in a timely manner. Short term fluctuations between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) the non-federal entity?s system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.In addition, the College?s grant fiscal management guide requires bi-annual reviews of time and effort certifications and related reports pertaining to split allocations of personnel charges, including the allocation of fringe benefits, will be conducted and maintained for all federal awards by the Compliance Officer. Questioned Costs - Not applicable. Effect - The College could over allocate payroll costs to a particular grant in which the employee did not participate. Cause - The College could not locate the time and effort certifications for the employees selected due to transitions within the payroll and the grant monitoring functions.
2022-013 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - During our review of payroll related transactions, the following were noted. ? For one of 25 payroll transactions tested, the supervisor did not sign the timesheet. ? For one of 25 payroll transactions tested, the employee?s contract was not updated as of July 1, 2021 to the correct salary amount. Therefore, the employee was underpaid a total of $475.29 during the fiscal year. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (i) be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; and (ii) be incorporated into the official records of the non-federal entity. Questioned Costs - Not applicable. Effect - The College may unintentionally overpay or underpay employees during their fiscal year. Cause - The College could not locate payroll records due to transition within the payroll and HR departments. In addition, the unsigned timesheet was overlooked.
2022-010 ? Equipment and Real Property Management ? Material Weakness Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College was not able to provide an equipment listing tracking items purchased with federal funding nor did the College conduct a physical inventory.Criteria - Per 2 CFR 200.313(d)(2), a physical inventory of program property must be taken and the results reconciled with the property records at least once every 2 years and per 2 CFR 200.303(a) states that the non-Federal entity 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. Questioned Costs - Not applicable. Effect - The College could dispose of or lose federally funded equipment without following federal guidelines. Cause - The College does not have policies and procedures to ensure that equipment purchases with federal funds is maintained and tracked and that the College performing a physical inventory at a minimum of every two years.
2022-011 ? Procurement ? Small Purchases ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College did not apply the correct micro purchase threshold and were not obtaining quotes for purchases that should have been subjected to the small purchase threshold. The population between $10k and $20k that were improperly treated as micro purchases consisted of four transactions totaling $50,373. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. Questioned Costs - Not applicable. Effect - The College may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. Cause - The College adopted to follow the NM Procurement Policy in 2018 but failed to update its policy employees still followed with incorrect threshold for micro purchases.
2022-012 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Material Weakness and Material Noncompliance Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - For nine of nine salaried employees tested, there was no time and effort documentation provided for the period under review. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1)(vii) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed, which includes support for the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. In addition, 2 CFR 200.430(i)(1)(viii) indicates that budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that (B) significant changes in the corresponding work activity are identified and entered into the records in a timely manner. Short term fluctuations between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) the non-federal entity?s system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.In addition, the College?s grant fiscal management guide requires bi-annual reviews of time and effort certifications and related reports pertaining to split allocations of personnel charges, including the allocation of fringe benefits, will be conducted and maintained for all federal awards by the Compliance Officer. Questioned Costs - Not applicable. Effect - The College could over allocate payroll costs to a particular grant in which the employee did not participate. Cause - The College could not locate the time and effort certifications for the employees selected due to transitions within the payroll and the grant monitoring functions.
2022-013 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - During our review of payroll related transactions, the following were noted. ? For one of 25 payroll transactions tested, the supervisor did not sign the timesheet. ? For one of 25 payroll transactions tested, the employee?s contract was not updated as of July 1, 2021 to the correct salary amount. Therefore, the employee was underpaid a total of $475.29 during the fiscal year. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (i) be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; and (ii) be incorporated into the official records of the non-federal entity. Questioned Costs - Not applicable. Effect - The College may unintentionally overpay or underpay employees during their fiscal year. Cause - The College could not locate payroll records due to transition within the payroll and HR departments. In addition, the unsigned timesheet was overlooked.
2022-010 ? Equipment and Real Property Management ? Material Weakness Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College was not able to provide an equipment listing tracking items purchased with federal funding nor did the College conduct a physical inventory.Criteria - Per 2 CFR 200.313(d)(2), a physical inventory of program property must be taken and the results reconciled with the property records at least once every 2 years and per 2 CFR 200.303(a) states that the non-Federal entity 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. Questioned Costs - Not applicable. Effect - The College could dispose of or lose federally funded equipment without following federal guidelines. Cause - The College does not have policies and procedures to ensure that equipment purchases with federal funds is maintained and tracked and that the College performing a physical inventory at a minimum of every two years.
2022-011 ? Procurement ? Small Purchases ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College did not apply the correct micro purchase threshold and were not obtaining quotes for purchases that should have been subjected to the small purchase threshold. The population between $10k and $20k that were improperly treated as micro purchases consisted of four transactions totaling $50,373. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. Questioned Costs - Not applicable. Effect - The College may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. Cause - The College adopted to follow the NM Procurement Policy in 2018 but failed to update its policy employees still followed with incorrect threshold for micro purchases.
2022-012 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Material Weakness and Material Noncompliance Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - For nine of nine salaried employees tested, there was no time and effort documentation provided for the period under review. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1)(vii) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed, which includes support for the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. In addition, 2 CFR 200.430(i)(1)(viii) indicates that budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that (B) significant changes in the corresponding work activity are identified and entered into the records in a timely manner. Short term fluctuations between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) the non-federal entity?s system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.In addition, the College?s grant fiscal management guide requires bi-annual reviews of time and effort certifications and related reports pertaining to split allocations of personnel charges, including the allocation of fringe benefits, will be conducted and maintained for all federal awards by the Compliance Officer. Questioned Costs - Not applicable. Effect - The College could over allocate payroll costs to a particular grant in which the employee did not participate. Cause - The College could not locate the time and effort certifications for the employees selected due to transitions within the payroll and the grant monitoring functions.
2022-013 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - During our review of payroll related transactions, the following were noted. ? For one of 25 payroll transactions tested, the supervisor did not sign the timesheet. ? For one of 25 payroll transactions tested, the employee?s contract was not updated as of July 1, 2021 to the correct salary amount. Therefore, the employee was underpaid a total of $475.29 during the fiscal year. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (i) be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; and (ii) be incorporated into the official records of the non-federal entity. Questioned Costs - Not applicable. Effect - The College may unintentionally overpay or underpay employees during their fiscal year. Cause - The College could not locate payroll records due to transition within the payroll and HR departments. In addition, the unsigned timesheet was overlooked.
2022-010 ? Equipment and Real Property Management ? Material Weakness Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College was not able to provide an equipment listing tracking items purchased with federal funding nor did the College conduct a physical inventory.Criteria - Per 2 CFR 200.313(d)(2), a physical inventory of program property must be taken and the results reconciled with the property records at least once every 2 years and per 2 CFR 200.303(a) states that the non-Federal entity 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. Questioned Costs - Not applicable. Effect - The College could dispose of or lose federally funded equipment without following federal guidelines. Cause - The College does not have policies and procedures to ensure that equipment purchases with federal funds is maintained and tracked and that the College performing a physical inventory at a minimum of every two years.
2022-011 ? Procurement ? Small Purchases ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College did not apply the correct micro purchase threshold and were not obtaining quotes for purchases that should have been subjected to the small purchase threshold. The population between $10k and $20k that were improperly treated as micro purchases consisted of four transactions totaling $50,373. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. Questioned Costs - Not applicable. Effect - The College may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. Cause - The College adopted to follow the NM Procurement Policy in 2018 but failed to update its policy employees still followed with incorrect threshold for micro purchases.
2022-012 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Material Weakness and Material Noncompliance Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - For nine of nine salaried employees tested, there was no time and effort documentation provided for the period under review. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1)(vii) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed, which includes support for the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. In addition, 2 CFR 200.430(i)(1)(viii) indicates that budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that (B) significant changes in the corresponding work activity are identified and entered into the records in a timely manner. Short term fluctuations between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) the non-federal entity?s system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.In addition, the College?s grant fiscal management guide requires bi-annual reviews of time and effort certifications and related reports pertaining to split allocations of personnel charges, including the allocation of fringe benefits, will be conducted and maintained for all federal awards by the Compliance Officer. Questioned Costs - Not applicable. Effect - The College could over allocate payroll costs to a particular grant in which the employee did not participate. Cause - The College could not locate the time and effort certifications for the employees selected due to transitions within the payroll and the grant monitoring functions.
