Federal Agency U.S. Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.063, 84.007, 84.033, 84.268
Federal Award Identification Number and Year P063P232037 - 2024, P007A233429 - 2024, P033A233429 - 2024, P268K242037 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/23 - 6/30/24
Compliance Requirement Affected Special Test and Provision
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
In addition per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified ten instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and five instance where the enrollment effective date was not reported correctly to NSLDS.
Cause The College did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner.
Effect Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding No
Recommendation We recommend that the College implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the College implement formal review procedures to document the review process.
Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.063, 84.007, 84.033, 84.268
Federal Award Identification Number and Year P063P232037 - 2024, P007A233429 - 2024, P033A233429 - 2024, P268K242037 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/23 - 6/30/24
Compliance Requirement Affected Special Tests and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment The College used the incorrect withdraw date and incorrectly performed the Return of Title IV funds calculation
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure.
Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition "The College incorrectly calculated Return to Title IV (R2T4) calculations.
"
Questioned costs: N/A
Known Not over $25k
Likely See Question Cost Tab
Context During our testing of 40 R2T4 calculations, we identified that 5 had mechanically incorrect calculations by using the incorrect withdraw date.
Cause The College was using the incorrect withdraw date
Effect The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned.
Repeat Finding No
Recommendation We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely.
Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.063, 84.007, 84.033, 84.268
Federal Award Identification Number and Year P063P232037 - 2024, P007A233429 - 2024, P033A233429 - 2024, P268K242037 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/23 - 6/30/24
Compliance Requirement Affected Special Test and Provision
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
In addition per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified ten instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and five instance where the enrollment effective date was not reported correctly to NSLDS.
Cause The College did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner.
Effect Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding No
Recommendation We recommend that the College implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the College implement formal review procedures to document the review process.
Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.063, 84.007, 84.033, 84.268
Federal Award Identification Number and Year P063P232037 - 2024, P007A233429 - 2024, P033A233429 - 2024, P268K242037 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/23 - 6/30/24
Compliance Requirement Affected Special Tests and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment The College used the incorrect withdraw date and incorrectly performed the Return of Title IV funds calculation
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure.
Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition "The College incorrectly calculated Return to Title IV (R2T4) calculations.
"
Questioned costs: N/A
Known Not over $25k
Likely See Question Cost Tab
Context During our testing of 40 R2T4 calculations, we identified that 5 had mechanically incorrect calculations by using the incorrect withdraw date.
Cause The College was using the incorrect withdraw date
Effect The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned.
Repeat Finding No
Recommendation We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely.
Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.063, 84.007, 84.033, 84.268
Federal Award Identification Number and Year P063P232037 - 2024, P007A233429 - 2024, P033A233429 - 2024, P268K242037 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/23 - 6/30/24
Compliance Requirement Affected Special Test and Provision
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
In addition per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified ten instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and five instance where the enrollment effective date was not reported correctly to NSLDS.
Cause The College did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner.
Effect Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding No
Recommendation We recommend that the College implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the College implement formal review procedures to document the review process.
Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.063, 84.007, 84.033, 84.268
Federal Award Identification Number and Year P063P232037 - 2024, P007A233429 - 2024, P033A233429 - 2024, P268K242037 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/23 - 6/30/24
Compliance Requirement Affected Special Tests and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment The College used the incorrect withdraw date and incorrectly performed the Return of Title IV funds calculation
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure.
Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition "The College incorrectly calculated Return to Title IV (R2T4) calculations.
"
Questioned costs: N/A
Known Not over $25k
Likely See Question Cost Tab
Context During our testing of 40 R2T4 calculations, we identified that 5 had mechanically incorrect calculations by using the incorrect withdraw date.
Cause The College was using the incorrect withdraw date
Effect The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned.
Repeat Finding No
Recommendation We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely.
Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.063, 84.007, 84.033, 84.268
Federal Award Identification Number and Year P063P232037 - 2024, P007A233429 - 2024, P033A233429 - 2024, P268K242037 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/23 - 6/30/24
Compliance Requirement Affected Special Test and Provision
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
In addition per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified ten instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and five instance where the enrollment effective date was not reported correctly to NSLDS.
Cause The College did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner.
Effect Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding No
Recommendation We recommend that the College implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the College implement formal review procedures to document the review process.
Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.063, 84.007, 84.033, 84.268
Federal Award Identification Number and Year P063P232037 - 2024, P007A233429 - 2024, P033A233429 - 2024, P268K242037 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/23 - 6/30/24
Compliance Requirement Affected Special Tests and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment The College used the incorrect withdraw date and incorrectly performed the Return of Title IV funds calculation
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure.
Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition "The College incorrectly calculated Return to Title IV (R2T4) calculations.
"
Questioned costs: N/A
Known Not over $25k
Likely See Question Cost Tab
Context During our testing of 40 R2T4 calculations, we identified that 5 had mechanically incorrect calculations by using the incorrect withdraw date.
Cause The College was using the incorrect withdraw date
Effect The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned.
Repeat Finding No
Recommendation We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely.
Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education
Federal Program Name Higher Educational Institutional Aid
Assistance Listing Number 84.031X
Federal Award Identification Number and Year "
P031X220005 - 2024, P031X200005 - 2024, P031X230006 - 2024"
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/23 - 6/30/24
Compliance Requirement Affected Allowable Costs and Special Tests and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure.
Criteria or specific requirement "Per 2 CFR 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records should support 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 allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not have proper documentation of Time and Effort reporting.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 Payroll transactions, we identified 8 time and effort reports that were not documented properly to track hours worked on federal grant and 12 reports that did not have a documentation of review. Additionally during our testing of 5 key personnel with Level of Effort provisions in the grant award notification, we identified 1 key personnel did not have documentation to track hours for level of effort required by the Federal agency.
Cause The College did not have proper procedures in place to track time and effort for personnel on federal grants.
Effect The College could potentially expense incorrect amount to federal grants.
Repeat Finding No
Recommendation "We recommend the College review policies and procedures to ensure all personnel on federal grants documented time and effort reports as stated in federal regulations.
"
Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education
Federal Program Name Higher Educational Institutional Aid
Assistance Listing Number 84.031X
Federal Award Identification Number and Year "
P031X220005 - 2024, P031X230006 - 2024"
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/23 - 6/30/24
Compliance Requirement Affected Procurement
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure.
Criteria or specific requirement "The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.320.
In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not have documentation that sole source justification was provided during the procurement process.
Questioned costs: N/A
Known
Likely
Context During our testing of 5 procurement transactions, we identified 3 vendors that had sole source justifications however they were not dated to verify that the documentation was provided prior to entering the contract.
Cause The College did not have proper documentation to support the procurement process was completed prior to purchase.
Effect The College could not be in compliance with federal procurement regulations.
Repeat Finding No
Recommendation We recommend the College evaluate its procedures to ensure documentation is properly supported within their procurement files.
Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education
Federal Program Name Higher Educational Institutional Aid
Assistance Listing Number 84.031X
Federal Award Identification Number and Year "
P031X220005 - 2024, P031X200005 - 2024, P031X230006 - 2024"
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/23 - 6/30/24
Compliance Requirement Affected Allowable Costs and Special Tests and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure.
Criteria or specific requirement "Per 2 CFR 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records should support 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 allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not have proper documentation of Time and Effort reporting.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 Payroll transactions, we identified 8 time and effort reports that were not documented properly to track hours worked on federal grant and 12 reports that did not have a documentation of review. Additionally during our testing of 5 key personnel with Level of Effort provisions in the grant award notification, we identified 1 key personnel did not have documentation to track hours for level of effort required by the Federal agency.
Cause The College did not have proper procedures in place to track time and effort for personnel on federal grants.
Effect The College could potentially expense incorrect amount to federal grants.
Repeat Finding No
Recommendation "We recommend the College review policies and procedures to ensure all personnel on federal grants documented time and effort reports as stated in federal regulations.
"
Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education
Federal Program Name Higher Educational Institutional Aid
Assistance Listing Number 84.031X
Federal Award Identification Number and Year "
P031X220005 - 2024, P031X230006 - 2024"
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/23 - 6/30/24
Compliance Requirement Affected Procurement
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure.
Criteria or specific requirement "The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.320.
In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not have documentation that sole source justification was provided during the procurement process.
Questioned costs: N/A
Known
Likely
Context During our testing of 5 procurement transactions, we identified 3 vendors that had sole source justifications however they were not dated to verify that the documentation was provided prior to entering the contract.
