Criteria or specific requirement: Per 34 CFR 685.309(b)(2), and as outlined in the OMB Compliance Supplement Part 5, enrollment information related to a change in status must be reported to the National Student Loan Database System (NSLDS) within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. At a minimum, schools are required to certify enrollment data in NSLDS every 60 days. In addition, regulations require the status include an accurate effective date. There are two categories of enrollment information; ?Campus Level? and ?Program Level,? both of which need to be reported accurately.Condition: During testing of underlying enrollment information, we identified the following:? Two students? enrollment ?Campus Level? detail did not match the students? ?Program Level? detail according to the College?s policy,? Two students? changes in enrollment status were not submitted to the NSLDS within 60 days, and? Three students? enrollment status were not certified within 60 days.Context: We tested a sample of 24 students. Of the 24 students, we noted 7 students had the exceptions noted above.Questioned costs: None.Cause: The College?s processes and controls did not ensure that the student status changes were properly and timely reported to NSLDS.Effect: The College is out of compliance with the requirement that enrollment information related to a change in status must be reported to the National Student Loan Database System (NSLDS).Repeat Finding: Yes. See 2021-002.Recommendation: We recommend the College evaluate its procedures and policies around reporting to NSLDS, including those that are unique in nature, to ensure that student information is reported accurately and timely.Views of responsible officials and management?s response: The College agrees with the finding.
Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.Condition: Per review of two student's account detail, the College did not report a Direct Loan disbursement to COD within the 15-day time requirement.Context: We tested a sample of 40 students to determine the College?s compliance with reporting requirements outlined by the Department of Education related to Common Origination and Disbursement and noted two of the disbursements were not reported within the 15-day requirement.Questioned costs: None.Cause: Due to the timing of employee turnover within the Student Financial Aid department procedures were not completed timely.Effect: The College is out of compliance with the requirement that disbursement dates and amounts are reported to the Common Origination Disbursement system within 15 days.Repeat Finding: Yes. See 2021-001.Recommendation: We recommend the College evaluate its procedures and policies around reporting Direct Loan disbursements to COD, including those that are unique in nature, to ensure that student information is reported accurately and timely.Views of responsible officials and management?s response: The College agrees with the finding.
Criteria or specific requirement: Per 34 CFR 685.309(b)(2), and as outlined in the OMB Compliance Supplement Part 5, enrollment information related to a change in status must be reported to the National Student Loan Database System (NSLDS) within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. At a minimum, schools are required to certify enrollment data in NSLDS every 60 days. In addition, regulations require the status include an accurate effective date. There are two categories of enrollment information; ?Campus Level? and ?Program Level,? both of which need to be reported accurately.Condition: During testing of underlying enrollment information, we identified the following:? Two students? enrollment ?Campus Level? detail did not match the students? ?Program Level? detail according to the College?s policy,? Two students? changes in enrollment status were not submitted to the NSLDS within 60 days, and? Three students? enrollment status were not certified within 60 days.Context: We tested a sample of 24 students. Of the 24 students, we noted 7 students had the exceptions noted above.Questioned costs: None.Cause: The College?s processes and controls did not ensure that the student status changes were properly and timely reported to NSLDS.Effect: The College is out of compliance with the requirement that enrollment information related to a change in status must be reported to the National Student Loan Database System (NSLDS).Repeat Finding: Yes. See 2021-002.Recommendation: We recommend the College evaluate its procedures and policies around reporting to NSLDS, including those that are unique in nature, to ensure that student information is reported accurately and timely.Views of responsible officials and management?s response: The College agrees with the finding.
