Finding 2024-002 – Allowable Costs & Activities (Significant Deficiency and Noncompliance)
Information on the Federal Program: U.S. Department of Education, Assistance listing # 84.031
Higher Education Institutional Aid and U.S. Department of Education, Trio Cluster
Criteria: 2 CFR Part 200 Subpart E establishes cost principles to apply in determining costs under
federal awards. Non-federal entities are also required to establish controls over the disbursement
process to ensure compliance with allowable cost requirements.Condition: We selected a sample of 25 non-payroll disbursements each for Title III and Trio
programs and three indirect costs for the Trio program. Of the 25 non-payroll disbursements for
Title III, two expenses were allocated but the portion charged to the grant did not tie back to the
invoice, two expenses were incurred in the prior fiscal year but recorded as current year expenses,
and two types of expenses were not in the applicable budgets.
Of the 25 non-payroll disbursements for the Trio Cluster, one type of expense exceeded the budget
amount and of the three indirect cost calculations, one was not calculated correctly.
Cause: On Title III, the College charged a portion of invoices to the grant but the amount could not
be recalculated based on the invoice; meals and subscriptions were charged to the grant but the
type of expense was not in the budget; and services were performed or orders were placed in the
prior year but recognized as current year expenses.
On the Trio Cluster, and equipment expenses were charged to the Trio grant but exceeded the
grant budget. The indirect cost calculation included previously recorded indirect costs in the base
used to recognize and request reimbursement for allowed percentage.
Effect: The College did not comply with the exceptions noted for allowable cost and activity
requirements.
Questioned Costs: Title III $10,261 and Trio Cluster $4,810.
Recommendation: We recommend the College strengthen its policies and procedures surrounding
non-payroll grant disbursements to ensure disbursements are approved, allowable, and calculations
supported.
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.
Finding 2024-002 – Allowable Costs & Activities (Significant Deficiency and Noncompliance)
Information on the Federal Program: U.S. Department of Education, Assistance listing # 84.031
Higher Education Institutional Aid and U.S. Department of Education, Trio Cluster
Criteria: 2 CFR Part 200 Subpart E establishes cost principles to apply in determining costs under
federal awards. Non-federal entities are also required to establish controls over the disbursement
process to ensure compliance with allowable cost requirements.Condition: We selected a sample of 25 non-payroll disbursements each for Title III and Trio
programs and three indirect costs for the Trio program. Of the 25 non-payroll disbursements for
Title III, two expenses were allocated but the portion charged to the grant did not tie back to the
invoice, two expenses were incurred in the prior fiscal year but recorded as current year expenses,
and two types of expenses were not in the applicable budgets.
Of the 25 non-payroll disbursements for the Trio Cluster, one type of expense exceeded the budget
amount and of the three indirect cost calculations, one was not calculated correctly.
Cause: On Title III, the College charged a portion of invoices to the grant but the amount could not
be recalculated based on the invoice; meals and subscriptions were charged to the grant but the
type of expense was not in the budget; and services were performed or orders were placed in the
prior year but recognized as current year expenses.
On the Trio Cluster, and equipment expenses were charged to the Trio grant but exceeded the
grant budget. The indirect cost calculation included previously recorded indirect costs in the base
used to recognize and request reimbursement for allowed percentage.
Effect: The College did not comply with the exceptions noted for allowable cost and activity
requirements.
Questioned Costs: Title III $10,261 and Trio Cluster $4,810.
Recommendation: We recommend the College strengthen its policies and procedures surrounding
non-payroll grant disbursements to ensure disbursements are approved, allowable, and calculations
supported.
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.
Finding 2024-003 – Allowable Costs & Activities (Significant Deficiency and Noncompliance)
Information on the Federal Program: U.S. Department of Education, Assistance listing # 84.031
Higher Education Institutional Aid and U.S. Department of Education, Trio Cluster
Criteria: 2 CFR Part 200 Subpart E establishes cost principles to apply in determining costs under
federal awards. Non-federal entities are also required to establish controls over the disbursement
process to ensure compliance with allowable cost requirements.