Cause The College did not have proper documentation to support the procurement process was completed prior to purchase.
Effect The College could not be in compliance with federal procurement regulations.
Repeat Finding No
Recommendation We recommend the College evaluate its procedures to ensure documentation is properly supported within their procurement files.
Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education
Federal Program Name Higher Educational Institutional Aid
Assistance Listing Number 84.031X
Federal Award Identification Number and Year "
P031X220005 - 2024, P031X200005 - 2024, P031X230006 - 2024"
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/23 - 6/30/24
Compliance Requirement Affected Allowable Costs and Special Tests and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure.
Criteria or specific requirement "Per 2 CFR 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records should support 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 allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not have proper documentation of Time and Effort reporting.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 Payroll transactions, we identified 8 time and effort reports that were not documented properly to track hours worked on federal grant and 12 reports that did not have a documentation of review. Additionally during our testing of 5 key personnel with Level of Effort provisions in the grant award notification, we identified 1 key personnel did not have documentation to track hours for level of effort required by the Federal agency.
Cause The College did not have proper procedures in place to track time and effort for personnel on federal grants.
Effect The College could potentially expense incorrect amount to federal grants.
Repeat Finding No
Recommendation "We recommend the College review policies and procedures to ensure all personnel on federal grants documented time and effort reports as stated in federal regulations.
"
Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education
Federal Program Name Higher Educational Institutional Aid
Assistance Listing Number 84.031X
Federal Award Identification Number and Year "
P031X220005 - 2024, P031X230006 - 2024"
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/23 - 6/30/24
Compliance Requirement Affected Procurement
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure.
Criteria or specific requirement "The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.320.
In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not have documentation that sole source justification was provided during the procurement process.
Questioned costs: N/A
Known
Likely
Context During our testing of 5 procurement transactions, we identified 3 vendors that had sole source justifications however they were not dated to verify that the documentation was provided prior to entering the contract.
Cause The College did not have proper documentation to support the procurement process was completed prior to purchase.
Effect The College could not be in compliance with federal procurement regulations.
Repeat Finding No
Recommendation We recommend the College evaluate its procedures to ensure documentation is properly supported within their procurement files.
Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.063, 84.007, 84.033, 84.268
Federal Award Identification Number and Year P063P232037 - 2024, P007A233429 - 2024, P033A233429 - 2024, P268K242037 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/23 - 6/30/24
Compliance Requirement Affected Special Test and Provision
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
In addition per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified ten instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and five instance where the enrollment effective date was not reported correctly to NSLDS.
Cause The College did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner.
Effect Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding No
Recommendation We recommend that the College implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the College implement formal review procedures to document the review process.
Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.063, 84.007, 84.033, 84.268
Federal Award Identification Number and Year P063P232037 - 2024, P007A233429 - 2024, P033A233429 - 2024, P268K242037 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/23 - 6/30/24
Compliance Requirement Affected Special Tests and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment The College used the incorrect withdraw date and incorrectly performed the Return of Title IV funds calculation
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure.
Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition "The College incorrectly calculated Return to Title IV (R2T4) calculations.
"
Questioned costs: N/A
Known Not over $25k
Likely See Question Cost Tab
Context During our testing of 40 R2T4 calculations, we identified that 5 had mechanically incorrect calculations by using the incorrect withdraw date.
Cause The College was using the incorrect withdraw date
Effect The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned.
Repeat Finding No
Recommendation We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely.
Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.063, 84.007, 84.033, 84.268
Federal Award Identification Number and Year P063P232037 - 2024, P007A233429 - 2024, P033A233429 - 2024, P268K242037 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/23 - 6/30/24
Compliance Requirement Affected Special Test and Provision
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
In addition per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified ten instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and five instance where the enrollment effective date was not reported correctly to NSLDS.
Cause The College did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner.
Effect Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding No
Recommendation We recommend that the College implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the College implement formal review procedures to document the review process.
Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.063, 84.007, 84.033, 84.268
Federal Award Identification Number and Year P063P232037 - 2024, P007A233429 - 2024, P033A233429 - 2024, P268K242037 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/23 - 6/30/24
Compliance Requirement Affected Special Tests and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment The College used the incorrect withdraw date and incorrectly performed the Return of Title IV funds calculation
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure.
Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition "The College incorrectly calculated Return to Title IV (R2T4) calculations.