2022-013 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - During our review of payroll related transactions, the following were noted. ? For one of 25 payroll transactions tested, the supervisor did not sign the timesheet. ? For one of 25 payroll transactions tested, the employee?s contract was not updated as of July 1, 2021 to the correct salary amount. Therefore, the employee was underpaid a total of $475.29 during the fiscal year. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (i) be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; and (ii) be incorporated into the official records of the non-federal entity. Questioned Costs - Not applicable. Effect - The College may unintentionally overpay or underpay employees during their fiscal year. Cause - The College could not locate payroll records due to transition within the payroll and HR departments. In addition, the unsigned timesheet was overlooked.
2022-010 ? Equipment and Real Property Management ? Material Weakness Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College was not able to provide an equipment listing tracking items purchased with federal funding nor did the College conduct a physical inventory.Criteria - Per 2 CFR 200.313(d)(2), a physical inventory of program property must be taken and the results reconciled with the property records at least once every 2 years and per 2 CFR 200.303(a) states that the non-Federal entity 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. Questioned Costs - Not applicable. Effect - The College could dispose of or lose federally funded equipment without following federal guidelines. Cause - The College does not have policies and procedures to ensure that equipment purchases with federal funds is maintained and tracked and that the College performing a physical inventory at a minimum of every two years.
2022-011 ? Procurement ? Small Purchases ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College did not apply the correct micro purchase threshold and were not obtaining quotes for purchases that should have been subjected to the small purchase threshold. The population between $10k and $20k that were improperly treated as micro purchases consisted of four transactions totaling $50,373. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. Questioned Costs - Not applicable. Effect - The College may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. Cause - The College adopted to follow the NM Procurement Policy in 2018 but failed to update its policy employees still followed with incorrect threshold for micro purchases.
2022-012 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Material Weakness and Material Noncompliance Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - For nine of nine salaried employees tested, there was no time and effort documentation provided for the period under review. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1)(vii) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed, which includes support for the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. In addition, 2 CFR 200.430(i)(1)(viii) indicates that budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that (B) significant changes in the corresponding work activity are identified and entered into the records in a timely manner. Short term fluctuations between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) the non-federal entity?s system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.In addition, the College?s grant fiscal management guide requires bi-annual reviews of time and effort certifications and related reports pertaining to split allocations of personnel charges, including the allocation of fringe benefits, will be conducted and maintained for all federal awards by the Compliance Officer. Questioned Costs - Not applicable. Effect - The College could over allocate payroll costs to a particular grant in which the employee did not participate. Cause - The College could not locate the time and effort certifications for the employees selected due to transitions within the payroll and the grant monitoring functions.
2022-013 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - During our review of payroll related transactions, the following were noted. ? For one of 25 payroll transactions tested, the supervisor did not sign the timesheet. ? For one of 25 payroll transactions tested, the employee?s contract was not updated as of July 1, 2021 to the correct salary amount. Therefore, the employee was underpaid a total of $475.29 during the fiscal year. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (i) be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; and (ii) be incorporated into the official records of the non-federal entity. Questioned Costs - Not applicable. Effect - The College may unintentionally overpay or underpay employees during their fiscal year. Cause - The College could not locate payroll records due to transition within the payroll and HR departments. In addition, the unsigned timesheet was overlooked.
2022-009 (2021-008) ? Special Reporting ? Quarterly Reporting ? Significant Deficiency (Modified and Repeated) Federal Program Information Funding Agency: U.S. Department of Education Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425E, 84.425F, and 84.425L Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - Two Quarterly Public Reports for the student portion did not contain dates reports were posted to verify timeliness nor was there support of documentation reviewed and compared prior to posting. Criteria - Per 2 CFR 200.303(a), an entity must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the entity is managing the Federal awards in compliance with statutes, regulations, and the terms and conditions of the award. The CARES Act establishing the Education Stabilization Fund required that reports be publically posted on the institution?s website for the Student Aid and Institutional portions of the Higher Education Emergency Relief Fund (HEERF). The forms must be conspicuously posted on the College?s primary website at certain dates throughout the year.Questioned Costs - Not applicable. Effect - Lack of proper review for accuracy and timeliness of reports can result in improper reporting which could lead to disallowed costs. However, our audit disclosed no instances of unallowable costs. Cause - The College did not have sufficient controls in place to review and approve reports ensuring accuracy and timeliness in accordance with HEERF reporting requirements.
2022-009 (2021-008) ? Special Reporting ? Quarterly Reporting ? Significant Deficiency (Modified and Repeated) Federal Program Information Funding Agency: U.S. Department of Education Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425E, 84.425F, and 84.425L Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - Two Quarterly Public Reports for the student portion did not contain dates reports were posted to verify timeliness nor was there support of documentation reviewed and compared prior to posting. Criteria - Per 2 CFR 200.303(a), an entity must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the entity is managing the Federal awards in compliance with statutes, regulations, and the terms and conditions of the award. The CARES Act establishing the Education Stabilization Fund required that reports be publically posted on the institution?s website for the Student Aid and Institutional portions of the Higher Education Emergency Relief Fund (HEERF). The forms must be conspicuously posted on the College?s primary website at certain dates throughout the year.Questioned Costs - Not applicable. Effect - Lack of proper review for accuracy and timeliness of reports can result in improper reporting which could lead to disallowed costs. However, our audit disclosed no instances of unallowable costs. Cause - The College did not have sufficient controls in place to review and approve reports ensuring accuracy and timeliness in accordance with HEERF reporting requirements.
2022-009 (2021-008) ? Special Reporting ? Quarterly Reporting ? Significant Deficiency (Modified and Repeated) Federal Program Information Funding Agency: U.S. Department of Education Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425E, 84.425F, and 84.425L Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - Two Quarterly Public Reports for the student portion did not contain dates reports were posted to verify timeliness nor was there support of documentation reviewed and compared prior to posting. Criteria - Per 2 CFR 200.303(a), an entity must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the entity is managing the Federal awards in compliance with statutes, regulations, and the terms and conditions of the award. The CARES Act establishing the Education Stabilization Fund required that reports be publically posted on the institution?s website for the Student Aid and Institutional portions of the Higher Education Emergency Relief Fund (HEERF). The forms must be conspicuously posted on the College?s primary website at certain dates throughout the year.Questioned Costs - Not applicable. Effect - Lack of proper review for accuracy and timeliness of reports can result in improper reporting which could lead to disallowed costs. However, our audit disclosed no instances of unallowable costs. Cause - The College did not have sufficient controls in place to review and approve reports ensuring accuracy and timeliness in accordance with HEERF reporting requirements.
2022-007 (2021-005) ? Special Tests and Provisions ? Enrollment Reporting ? Material Weakness and Material Noncompliance (Modified and Repeated) Federal Program Information Funding Agency: U.S. Department of Education Federal Award Agreement Number: Not Applicable Award Year: All Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College does not have effective controls over this compliance requirement, which resulted in the College not notifying the Department of Education and NSLDS of changes in student status in a timely and accurate manner. We noted the following instances of noncompliance: ? For nine of 60 students tested, the Student had status information included in Banner but no information was included on the NSLDS report. ? For one of 60 students tested, the student?s program on the NSLDS report did not match that listed in Banner. ? For one of 60 students tested, the student?s degree type on the NSLDS report did not match that listed in Banner. ? For 24 of 60 students tested, the student?s time status on the NSLDS report did not match that listed in Banner. ? For 51 of 60 students tested, the roster was not submitted within 15 days.As noted in the prior year audit management response, the College did not anticipate this finding would be resolved during fiscal year 2022 as they did not know of the issue until late into the fiscal year. Criteria - Per 2 CFR 200.303(a), an entity must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the entity is managing the Federal awards in compliance with statutes, regulations, and the terms and conditions of the award. In addition, the Department of Education relies on institution?s enrollments reports to determine a student?s enrollment status based on reductions or increases in attendance levels, withdrawals, graduations or approved leaves-of-absence. According to 34 CFR 690.83(b)(2) and 685.309, the College is required to submit changes in student attendance to the National Student Loan Data System (NSLDS) at a minimum of every 60 days. Questioned Costs - Not applicable. Effect - This resulted in inaccurate enrollment reporting during the year, which may cause a student?s status to be incorrect for extended periods of time. As a result, the College did not promptly notify Department of Education, lenders, or NSLDS of changes in student status in a timely and accurate manner. Cause - The College did not have controls in place to help follow the appropriate procedures in accordance with enrollment reporting requirements.