Criteria or specific requirement: Per the American Rescue Plan (ARP), Public Law 117-2, an institution receiving funds under Higher Education Emergency Relief Fund (HEERF III) is required to publicly post on the institution?s website certain key information on a quarterly basis. This reporting is required for both the institutional and the student portion of funding.Condition: During testing to determine if the required quarterly reports (both the student funding reports and the institutional funding reports) were both timely and accurate/supported by the College?s books and records, we noted for the three quarterly student funding reports, the College did not have records to support the estimated total number of students eligible to receive emergency financial aid grants reported. As such, the amounts reported could not be substantiated.Context: Of the three student funding quarterly reports tested, the estimated total number of students eligible to receive emergency financial aid grants could not be substantiated.Questioned costs: None.Cause: When obtaining the number of eligible students reported on the student funding quarterly reports, a snapshot of eligible students was obtained. The student aid database, PowerFAIDS, doesn?t track by date or quarter in a way that would allow the recreation of the total eligible students nor was a report kept for future reference.Effect: The College is not in compliance with all statutory or regulatory provisions as it pertains to the HEERF student quarterly reporting.Repeat Finding: Yes. See 2021-003.Recommendation: For any reports required by federal grants or programs, the College should establish procedures that include ensuring an audit trail remains for information reported. Those who review after prepared should trace back to such information.Views of responsible officials and management?s response: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.Condition: The College had a procurement policy that conformed to 2 CFR Part 200. Yet, during our testing, we noted that the College?s procurement policies were not followed. There was a single vendor who provided similar goods and services across two grants which had cumulative purchases over $10,000 within the fiscal year. This triggered Small Purchase compliance requirements to be followed; however, there was no documentation to support compliance.Questioned costs: None.Context: We tested a sample of five vendors and noted one vendor had the exception noted above.Cause: The College focused on the individual amounts being charged to the separate grants, not the cumulative amount paid to the vendor for the goods and services being provided.Effect: The College is not in compliance with their policy, nor are they in compliance with the prescribed methods of procurement as outlined in 2 CFR Part 200.320 to ensure reasonable price or rate.Repeat finding: No.Recommendation: We recommend that the College ensure its policies and procedures over procurement are being enforced to ensure reasonable prices and rates. Specifically, the College should consider training employees that regulations do apply when a single vendor is being used for a good or service, yet the charges are split amongst various funding sources.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per 34 CFR 685.309(b)(2), and as outlined in the OMB Compliance Supplement Part 5, enrollment information related to a change in status must be reported to the National Student Loan Database System (NSLDS) within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. At a minimum, schools are required to certify enrollment data in NSLDS every 60 days. In addition, regulations require the status include an accurate effective date. There are two categories of enrollment information; ?Campus Level? and ?Program Level,? both of which need to be reported accurately.Condition: During testing of underlying enrollment information, we identified the following:? Two students? enrollment ?Campus Level? detail did not match the students? ?Program Level? detail according to the College?s policy,? Two students? changes in enrollment status were not submitted to the NSLDS within 60 days, and? Three students? enrollment status were not certified within 60 days.Context: We tested a sample of 24 students. Of the 24 students, we noted 7 students had the exceptions noted above.Questioned costs: None.Cause: The College?s processes and controls did not ensure that the student status changes were properly and timely reported to NSLDS.Effect: The College is out of compliance with the requirement that enrollment information related to a change in status must be reported to the National Student Loan Database System (NSLDS).Repeat Finding: Yes. See 2021-002.Recommendation: We recommend the College evaluate its procedures and policies around reporting to NSLDS, including those that are unique in nature, to ensure that student information is reported accurately and timely.Views of responsible officials and management?s response: The College agrees with the finding.
Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.Condition: Per review of two student's account detail, the College did not report a Direct Loan disbursement to COD within the 15-day time requirement.Context: We tested a sample of 40 students to determine the College?s compliance with reporting requirements outlined by the Department of Education related to Common Origination and Disbursement and noted two of the disbursements were not reported within the 15-day requirement.Questioned costs: None.Cause: Due to the timing of employee turnover within the Student Financial Aid department procedures were not completed timely.Effect: The College is out of compliance with the requirement that disbursement dates and amounts are reported to the Common Origination Disbursement system within 15 days.Repeat Finding: Yes. See 2021-001.Recommendation: We recommend the College evaluate its procedures and policies around reporting Direct Loan disbursements to COD, including those that are unique in nature, to ensure that student information is reported accurately and timely.Views of responsible officials and management?s response: The College agrees with the finding.