"
Questioned costs: N/A
Known Not over $25k
Likely See Question Cost Tab
Context During our testing of 40 R2T4 calculations, we identified that 5 had mechanically incorrect calculations by using the incorrect withdraw date.
Cause The College was using the incorrect withdraw date
Effect The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned.
Repeat Finding No
Recommendation We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely.
Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.063, 84.007, 84.033, 84.268
Federal Award Identification Number and Year P063P232037 - 2024, P007A233429 - 2024, P033A233429 - 2024, P268K242037 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/23 - 6/30/24
Compliance Requirement Affected Special Test and Provision
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
In addition per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified ten instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and five instance where the enrollment effective date was not reported correctly to NSLDS.
Cause The College did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner.
Effect Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding No
Recommendation We recommend that the College implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the College implement formal review procedures to document the review process.
Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.063, 84.007, 84.033, 84.268
Federal Award Identification Number and Year P063P232037 - 2024, P007A233429 - 2024, P033A233429 - 2024, P268K242037 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/23 - 6/30/24
Compliance Requirement Affected Special Tests and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment The College used the incorrect withdraw date and incorrectly performed the Return of Title IV funds calculation
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure.
Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition "The College incorrectly calculated Return to Title IV (R2T4) calculations.
"
Questioned costs: N/A
Known Not over $25k
Likely See Question Cost Tab
Context During our testing of 40 R2T4 calculations, we identified that 5 had mechanically incorrect calculations by using the incorrect withdraw date.
Cause The College was using the incorrect withdraw date
Effect The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned.
Repeat Finding No
Recommendation We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely.
Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.063, 84.007, 84.033, 84.268
Federal Award Identification Number and Year P063P232037 - 2024, P007A233429 - 2024, P033A233429 - 2024, P268K242037 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/23 - 6/30/24
Compliance Requirement Affected Special Test and Provision
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
In addition per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified ten instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and five instance where the enrollment effective date was not reported correctly to NSLDS.
Cause The College did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner.
Effect Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding No
Recommendation We recommend that the College implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the College implement formal review procedures to document the review process.
Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.063, 84.007, 84.033, 84.268
Federal Award Identification Number and Year P063P232037 - 2024, P007A233429 - 2024, P033A233429 - 2024, P268K242037 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/23 - 6/30/24
Compliance Requirement Affected Special Tests and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment The College used the incorrect withdraw date and incorrectly performed the Return of Title IV funds calculation
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure.
Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition "The College incorrectly calculated Return to Title IV (R2T4) calculations.
"
Questioned costs: N/A
Known Not over $25k
Likely See Question Cost Tab
Context During our testing of 40 R2T4 calculations, we identified that 5 had mechanically incorrect calculations by using the incorrect withdraw date.
Cause The College was using the incorrect withdraw date
Effect The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned.
Repeat Finding No
Recommendation We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely.
Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education
Federal Program Name Higher Educational Institutional Aid
Assistance Listing Number 84.031X
Federal Award Identification Number and Year "
P031X220005 - 2024, P031X200005 - 2024, P031X230006 - 2024"
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/23 - 6/30/24
Compliance Requirement Affected Allowable Costs and Special Tests and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure.
Criteria or specific requirement "Per 2 CFR 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records should support 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 allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not have proper documentation of Time and Effort reporting.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 Payroll transactions, we identified 8 time and effort reports that were not documented properly to track hours worked on federal grant and 12 reports that did not have a documentation of review. Additionally during our testing of 5 key personnel with Level of Effort provisions in the grant award notification, we identified 1 key personnel did not have documentation to track hours for level of effort required by the Federal agency.
Cause The College did not have proper procedures in place to track time and effort for personnel on federal grants.
Effect The College could potentially expense incorrect amount to federal grants.
Repeat Finding No
Recommendation "We recommend the College review policies and procedures to ensure all personnel on federal grants documented time and effort reports as stated in federal regulations.
"
Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education
Federal Program Name Higher Educational Institutional Aid
Assistance Listing Number 84.031X
Federal Award Identification Number and Year "
P031X220005 - 2024, P031X230006 - 2024"
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/23 - 6/30/24
Compliance Requirement Affected Procurement
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure.
Criteria or specific requirement "The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.320.
In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not have documentation that sole source justification was provided during the procurement process.