2022-008 ? Special Tests and Provisions ? Return of Title IV Funds ? Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Education Federal Award Agreement Number: Not Applicable Award Year: All Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College does not have effective controls over this compliance requirement, which resulted in four students out of five tested having enrollment dates not matching in two different areas in Banner (SFAWDRL and ROAENRL), and 2 out of 5 students tested did not have professors update the last attendance date. In addition, one of five students tested had an amount due of $594.38 for the school to return to ED, which was not listed in Banner as paid back. Criteria - Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entity 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per Title 34 US Code of Federal Regulations Part 668.173 Refund reserve standards (b) timely return of title IV funds, no later than 45 days after the date it was determined the student withdrew. Per Title 34 US Code of Federal Regulations Part 668.22(g), the institution must return the amount of unearned aid they are responsible as calculated and Title 2 US Code of Federal Regulations Part 668.22(j) timeframe for the return of title IV funds as soon as possible but no later than 45 days after the date the institution determined the student withdrew. Questioned Costs - $594.38 of known questioned costs and $5,867 of likely questioned costs. Effect - Failure to return title IV funds which the College was responsible for could result in noncompliance with the Refund Reserve standards of 34 CFR 668.176. Failure to return Title IV funds which the College was responsible for could result in noncompliance with the Refund Reserve standards of 34 CFR 668.176. In addition the risk of inaccurate calculation increases when enrollment data entry is inaccurately recorded.Cause ? The College is not implementing policy and procedures for the institution?s return of unearned aid timely and the enrollment dates are not consistent in Banner.
2022-007 (2021-005) ? Special Tests and Provisions ? Enrollment Reporting ? Material Weakness and Material Noncompliance (Modified and Repeated) Federal Program Information Funding Agency: U.S. Department of Education Federal Award Agreement Number: Not Applicable Award Year: All Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College does not have effective controls over this compliance requirement, which resulted in the College not notifying the Department of Education and NSLDS of changes in student status in a timely and accurate manner. We noted the following instances of noncompliance: ? For nine of 60 students tested, the Student had status information included in Banner but no information was included on the NSLDS report. ? For one of 60 students tested, the student?s program on the NSLDS report did not match that listed in Banner. ? For one of 60 students tested, the student?s degree type on the NSLDS report did not match that listed in Banner. ? For 24 of 60 students tested, the student?s time status on the NSLDS report did not match that listed in Banner. ? For 51 of 60 students tested, the roster was not submitted within 15 days.As noted in the prior year audit management response, the College did not anticipate this finding would be resolved during fiscal year 2022 as they did not know of the issue until late into the fiscal year. Criteria - Per 2 CFR 200.303(a), an entity must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the entity is managing the Federal awards in compliance with statutes, regulations, and the terms and conditions of the award. In addition, the Department of Education relies on institution?s enrollments reports to determine a student?s enrollment status based on reductions or increases in attendance levels, withdrawals, graduations or approved leaves-of-absence. According to 34 CFR 690.83(b)(2) and 685.309, the College is required to submit changes in student attendance to the National Student Loan Data System (NSLDS) at a minimum of every 60 days. Questioned Costs - Not applicable. Effect - This resulted in inaccurate enrollment reporting during the year, which may cause a student?s status to be incorrect for extended periods of time. As a result, the College did not promptly notify Department of Education, lenders, or NSLDS of changes in student status in a timely and accurate manner. Cause - The College did not have controls in place to help follow the appropriate procedures in accordance with enrollment reporting requirements.
2022-008 ? Special Tests and Provisions ? Return of Title IV Funds ? Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Education Federal Award Agreement Number: Not Applicable Award Year: All Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College does not have effective controls over this compliance requirement, which resulted in four students out of five tested having enrollment dates not matching in two different areas in Banner (SFAWDRL and ROAENRL), and 2 out of 5 students tested did not have professors update the last attendance date. In addition, one of five students tested had an amount due of $594.38 for the school to return to ED, which was not listed in Banner as paid back. Criteria - Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entity 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per Title 34 US Code of Federal Regulations Part 668.173 Refund reserve standards (b) timely return of title IV funds, no later than 45 days after the date it was determined the student withdrew. Per Title 34 US Code of Federal Regulations Part 668.22(g), the institution must return the amount of unearned aid they are responsible as calculated and Title 2 US Code of Federal Regulations Part 668.22(j) timeframe for the return of title IV funds as soon as possible but no later than 45 days after the date the institution determined the student withdrew. Questioned Costs - $594.38 of known questioned costs and $5,867 of likely questioned costs. Effect - Failure to return title IV funds which the College was responsible for could result in noncompliance with the Refund Reserve standards of 34 CFR 668.176. Failure to return Title IV funds which the College was responsible for could result in noncompliance with the Refund Reserve standards of 34 CFR 668.176. In addition the risk of inaccurate calculation increases when enrollment data entry is inaccurately recorded.Cause ? The College is not implementing policy and procedures for the institution?s return of unearned aid timely and the enrollment dates are not consistent in Banner.
2022-007 (2021-005) ? Special Tests and Provisions ? Enrollment Reporting ? Material Weakness and Material Noncompliance (Modified and Repeated) Federal Program Information Funding Agency: U.S. Department of Education Federal Award Agreement Number: Not Applicable Award Year: All Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College does not have effective controls over this compliance requirement, which resulted in the College not notifying the Department of Education and NSLDS of changes in student status in a timely and accurate manner. We noted the following instances of noncompliance: ? For nine of 60 students tested, the Student had status information included in Banner but no information was included on the NSLDS report. ? For one of 60 students tested, the student?s program on the NSLDS report did not match that listed in Banner. ? For one of 60 students tested, the student?s degree type on the NSLDS report did not match that listed in Banner. ? For 24 of 60 students tested, the student?s time status on the NSLDS report did not match that listed in Banner. ? For 51 of 60 students tested, the roster was not submitted within 15 days.As noted in the prior year audit management response, the College did not anticipate this finding would be resolved during fiscal year 2022 as they did not know of the issue until late into the fiscal year. Criteria - Per 2 CFR 200.303(a), an entity must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the entity is managing the Federal awards in compliance with statutes, regulations, and the terms and conditions of the award. In addition, the Department of Education relies on institution?s enrollments reports to determine a student?s enrollment status based on reductions or increases in attendance levels, withdrawals, graduations or approved leaves-of-absence. According to 34 CFR 690.83(b)(2) and 685.309, the College is required to submit changes in student attendance to the National Student Loan Data System (NSLDS) at a minimum of every 60 days. Questioned Costs - Not applicable. Effect - This resulted in inaccurate enrollment reporting during the year, which may cause a student?s status to be incorrect for extended periods of time. As a result, the College did not promptly notify Department of Education, lenders, or NSLDS of changes in student status in a timely and accurate manner. Cause - The College did not have controls in place to help follow the appropriate procedures in accordance with enrollment reporting requirements.
2022-008 ? Special Tests and Provisions ? Return of Title IV Funds ? Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Education Federal Award Agreement Number: Not Applicable Award Year: All Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College does not have effective controls over this compliance requirement, which resulted in four students out of five tested having enrollment dates not matching in two different areas in Banner (SFAWDRL and ROAENRL), and 2 out of 5 students tested did not have professors update the last attendance date. In addition, one of five students tested had an amount due of $594.38 for the school to return to ED, which was not listed in Banner as paid back. Criteria - Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entity 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per Title 34 US Code of Federal Regulations Part 668.173 Refund reserve standards (b) timely return of title IV funds, no later than 45 days after the date it was determined the student withdrew. Per Title 34 US Code of Federal Regulations Part 668.22(g), the institution must return the amount of unearned aid they are responsible as calculated and Title 2 US Code of Federal Regulations Part 668.22(j) timeframe for the return of title IV funds as soon as possible but no later than 45 days after the date the institution determined the student withdrew. Questioned Costs - $594.38 of known questioned costs and $5,867 of likely questioned costs. Effect - Failure to return title IV funds which the College was responsible for could result in noncompliance with the Refund Reserve standards of 34 CFR 668.176. Failure to return Title IV funds which the College was responsible for could result in noncompliance with the Refund Reserve standards of 34 CFR 668.176. In addition the risk of inaccurate calculation increases when enrollment data entry is inaccurately recorded.Cause ? The College is not implementing policy and procedures for the institution?s return of unearned aid timely and the enrollment dates are not consistent in Banner.