Criteria or specific requirement: Per 34 CFR 685.309(b)(2), and as outlined in the OMB Compliance Supplement Part 5, enrollment information related to a change in status must be reported to the National Student Loan Database System (NSLDS) within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. At a minimum, schools are required to certify enrollment data in NSLDS every 60 days. In addition, regulations require the status include an accurate effective date. There are two categories of enrollment information; ?Campus Level? and ?Program Level,? both of which need to be reported accurately.Condition: During testing of underlying enrollment information, we identified the following:? Two students? enrollment ?Campus Level? detail did not match the students? ?Program Level? detail according to the College?s policy,? Two students? changes in enrollment status were not submitted to the NSLDS within 60 days, and? Three students? enrollment status were not certified within 60 days.Context: We tested a sample of 24 students. Of the 24 students, we noted 7 students had the exceptions noted above.Questioned costs: None.Cause: The College?s processes and controls did not ensure that the student status changes were properly and timely reported to NSLDS.Effect: The College is out of compliance with the requirement that enrollment information related to a change in status must be reported to the National Student Loan Database System (NSLDS).Repeat Finding: Yes. See 2021-002.Recommendation: We recommend the College evaluate its procedures and policies around reporting to NSLDS, including those that are unique in nature, to ensure that student information is reported accurately and timely.Views of responsible officials and management?s response: The College agrees with the finding.
Criteria or specific requirement: Per the American Rescue Plan (ARP), Public Law 117-2, an institution receiving funds under Higher Education Emergency Relief Fund (HEERF III) is required to publicly post on the institution?s website certain key information on a quarterly basis. This reporting is required for both the institutional and the student portion of funding.Condition: During testing to determine if the required quarterly reports (both the student funding reports and the institutional funding reports) were both timely and accurate/supported by the College?s books and records, we noted for the three quarterly student funding reports, the College did not have records to support the estimated total number of students eligible to receive emergency financial aid grants reported. As such, the amounts reported could not be substantiated.Context: Of the three student funding quarterly reports tested, the estimated total number of students eligible to receive emergency financial aid grants could not be substantiated.Questioned costs: None.Cause: When obtaining the number of eligible students reported on the student funding quarterly reports, a snapshot of eligible students was obtained. The student aid database, PowerFAIDS, doesn?t track by date or quarter in a way that would allow the recreation of the total eligible students nor was a report kept for future reference.Effect: The College is not in compliance with all statutory or regulatory provisions as it pertains to the HEERF student quarterly reporting.Repeat Finding: Yes. See 2021-003.Recommendation: For any reports required by federal grants or programs, the College should establish procedures that include ensuring an audit trail remains for information reported. Those who review after prepared should trace back to such information.Views of responsible officials and management?s response: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.Condition: The College had a procurement policy that conformed to 2 CFR Part 200. Yet, during our testing, we noted that the College?s procurement policies were not followed. There was a single vendor who provided similar goods and services across two grants which had cumulative purchases over $10,000 within the fiscal year. This triggered Small Purchase compliance requirements to be followed; however, there was no documentation to support compliance.Questioned costs: None.Context: We tested a sample of five vendors and noted one vendor had the exception noted above.Cause: The College focused on the individual amounts being charged to the separate grants, not the cumulative amount paid to the vendor for the goods and services being provided.Effect: The College is not in compliance with their policy, nor are they in compliance with the prescribed methods of procurement as outlined in 2 CFR Part 200.320 to ensure reasonable price or rate.Repeat finding: No.Recommendation: We recommend that the College ensure its policies and procedures over procurement are being enforced to ensure reasonable prices and rates. Specifically, the College should consider training employees that regulations do apply when a single vendor is being used for a good or service, yet the charges are split amongst various funding sources.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) 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.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.