Questioned costs: N/A
Known
Likely
Context During our testing of 5 procurement transactions, we identified 3 vendors that had sole source justifications however they were not dated to verify that the documentation was provided prior to entering the contract.
Cause The College did not have proper documentation to support the procurement process was completed prior to purchase.
Effect The College could not be in compliance with federal procurement regulations.
Repeat Finding No
Recommendation We recommend the College evaluate its procedures to ensure documentation is properly supported within their procurement files.
Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education
Federal Program Name Higher Educational Institutional Aid
Assistance Listing Number 84.031X
Federal Award Identification Number and Year "
P031X220005 - 2024, P031X200005 - 2024, P031X230006 - 2024"
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/23 - 6/30/24
Compliance Requirement Affected Allowable Costs and Special Tests and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure.
Criteria or specific requirement "Per 2 CFR 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records should support 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 allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not have proper documentation of Time and Effort reporting.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 Payroll transactions, we identified 8 time and effort reports that were not documented properly to track hours worked on federal grant and 12 reports that did not have a documentation of review. Additionally during our testing of 5 key personnel with Level of Effort provisions in the grant award notification, we identified 1 key personnel did not have documentation to track hours for level of effort required by the Federal agency.
Cause The College did not have proper procedures in place to track time and effort for personnel on federal grants.
Effect The College could potentially expense incorrect amount to federal grants.
Repeat Finding No
Recommendation "We recommend the College review policies and procedures to ensure all personnel on federal grants documented time and effort reports as stated in federal regulations.
"
Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education
Federal Program Name Higher Educational Institutional Aid
Assistance Listing Number 84.031X
Federal Award Identification Number and Year "
P031X220005 - 2024, P031X230006 - 2024"
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/23 - 6/30/24
Compliance Requirement Affected Procurement
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure.
Criteria or specific requirement "The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.320.
In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not have documentation that sole source justification was provided during the procurement process.
Questioned costs: N/A
Known
Likely
Context During our testing of 5 procurement transactions, we identified 3 vendors that had sole source justifications however they were not dated to verify that the documentation was provided prior to entering the contract.
Cause The College did not have proper documentation to support the procurement process was completed prior to purchase.
Effect The College could not be in compliance with federal procurement regulations.
Repeat Finding No
Recommendation We recommend the College evaluate its procedures to ensure documentation is properly supported within their procurement files.
Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education
Federal Program Name Higher Educational Institutional Aid
Assistance Listing Number 84.031X
Federal Award Identification Number and Year "
P031X220005 - 2024, P031X200005 - 2024, P031X230006 - 2024"
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/23 - 6/30/24
Compliance Requirement Affected Allowable Costs and Special Tests and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure.
Criteria or specific requirement "Per 2 CFR 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records should support 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 allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not have proper documentation of Time and Effort reporting.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 Payroll transactions, we identified 8 time and effort reports that were not documented properly to track hours worked on federal grant and 12 reports that did not have a documentation of review. Additionally during our testing of 5 key personnel with Level of Effort provisions in the grant award notification, we identified 1 key personnel did not have documentation to track hours for level of effort required by the Federal agency.
Cause The College did not have proper procedures in place to track time and effort for personnel on federal grants.
Effect The College could potentially expense incorrect amount to federal grants.
Repeat Finding No
Recommendation "We recommend the College review policies and procedures to ensure all personnel on federal grants documented time and effort reports as stated in federal regulations.
"
Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education
Federal Program Name Higher Educational Institutional Aid
Assistance Listing Number 84.031X
Federal Award Identification Number and Year "
P031X220005 - 2024, P031X230006 - 2024"
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/23 - 6/30/24
Compliance Requirement Affected Procurement
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure.
Criteria or specific requirement "The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.320.
In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not have documentation that sole source justification was provided during the procurement process.
Questioned costs: N/A
Known
Likely
Context During our testing of 5 procurement transactions, we identified 3 vendors that had sole source justifications however they were not dated to verify that the documentation was provided prior to entering the contract.
Cause The College did not have proper documentation to support the procurement process was completed prior to purchase.
Effect The College could not be in compliance with federal procurement regulations.
Repeat Finding No
Recommendation We recommend the College evaluate its procedures to ensure documentation is properly supported within their procurement files.
Views of Responsible Officials Management agrees with this finding.