2022-007 (2021-005) ? Special Tests and Provisions ? Enrollment Reporting ? Material Weakness and Material Noncompliance (Modified and Repeated) Federal Program Information Funding Agency: U.S. Department of Education Federal Award Agreement Number: Not Applicable Award Year: All Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College does not have effective controls over this compliance requirement, which resulted in the College not notifying the Department of Education and NSLDS of changes in student status in a timely and accurate manner. We noted the following instances of noncompliance: ? For nine of 60 students tested, the Student had status information included in Banner but no information was included on the NSLDS report. ? For one of 60 students tested, the student?s program on the NSLDS report did not match that listed in Banner. ? For one of 60 students tested, the student?s degree type on the NSLDS report did not match that listed in Banner. ? For 24 of 60 students tested, the student?s time status on the NSLDS report did not match that listed in Banner. ? For 51 of 60 students tested, the roster was not submitted within 15 days.As noted in the prior year audit management response, the College did not anticipate this finding would be resolved during fiscal year 2022 as they did not know of the issue until late into the fiscal year. Criteria - Per 2 CFR 200.303(a), an entity must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the entity is managing the Federal awards in compliance with statutes, regulations, and the terms and conditions of the award. In addition, the Department of Education relies on institution?s enrollments reports to determine a student?s enrollment status based on reductions or increases in attendance levels, withdrawals, graduations or approved leaves-of-absence. According to 34 CFR 690.83(b)(2) and 685.309, the College is required to submit changes in student attendance to the National Student Loan Data System (NSLDS) at a minimum of every 60 days. Questioned Costs - Not applicable. Effect - This resulted in inaccurate enrollment reporting during the year, which may cause a student?s status to be incorrect for extended periods of time. As a result, the College did not promptly notify Department of Education, lenders, or NSLDS of changes in student status in a timely and accurate manner. Cause - The College did not have controls in place to help follow the appropriate procedures in accordance with enrollment reporting requirements.
2022-008 ? Special Tests and Provisions ? Return of Title IV Funds ? Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Education Federal Award Agreement Number: Not Applicable Award Year: All Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College does not have effective controls over this compliance requirement, which resulted in four students out of five tested having enrollment dates not matching in two different areas in Banner (SFAWDRL and ROAENRL), and 2 out of 5 students tested did not have professors update the last attendance date. In addition, one of five students tested had an amount due of $594.38 for the school to return to ED, which was not listed in Banner as paid back. Criteria - Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entity 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per Title 34 US Code of Federal Regulations Part 668.173 Refund reserve standards (b) timely return of title IV funds, no later than 45 days after the date it was determined the student withdrew. Per Title 34 US Code of Federal Regulations Part 668.22(g), the institution must return the amount of unearned aid they are responsible as calculated and Title 2 US Code of Federal Regulations Part 668.22(j) timeframe for the return of title IV funds as soon as possible but no later than 45 days after the date the institution determined the student withdrew. Questioned Costs - $594.38 of known questioned costs and $5,867 of likely questioned costs. Effect - Failure to return title IV funds which the College was responsible for could result in noncompliance with the Refund Reserve standards of 34 CFR 668.176. Failure to return Title IV funds which the College was responsible for could result in noncompliance with the Refund Reserve standards of 34 CFR 668.176. In addition the risk of inaccurate calculation increases when enrollment data entry is inaccurately recorded.Cause ? The College is not implementing policy and procedures for the institution?s return of unearned aid timely and the enrollment dates are not consistent in Banner.
2022-007 (2021-005) ? Special Tests and Provisions ? Enrollment Reporting ? Material Weakness and Material Noncompliance (Modified and Repeated) Federal Program Information Funding Agency: U.S. Department of Education Federal Award Agreement Number: Not Applicable Award Year: All Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College does not have effective controls over this compliance requirement, which resulted in the College not notifying the Department of Education and NSLDS of changes in student status in a timely and accurate manner. We noted the following instances of noncompliance: ? For nine of 60 students tested, the Student had status information included in Banner but no information was included on the NSLDS report. ? For one of 60 students tested, the student?s program on the NSLDS report did not match that listed in Banner. ? For one of 60 students tested, the student?s degree type on the NSLDS report did not match that listed in Banner. ? For 24 of 60 students tested, the student?s time status on the NSLDS report did not match that listed in Banner. ? For 51 of 60 students tested, the roster was not submitted within 15 days.As noted in the prior year audit management response, the College did not anticipate this finding would be resolved during fiscal year 2022 as they did not know of the issue until late into the fiscal year. Criteria - Per 2 CFR 200.303(a), an entity must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the entity is managing the Federal awards in compliance with statutes, regulations, and the terms and conditions of the award. In addition, the Department of Education relies on institution?s enrollments reports to determine a student?s enrollment status based on reductions or increases in attendance levels, withdrawals, graduations or approved leaves-of-absence. According to 34 CFR 690.83(b)(2) and 685.309, the College is required to submit changes in student attendance to the National Student Loan Data System (NSLDS) at a minimum of every 60 days. Questioned Costs - Not applicable. Effect - This resulted in inaccurate enrollment reporting during the year, which may cause a student?s status to be incorrect for extended periods of time. As a result, the College did not promptly notify Department of Education, lenders, or NSLDS of changes in student status in a timely and accurate manner. Cause - The College did not have controls in place to help follow the appropriate procedures in accordance with enrollment reporting requirements.
2022-008 ? Special Tests and Provisions ? Return of Title IV Funds ? Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Education Federal Award Agreement Number: Not Applicable Award Year: All Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College does not have effective controls over this compliance requirement, which resulted in four students out of five tested having enrollment dates not matching in two different areas in Banner (SFAWDRL and ROAENRL), and 2 out of 5 students tested did not have professors update the last attendance date. In addition, one of five students tested had an amount due of $594.38 for the school to return to ED, which was not listed in Banner as paid back. Criteria - Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entity 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per Title 34 US Code of Federal Regulations Part 668.173 Refund reserve standards (b) timely return of title IV funds, no later than 45 days after the date it was determined the student withdrew. Per Title 34 US Code of Federal Regulations Part 668.22(g), the institution must return the amount of unearned aid they are responsible as calculated and Title 2 US Code of Federal Regulations Part 668.22(j) timeframe for the return of title IV funds as soon as possible but no later than 45 days after the date the institution determined the student withdrew. Questioned Costs - $594.38 of known questioned costs and $5,867 of likely questioned costs. Effect - Failure to return title IV funds which the College was responsible for could result in noncompliance with the Refund Reserve standards of 34 CFR 668.176. Failure to return Title IV funds which the College was responsible for could result in noncompliance with the Refund Reserve standards of 34 CFR 668.176. In addition the risk of inaccurate calculation increases when enrollment data entry is inaccurately recorded.Cause ? The College is not implementing policy and procedures for the institution?s return of unearned aid timely and the enrollment dates are not consistent in Banner.
2022-010 ? Equipment and Real Property Management ? Material Weakness Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College was not able to provide an equipment listing tracking items purchased with federal funding nor did the College conduct a physical inventory.Criteria - Per 2 CFR 200.313(d)(2), a physical inventory of program property must be taken and the results reconciled with the property records at least once every 2 years and per 2 CFR 200.303(a) states that the non-Federal entity 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. Questioned Costs - Not applicable. Effect - The College could dispose of or lose federally funded equipment without following federal guidelines. Cause - The College does not have policies and procedures to ensure that equipment purchases with federal funds is maintained and tracked and that the College performing a physical inventory at a minimum of every two years.
2022-011 ? Procurement ? Small Purchases ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College did not apply the correct micro purchase threshold and were not obtaining quotes for purchases that should have been subjected to the small purchase threshold. The population between $10k and $20k that were improperly treated as micro purchases consisted of four transactions totaling $50,373. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. Questioned Costs - Not applicable. Effect - The College may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. Cause - The College adopted to follow the NM Procurement Policy in 2018 but failed to update its policy employees still followed with incorrect threshold for micro purchases.
2022-012 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Material Weakness and Material Noncompliance Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - For nine of nine salaried employees tested, there was no time and effort documentation provided for the period under review. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1)(vii) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed, which includes support for the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. In addition, 2 CFR 200.430(i)(1)(viii) indicates that budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that (B) significant changes in the corresponding work activity are identified and entered into the records in a timely manner. Short term fluctuations between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) the non-federal entity?s system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.In addition, the College?s grant fiscal management guide requires bi-annual reviews of time and effort certifications and related reports pertaining to split allocations of personnel charges, including the allocation of fringe benefits, will be conducted and maintained for all federal awards by the Compliance Officer. Questioned Costs - Not applicable. Effect - The College could over allocate payroll costs to a particular grant in which the employee did not participate. Cause - The College could not locate the time and effort certifications for the employees selected due to transitions within the payroll and the grant monitoring functions.
2022-013 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - During our review of payroll related transactions, the following were noted. ? For one of 25 payroll transactions tested, the supervisor did not sign the timesheet. ? For one of 25 payroll transactions tested, the employee?s contract was not updated as of July 1, 2021 to the correct salary amount. Therefore, the employee was underpaid a total of $475.29 during the fiscal year. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (i) be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; and (ii) be incorporated into the official records of the non-federal entity. Questioned Costs - Not applicable. Effect - The College may unintentionally overpay or underpay employees during their fiscal year. Cause - The College could not locate payroll records due to transition within the payroll and HR departments. In addition, the unsigned timesheet was overlooked.
2022-010 ? Equipment and Real Property Management ? Material Weakness Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College was not able to provide an equipment listing tracking items purchased with federal funding nor did the College conduct a physical inventory.Criteria - Per 2 CFR 200.313(d)(2), a physical inventory of program property must be taken and the results reconciled with the property records at least once every 2 years and per 2 CFR 200.303(a) states that the non-Federal entity 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. Questioned Costs - Not applicable. Effect - The College could dispose of or lose federally funded equipment without following federal guidelines. Cause - The College does not have policies and procedures to ensure that equipment purchases with federal funds is maintained and tracked and that the College performing a physical inventory at a minimum of every two years.
2022-011 ? Procurement ? Small Purchases ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College did not apply the correct micro purchase threshold and were not obtaining quotes for purchases that should have been subjected to the small purchase threshold. The population between $10k and $20k that were improperly treated as micro purchases consisted of four transactions totaling $50,373. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. Questioned Costs - Not applicable. Effect - The College may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. Cause - The College adopted to follow the NM Procurement Policy in 2018 but failed to update its policy employees still followed with incorrect threshold for micro purchases.
2022-012 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Material Weakness and Material Noncompliance Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - For nine of nine salaried employees tested, there was no time and effort documentation provided for the period under review. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1)(vii) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed, which includes support for the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. In addition, 2 CFR 200.430(i)(1)(viii) indicates that budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that (B) significant changes in the corresponding work activity are identified and entered into the records in a timely manner. Short term fluctuations between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) the non-federal entity?s system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.In addition, the College?s grant fiscal management guide requires bi-annual reviews of time and effort certifications and related reports pertaining to split allocations of personnel charges, including the allocation of fringe benefits, will be conducted and maintained for all federal awards by the Compliance Officer. Questioned Costs - Not applicable. Effect - The College could over allocate payroll costs to a particular grant in which the employee did not participate. Cause - The College could not locate the time and effort certifications for the employees selected due to transitions within the payroll and the grant monitoring functions.
2022-013 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - During our review of payroll related transactions, the following were noted. ? For one of 25 payroll transactions tested, the supervisor did not sign the timesheet. ? For one of 25 payroll transactions tested, the employee?s contract was not updated as of July 1, 2021 to the correct salary amount. Therefore, the employee was underpaid a total of $475.29 during the fiscal year. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (i) be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; and (ii) be incorporated into the official records of the non-federal entity. Questioned Costs - Not applicable. Effect - The College may unintentionally overpay or underpay employees during their fiscal year. Cause - The College could not locate payroll records due to transition within the payroll and HR departments. In addition, the unsigned timesheet was overlooked.
2022-010 ? Equipment and Real Property Management ? Material Weakness Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College was not able to provide an equipment listing tracking items purchased with federal funding nor did the College conduct a physical inventory.Criteria - Per 2 CFR 200.313(d)(2), a physical inventory of program property must be taken and the results reconciled with the property records at least once every 2 years and per 2 CFR 200.303(a) states that the non-Federal entity 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. Questioned Costs - Not applicable. Effect - The College could dispose of or lose federally funded equipment without following federal guidelines. Cause - The College does not have policies and procedures to ensure that equipment purchases with federal funds is maintained and tracked and that the College performing a physical inventory at a minimum of every two years.
2022-011 ? Procurement ? Small Purchases ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College did not apply the correct micro purchase threshold and were not obtaining quotes for purchases that should have been subjected to the small purchase threshold. The population between $10k and $20k that were improperly treated as micro purchases consisted of four transactions totaling $50,373. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. Questioned Costs - Not applicable. Effect - The College may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. Cause - The College adopted to follow the NM Procurement Policy in 2018 but failed to update its policy employees still followed with incorrect threshold for micro purchases.
2022-012 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Material Weakness and Material Noncompliance Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - For nine of nine salaried employees tested, there was no time and effort documentation provided for the period under review. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1)(vii) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed, which includes support for the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. In addition, 2 CFR 200.430(i)(1)(viii) indicates that budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that (B) significant changes in the corresponding work activity are identified and entered into the records in a timely manner. Short term fluctuations between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) the non-federal entity?s system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.In addition, the College?s grant fiscal management guide requires bi-annual reviews of time and effort certifications and related reports pertaining to split allocations of personnel charges, including the allocation of fringe benefits, will be conducted and maintained for all federal awards by the Compliance Officer. Questioned Costs - Not applicable. Effect - The College could over allocate payroll costs to a particular grant in which the employee did not participate. Cause - The College could not locate the time and effort certifications for the employees selected due to transitions within the payroll and the grant monitoring functions.
2022-013 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - During our review of payroll related transactions, the following were noted. ? For one of 25 payroll transactions tested, the supervisor did not sign the timesheet. ? For one of 25 payroll transactions tested, the employee?s contract was not updated as of July 1, 2021 to the correct salary amount. Therefore, the employee was underpaid a total of $475.29 during the fiscal year. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (i) be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; and (ii) be incorporated into the official records of the non-federal entity. Questioned Costs - Not applicable. Effect - The College may unintentionally overpay or underpay employees during their fiscal year. Cause - The College could not locate payroll records due to transition within the payroll and HR departments. In addition, the unsigned timesheet was overlooked.
2022-010 ? Equipment and Real Property Management ? Material Weakness Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College was not able to provide an equipment listing tracking items purchased with federal funding nor did the College conduct a physical inventory.Criteria - Per 2 CFR 200.313(d)(2), a physical inventory of program property must be taken and the results reconciled with the property records at least once every 2 years and per 2 CFR 200.303(a) states that the non-Federal entity 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. Questioned Costs - Not applicable. Effect - The College could dispose of or lose federally funded equipment without following federal guidelines. Cause - The College does not have policies and procedures to ensure that equipment purchases with federal funds is maintained and tracked and that the College performing a physical inventory at a minimum of every two years.
2022-011 ? Procurement ? Small Purchases ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College did not apply the correct micro purchase threshold and were not obtaining quotes for purchases that should have been subjected to the small purchase threshold. The population between $10k and $20k that were improperly treated as micro purchases consisted of four transactions totaling $50,373. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. Questioned Costs - Not applicable. Effect - The College may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. Cause - The College adopted to follow the NM Procurement Policy in 2018 but failed to update its policy employees still followed with incorrect threshold for micro purchases.
2022-012 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Material Weakness and Material Noncompliance Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - For nine of nine salaried employees tested, there was no time and effort documentation provided for the period under review. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1)(vii) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed, which includes support for the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. In addition, 2 CFR 200.430(i)(1)(viii) indicates that budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that (B) significant changes in the corresponding work activity are identified and entered into the records in a timely manner. Short term fluctuations between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) the non-federal entity?s system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.In addition, the College?s grant fiscal management guide requires bi-annual reviews of time and effort certifications and related reports pertaining to split allocations of personnel charges, including the allocation of fringe benefits, will be conducted and maintained for all federal awards by the Compliance Officer. Questioned Costs - Not applicable. Effect - The College could over allocate payroll costs to a particular grant in which the employee did not participate. Cause - The College could not locate the time and effort certifications for the employees selected due to transitions within the payroll and the grant monitoring functions.
2022-013 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - During our review of payroll related transactions, the following were noted. ? For one of 25 payroll transactions tested, the supervisor did not sign the timesheet. ? For one of 25 payroll transactions tested, the employee?s contract was not updated as of July 1, 2021 to the correct salary amount. Therefore, the employee was underpaid a total of $475.29 during the fiscal year. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (i) be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; and (ii) be incorporated into the official records of the non-federal entity. Questioned Costs - Not applicable. Effect - The College may unintentionally overpay or underpay employees during their fiscal year. Cause - The College could not locate payroll records due to transition within the payroll and HR departments. In addition, the unsigned timesheet was overlooked.
2022-010 ? Equipment and Real Property Management ? Material Weakness Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College was not able to provide an equipment listing tracking items purchased with federal funding nor did the College conduct a physical inventory.Criteria - Per 2 CFR 200.313(d)(2), a physical inventory of program property must be taken and the results reconciled with the property records at least once every 2 years and per 2 CFR 200.303(a) states that the non-Federal entity 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. Questioned Costs - Not applicable. Effect - The College could dispose of or lose federally funded equipment without following federal guidelines. Cause - The College does not have policies and procedures to ensure that equipment purchases with federal funds is maintained and tracked and that the College performing a physical inventory at a minimum of every two years.
2022-011 ? Procurement ? Small Purchases ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College did not apply the correct micro purchase threshold and were not obtaining quotes for purchases that should have been subjected to the small purchase threshold. The population between $10k and $20k that were improperly treated as micro purchases consisted of four transactions totaling $50,373. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. Questioned Costs - Not applicable. Effect - The College may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. Cause - The College adopted to follow the NM Procurement Policy in 2018 but failed to update its policy employees still followed with incorrect threshold for micro purchases.
2022-012 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Material Weakness and Material Noncompliance Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - For nine of nine salaried employees tested, there was no time and effort documentation provided for the period under review. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1)(vii) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed, which includes support for the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. In addition, 2 CFR 200.430(i)(1)(viii) indicates that budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that (B) significant changes in the corresponding work activity are identified and entered into the records in a timely manner. Short term fluctuations between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) the non-federal entity?s system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.In addition, the College?s grant fiscal management guide requires bi-annual reviews of time and effort certifications and related reports pertaining to split allocations of personnel charges, including the allocation of fringe benefits, will be conducted and maintained for all federal awards by the Compliance Officer. Questioned Costs - Not applicable. Effect - The College could over allocate payroll costs to a particular grant in which the employee did not participate. Cause - The College could not locate the time and effort certifications for the employees selected due to transitions within the payroll and the grant monitoring functions.
2022-013 ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance ? Payroll ? Significant Deficiency Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - During our review of payroll related transactions, the following were noted. ? For one of 25 payroll transactions tested, the supervisor did not sign the timesheet. ? For one of 25 payroll transactions tested, the employee?s contract was not updated as of July 1, 2021 to the correct salary amount. Therefore, the employee was underpaid a total of $475.29 during the fiscal year. Criteria - 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.430(i)(1) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (i) be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; and (ii) be incorporated into the official records of the non-federal entity. Questioned Costs - Not applicable. Effect - The College may unintentionally overpay or underpay employees during their fiscal year. Cause - The College could not locate payroll records due to transition within the payroll and HR departments. In addition, the unsigned timesheet was overlooked.
2022-009 (2021-008) ? Special Reporting ? Quarterly Reporting ? Significant Deficiency (Modified and Repeated) Federal Program Information Funding Agency: U.S. Department of Education Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425E, 84.425F, and 84.425L Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - Two Quarterly Public Reports for the student portion did not contain dates reports were posted to verify timeliness nor was there support of documentation reviewed and compared prior to posting. Criteria - Per 2 CFR 200.303(a), an entity must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the entity is managing the Federal awards in compliance with statutes, regulations, and the terms and conditions of the award. The CARES Act establishing the Education Stabilization Fund required that reports be publically posted on the institution?s website for the Student Aid and Institutional portions of the Higher Education Emergency Relief Fund (HEERF). The forms must be conspicuously posted on the College?s primary website at certain dates throughout the year.Questioned Costs - Not applicable. Effect - Lack of proper review for accuracy and timeliness of reports can result in improper reporting which could lead to disallowed costs. However, our audit disclosed no instances of unallowable costs. Cause - The College did not have sufficient controls in place to review and approve reports ensuring accuracy and timeliness in accordance with HEERF reporting requirements.
2022-009 (2021-008) ? Special Reporting ? Quarterly Reporting ? Significant Deficiency (Modified and Repeated) Federal Program Information Funding Agency: U.S. Department of Education Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425E, 84.425F, and 84.425L Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - Two Quarterly Public Reports for the student portion did not contain dates reports were posted to verify timeliness nor was there support of documentation reviewed and compared prior to posting. Criteria - Per 2 CFR 200.303(a), an entity must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the entity is managing the Federal awards in compliance with statutes, regulations, and the terms and conditions of the award. The CARES Act establishing the Education Stabilization Fund required that reports be publically posted on the institution?s website for the Student Aid and Institutional portions of the Higher Education Emergency Relief Fund (HEERF). The forms must be conspicuously posted on the College?s primary website at certain dates throughout the year.Questioned Costs - Not applicable. Effect - Lack of proper review for accuracy and timeliness of reports can result in improper reporting which could lead to disallowed costs. However, our audit disclosed no instances of unallowable costs. Cause - The College did not have sufficient controls in place to review and approve reports ensuring accuracy and timeliness in accordance with HEERF reporting requirements.
2022-009 (2021-008) ? Special Reporting ? Quarterly Reporting ? Significant Deficiency (Modified and Repeated) Federal Program Information Funding Agency: U.S. Department of Education Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425E, 84.425F, and 84.425L Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - Two Quarterly Public Reports for the student portion did not contain dates reports were posted to verify timeliness nor was there support of documentation reviewed and compared prior to posting. Criteria - Per 2 CFR 200.303(a), an entity must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the entity is managing the Federal awards in compliance with statutes, regulations, and the terms and conditions of the award. The CARES Act establishing the Education Stabilization Fund required that reports be publically posted on the institution?s website for the Student Aid and Institutional portions of the Higher Education Emergency Relief Fund (HEERF). The forms must be conspicuously posted on the College?s primary website at certain dates throughout the year.Questioned Costs - Not applicable. Effect - Lack of proper review for accuracy and timeliness of reports can result in improper reporting which could lead to disallowed costs. However, our audit disclosed no instances of unallowable costs. Cause - The College did not have sufficient controls in place to review and approve reports ensuring accuracy and timeliness in accordance with HEERF reporting requirements.
2022-007 (2021-005) ? Special Tests and Provisions ? Enrollment Reporting ? Material Weakness and Material Noncompliance (Modified and Repeated) Federal Program Information Funding Agency: U.S. Department of Education Federal Award Agreement Number: Not Applicable Award Year: All Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College does not have effective controls over this compliance requirement, which resulted in the College not notifying the Department of Education and NSLDS of changes in student status in a timely and accurate manner. We noted the following instances of noncompliance: ? For nine of 60 students tested, the Student had status information included in Banner but no information was included on the NSLDS report. ? For one of 60 students tested, the student?s program on the NSLDS report did not match that listed in Banner. ? For one of 60 students tested, the student?s degree type on the NSLDS report did not match that listed in Banner. ? For 24 of 60 students tested, the student?s time status on the NSLDS report did not match that listed in Banner. ? For 51 of 60 students tested, the roster was not submitted within 15 days.As noted in the prior year audit management response, the College did not anticipate this finding would be resolved during fiscal year 2022 as they did not know of the issue until late into the fiscal year. Criteria - Per 2 CFR 200.303(a), an entity must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the entity is managing the Federal awards in compliance with statutes, regulations, and the terms and conditions of the award. In addition, the Department of Education relies on institution?s enrollments reports to determine a student?s enrollment status based on reductions or increases in attendance levels, withdrawals, graduations or approved leaves-of-absence. According to 34 CFR 690.83(b)(2) and 685.309, the College is required to submit changes in student attendance to the National Student Loan Data System (NSLDS) at a minimum of every 60 days. Questioned Costs - Not applicable. Effect - This resulted in inaccurate enrollment reporting during the year, which may cause a student?s status to be incorrect for extended periods of time. As a result, the College did not promptly notify Department of Education, lenders, or NSLDS of changes in student status in a timely and accurate manner. Cause - The College did not have controls in place to help follow the appropriate procedures in accordance with enrollment reporting requirements.
2022-008 ? Special Tests and Provisions ? Return of Title IV Funds ? Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Education Federal Award Agreement Number: Not Applicable Award Year: All Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College does not have effective controls over this compliance requirement, which resulted in four students out of five tested having enrollment dates not matching in two different areas in Banner (SFAWDRL and ROAENRL), and 2 out of 5 students tested did not have professors update the last attendance date. In addition, one of five students tested had an amount due of $594.38 for the school to return to ED, which was not listed in Banner as paid back. Criteria - Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entity 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per Title 34 US Code of Federal Regulations Part 668.173 Refund reserve standards (b) timely return of title IV funds, no later than 45 days after the date it was determined the student withdrew. Per Title 34 US Code of Federal Regulations Part 668.22(g), the institution must return the amount of unearned aid they are responsible as calculated and Title 2 US Code of Federal Regulations Part 668.22(j) timeframe for the return of title IV funds as soon as possible but no later than 45 days after the date the institution determined the student withdrew. Questioned Costs - $594.38 of known questioned costs and $5,867 of likely questioned costs. Effect - Failure to return title IV funds which the College was responsible for could result in noncompliance with the Refund Reserve standards of 34 CFR 668.176. Failure to return Title IV funds which the College was responsible for could result in noncompliance with the Refund Reserve standards of 34 CFR 668.176. In addition the risk of inaccurate calculation increases when enrollment data entry is inaccurately recorded.Cause ? The College is not implementing policy and procedures for the institution?s return of unearned aid timely and the enrollment dates are not consistent in Banner.
2022-007 (2021-005) ? Special Tests and Provisions ? Enrollment Reporting ? Material Weakness and Material Noncompliance (Modified and Repeated) Federal Program Information Funding Agency: U.S. Department of Education Federal Award Agreement Number: Not Applicable Award Year: All Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College does not have effective controls over this compliance requirement, which resulted in the College not notifying the Department of Education and NSLDS of changes in student status in a timely and accurate manner. We noted the following instances of noncompliance: ? For nine of 60 students tested, the Student had status information included in Banner but no information was included on the NSLDS report. ? For one of 60 students tested, the student?s program on the NSLDS report did not match that listed in Banner. ? For one of 60 students tested, the student?s degree type on the NSLDS report did not match that listed in Banner. ? For 24 of 60 students tested, the student?s time status on the NSLDS report did not match that listed in Banner. ? For 51 of 60 students tested, the roster was not submitted within 15 days.As noted in the prior year audit management response, the College did not anticipate this finding would be resolved during fiscal year 2022 as they did not know of the issue until late into the fiscal year. Criteria - Per 2 CFR 200.303(a), an entity must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the entity is managing the Federal awards in compliance with statutes, regulations, and the terms and conditions of the award. In addition, the Department of Education relies on institution?s enrollments reports to determine a student?s enrollment status based on reductions or increases in attendance levels, withdrawals, graduations or approved leaves-of-absence. According to 34 CFR 690.83(b)(2) and 685.309, the College is required to submit changes in student attendance to the National Student Loan Data System (NSLDS) at a minimum of every 60 days. Questioned Costs - Not applicable. Effect - This resulted in inaccurate enrollment reporting during the year, which may cause a student?s status to be incorrect for extended periods of time. As a result, the College did not promptly notify Department of Education, lenders, or NSLDS of changes in student status in a timely and accurate manner. Cause - The College did not have controls in place to help follow the appropriate procedures in accordance with enrollment reporting requirements.
2022-008 ? Special Tests and Provisions ? Return of Title IV Funds ? Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Education Federal Award Agreement Number: Not Applicable Award Year: All Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College does not have effective controls over this compliance requirement, which resulted in four students out of five tested having enrollment dates not matching in two different areas in Banner (SFAWDRL and ROAENRL), and 2 out of 5 students tested did not have professors update the last attendance date. In addition, one of five students tested had an amount due of $594.38 for the school to return to ED, which was not listed in Banner as paid back. Criteria - Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entity 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per Title 34 US Code of Federal Regulations Part 668.173 Refund reserve standards (b) timely return of title IV funds, no later than 45 days after the date it was determined the student withdrew. Per Title 34 US Code of Federal Regulations Part 668.22(g), the institution must return the amount of unearned aid they are responsible as calculated and Title 2 US Code of Federal Regulations Part 668.22(j) timeframe for the return of title IV funds as soon as possible but no later than 45 days after the date the institution determined the student withdrew. Questioned Costs - $594.38 of known questioned costs and $5,867 of likely questioned costs. Effect - Failure to return title IV funds which the College was responsible for could result in noncompliance with the Refund Reserve standards of 34 CFR 668.176. Failure to return Title IV funds which the College was responsible for could result in noncompliance with the Refund Reserve standards of 34 CFR 668.176. In addition the risk of inaccurate calculation increases when enrollment data entry is inaccurately recorded.Cause ? The College is not implementing policy and procedures for the institution?s return of unearned aid timely and the enrollment dates are not consistent in Banner.
2022-007 (2021-005) ? Special Tests and Provisions ? Enrollment Reporting ? Material Weakness and Material Noncompliance (Modified and Repeated) Federal Program Information Funding Agency: U.S. Department of Education Federal Award Agreement Number: Not Applicable Award Year: All Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College does not have effective controls over this compliance requirement, which resulted in the College not notifying the Department of Education and NSLDS of changes in student status in a timely and accurate manner. We noted the following instances of noncompliance: ? For nine of 60 students tested, the Student had status information included in Banner but no information was included on the NSLDS report. ? For one of 60 students tested, the student?s program on the NSLDS report did not match that listed in Banner. ? For one of 60 students tested, the student?s degree type on the NSLDS report did not match that listed in Banner. ? For 24 of 60 students tested, the student?s time status on the NSLDS report did not match that listed in Banner. ? For 51 of 60 students tested, the roster was not submitted within 15 days.As noted in the prior year audit management response, the College did not anticipate this finding would be resolved during fiscal year 2022 as they did not know of the issue until late into the fiscal year. Criteria - Per 2 CFR 200.303(a), an entity must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the entity is managing the Federal awards in compliance with statutes, regulations, and the terms and conditions of the award. In addition, the Department of Education relies on institution?s enrollments reports to determine a student?s enrollment status based on reductions or increases in attendance levels, withdrawals, graduations or approved leaves-of-absence. According to 34 CFR 690.83(b)(2) and 685.309, the College is required to submit changes in student attendance to the National Student Loan Data System (NSLDS) at a minimum of every 60 days. Questioned Costs - Not applicable. Effect - This resulted in inaccurate enrollment reporting during the year, which may cause a student?s status to be incorrect for extended periods of time. As a result, the College did not promptly notify Department of Education, lenders, or NSLDS of changes in student status in a timely and accurate manner. Cause - The College did not have controls in place to help follow the appropriate procedures in accordance with enrollment reporting requirements.
2022-008 ? Special Tests and Provisions ? Return of Title IV Funds ? Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Education Federal Award Agreement Number: Not Applicable Award Year: All Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College does not have effective controls over this compliance requirement, which resulted in four students out of five tested having enrollment dates not matching in two different areas in Banner (SFAWDRL and ROAENRL), and 2 out of 5 students tested did not have professors update the last attendance date. In addition, one of five students tested had an amount due of $594.38 for the school to return to ED, which was not listed in Banner as paid back. Criteria - Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entity 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per Title 34 US Code of Federal Regulations Part 668.173 Refund reserve standards (b) timely return of title IV funds, no later than 45 days after the date it was determined the student withdrew. Per Title 34 US Code of Federal Regulations Part 668.22(g), the institution must return the amount of unearned aid they are responsible as calculated and Title 2 US Code of Federal Regulations Part 668.22(j) timeframe for the return of title IV funds as soon as possible but no later than 45 days after the date the institution determined the student withdrew. Questioned Costs - $594.38 of known questioned costs and $5,867 of likely questioned costs. Effect - Failure to return title IV funds which the College was responsible for could result in noncompliance with the Refund Reserve standards of 34 CFR 668.176. Failure to return Title IV funds which the College was responsible for could result in noncompliance with the Refund Reserve standards of 34 CFR 668.176. In addition the risk of inaccurate calculation increases when enrollment data entry is inaccurately recorded.Cause ? The College is not implementing policy and procedures for the institution?s return of unearned aid timely and the enrollment dates are not consistent in Banner.
2022-007 (2021-005) ? Special Tests and Provisions ? Enrollment Reporting ? Material Weakness and Material Noncompliance (Modified and Repeated) Federal Program Information Funding Agency: U.S. Department of Education Federal Award Agreement Number: Not Applicable Award Year: All Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College does not have effective controls over this compliance requirement, which resulted in the College not notifying the Department of Education and NSLDS of changes in student status in a timely and accurate manner. We noted the following instances of noncompliance: ? For nine of 60 students tested, the Student had status information included in Banner but no information was included on the NSLDS report. ? For one of 60 students tested, the student?s program on the NSLDS report did not match that listed in Banner. ? For one of 60 students tested, the student?s degree type on the NSLDS report did not match that listed in Banner. ? For 24 of 60 students tested, the student?s time status on the NSLDS report did not match that listed in Banner. ? For 51 of 60 students tested, the roster was not submitted within 15 days.As noted in the prior year audit management response, the College did not anticipate this finding would be resolved during fiscal year 2022 as they did not know of the issue until late into the fiscal year. Criteria - Per 2 CFR 200.303(a), an entity must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the entity is managing the Federal awards in compliance with statutes, regulations, and the terms and conditions of the award. In addition, the Department of Education relies on institution?s enrollments reports to determine a student?s enrollment status based on reductions or increases in attendance levels, withdrawals, graduations or approved leaves-of-absence. According to 34 CFR 690.83(b)(2) and 685.309, the College is required to submit changes in student attendance to the National Student Loan Data System (NSLDS) at a minimum of every 60 days. Questioned Costs - Not applicable. Effect - This resulted in inaccurate enrollment reporting during the year, which may cause a student?s status to be incorrect for extended periods of time. As a result, the College did not promptly notify Department of Education, lenders, or NSLDS of changes in student status in a timely and accurate manner. Cause - The College did not have controls in place to help follow the appropriate procedures in accordance with enrollment reporting requirements.
2022-008 ? Special Tests and Provisions ? Return of Title IV Funds ? Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Education Federal Award Agreement Number: Not Applicable Award Year: All Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College does not have effective controls over this compliance requirement, which resulted in four students out of five tested having enrollment dates not matching in two different areas in Banner (SFAWDRL and ROAENRL), and 2 out of 5 students tested did not have professors update the last attendance date. In addition, one of five students tested had an amount due of $594.38 for the school to return to ED, which was not listed in Banner as paid back. Criteria - Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entity 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per Title 34 US Code of Federal Regulations Part 668.173 Refund reserve standards (b) timely return of title IV funds, no later than 45 days after the date it was determined the student withdrew. Per Title 34 US Code of Federal Regulations Part 668.22(g), the institution must return the amount of unearned aid they are responsible as calculated and Title 2 US Code of Federal Regulations Part 668.22(j) timeframe for the return of title IV funds as soon as possible but no later than 45 days after the date the institution determined the student withdrew. Questioned Costs - $594.38 of known questioned costs and $5,867 of likely questioned costs. Effect - Failure to return title IV funds which the College was responsible for could result in noncompliance with the Refund Reserve standards of 34 CFR 668.176. Failure to return Title IV funds which the College was responsible for could result in noncompliance with the Refund Reserve standards of 34 CFR 668.176. In addition the risk of inaccurate calculation increases when enrollment data entry is inaccurately recorded.Cause ? The College is not implementing policy and procedures for the institution?s return of unearned aid timely and the enrollment dates are not consistent in Banner.
2022-007 (2021-005) ? Special Tests and Provisions ? Enrollment Reporting ? Material Weakness and Material Noncompliance (Modified and Repeated) Federal Program Information Funding Agency: U.S. Department of Education Federal Award Agreement Number: Not Applicable Award Year: All Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College does not have effective controls over this compliance requirement, which resulted in the College not notifying the Department of Education and NSLDS of changes in student status in a timely and accurate manner. We noted the following instances of noncompliance: ? For nine of 60 students tested, the Student had status information included in Banner but no information was included on the NSLDS report. ? For one of 60 students tested, the student?s program on the NSLDS report did not match that listed in Banner. ? For one of 60 students tested, the student?s degree type on the NSLDS report did not match that listed in Banner. ? For 24 of 60 students tested, the student?s time status on the NSLDS report did not match that listed in Banner. ? For 51 of 60 students tested, the roster was not submitted within 15 days.As noted in the prior year audit management response, the College did not anticipate this finding would be resolved during fiscal year 2022 as they did not know of the issue until late into the fiscal year. Criteria - Per 2 CFR 200.303(a), an entity must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the entity is managing the Federal awards in compliance with statutes, regulations, and the terms and conditions of the award. In addition, the Department of Education relies on institution?s enrollments reports to determine a student?s enrollment status based on reductions or increases in attendance levels, withdrawals, graduations or approved leaves-of-absence. According to 34 CFR 690.83(b)(2) and 685.309, the College is required to submit changes in student attendance to the National Student Loan Data System (NSLDS) at a minimum of every 60 days. Questioned Costs - Not applicable. Effect - This resulted in inaccurate enrollment reporting during the year, which may cause a student?s status to be incorrect for extended periods of time. As a result, the College did not promptly notify Department of Education, lenders, or NSLDS of changes in student status in a timely and accurate manner. Cause - The College did not have controls in place to help follow the appropriate procedures in accordance with enrollment reporting requirements.
2022-008 ? Special Tests and Provisions ? Return of Title IV Funds ? Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Education Federal Award Agreement Number: Not Applicable Award Year: All Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College does not have effective controls over this compliance requirement, which resulted in four students out of five tested having enrollment dates not matching in two different areas in Banner (SFAWDRL and ROAENRL), and 2 out of 5 students tested did not have professors update the last attendance date. In addition, one of five students tested had an amount due of $594.38 for the school to return to ED, which was not listed in Banner as paid back. Criteria - Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entity 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per Title 34 US Code of Federal Regulations Part 668.173 Refund reserve standards (b) timely return of title IV funds, no later than 45 days after the date it was determined the student withdrew. Per Title 34 US Code of Federal Regulations Part 668.22(g), the institution must return the amount of unearned aid they are responsible as calculated and Title 2 US Code of Federal Regulations Part 668.22(j) timeframe for the return of title IV funds as soon as possible but no later than 45 days after the date the institution determined the student withdrew. Questioned Costs - $594.38 of known questioned costs and $5,867 of likely questioned costs. Effect - Failure to return title IV funds which the College was responsible for could result in noncompliance with the Refund Reserve standards of 34 CFR 668.176. Failure to return Title IV funds which the College was responsible for could result in noncompliance with the Refund Reserve standards of 34 CFR 668.176. In addition the risk of inaccurate calculation increases when enrollment data entry is inaccurately recorded.Cause ? The College is not implementing policy and procedures for the institution?s return of unearned aid timely and the enrollment dates are not consistent in Banner.
2022-010 ? Equipment and Real Property Management ? Material Weakness Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College was not able to provide an equipment listing tracking items purchased with federal funding nor did the College conduct a physical inventory.Criteria - Per 2 CFR 200.313(d)(2), a physical inventory of program property must be taken and the results reconciled with the property records at least once every 2 years and per 2 CFR 200.303(a) states that the non-Federal entity 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. Questioned Costs - Not applicable. Effect - The College could dispose of or lose federally funded equipment without following federal guidelines. Cause - The College does not have policies and procedures to ensure that equipment purchases with federal funds is maintained and tracked and that the College performing a physical inventory at a minimum of every two years.