Condition: We selected a sample of six payroll disbursements for Title III and eleven payroll
disbursements for the Trio programs. Of the six payroll disbursements for Title III, four exceptions
were noted related to approved pay rate documentation. In one instance the position was not in the
grant budget and in three instances, the approved pay rate did not agree to the actual paycheck
amount. Of the eleven payroll disbursements for the Trio Cluster, thirty-two employees were included. Of
these thirty-two, twenty-one exceptions were noted for lack of proper support. Nineteen exceptions
were noted in which the actual pay rate did not agree to the budgeted pay rate; two employees’ job
descriptions did not fall under an allowable position in the grant budget; one journal entry
reclassified payroll costs but the support for pay rate and time charged were not provided; and one
employee received additional pay over the approved letter of appointment, and there was no
support for the percent charged to the program.
Cause: Payroll costs charged to the grants were not properly documented.
Effect: The College did not comply with all allowable cost and activity requirements.
The College did not comply with the exceptions noted for allowable cost and activity requirements.
Questioned Costs: Title III $4,119 and Trio Cluster $25,655.
Recommendation: We recommend the College strengthen its policies and procedures surrounding
payroll grant disbursements to ensure expenses are properly approved and allowable under the
specific grant budget.
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.
Finding 2024-003 – Allowable Costs & Activities (Significant Deficiency and Noncompliance)
Information on the Federal Program: U.S. Department of Education, Assistance listing # 84.031
Higher Education Institutional Aid and U.S. Department of Education, Trio Cluster
Criteria: 2 CFR Part 200 Subpart E establishes cost principles to apply in determining costs under
federal awards. Non-federal entities are also required to establish controls over the disbursement
process to ensure compliance with allowable cost requirements.
Condition: We selected a sample of six payroll disbursements for Title III and eleven payroll
disbursements for the Trio programs. Of the six payroll disbursements for Title III, four exceptions
were noted related to approved pay rate documentation. In one instance the position was not in the
grant budget and in three instances, the approved pay rate did not agree to the actual paycheck
amount. Of the eleven payroll disbursements for the Trio Cluster, thirty-two employees were included. Of
these thirty-two, twenty-one exceptions were noted for lack of proper support. Nineteen exceptions
were noted in which the actual pay rate did not agree to the budgeted pay rate; two employees’ job
descriptions did not fall under an allowable position in the grant budget; one journal entry
reclassified payroll costs but the support for pay rate and time charged were not provided; and one
employee received additional pay over the approved letter of appointment, and there was no
support for the percent charged to the program.
Cause: Payroll costs charged to the grants were not properly documented.
Effect: The College did not comply with all allowable cost and activity requirements.
The College did not comply with the exceptions noted for allowable cost and activity requirements.
Questioned Costs: Title III $4,119 and Trio Cluster $25,655.
Recommendation: We recommend the College strengthen its policies and procedures surrounding
payroll grant disbursements to ensure expenses are properly approved and allowable under the
specific grant budget.
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.
Finding 2024-002 – Allowable Costs & Activities (Significant Deficiency and Noncompliance)
Information on the Federal Program: U.S. Department of Education, Assistance listing # 84.031
Higher Education Institutional Aid and U.S. Department of Education, Trio Cluster
Criteria: 2 CFR Part 200 Subpart E establishes cost principles to apply in determining costs under
federal awards. Non-federal entities are also required to establish controls over the disbursement
process to ensure compliance with allowable cost requirements.Condition: We selected a sample of 25 non-payroll disbursements each for Title III and Trio
programs and three indirect costs for the Trio program. Of the 25 non-payroll disbursements for
Title III, two expenses were allocated but the portion charged to the grant did not tie back to the
invoice, two expenses were incurred in the prior fiscal year but recorded as current year expenses,
and two types of expenses were not in the applicable budgets.
Of the 25 non-payroll disbursements for the Trio Cluster, one type of expense exceeded the budget
amount and of the three indirect cost calculations, one was not calculated correctly.
Cause: On Title III, the College charged a portion of invoices to the grant but the amount could not
be recalculated based on the invoice; meals and subscriptions were charged to the grant but the
type of expense was not in the budget; and services were performed or orders were placed in the
prior year but recognized as current year expenses.
On the Trio Cluster, and equipment expenses were charged to the Trio grant but exceeded the
grant budget. The indirect cost calculation included previously recorded indirect costs in the base
used to recognize and request reimbursement for allowed percentage.
Effect: The College did not comply with the exceptions noted for allowable cost and activity
requirements.
Questioned Costs: Title III $10,261 and Trio Cluster $4,810.
Recommendation: We recommend the College strengthen its policies and procedures surrounding
non-payroll grant disbursements to ensure disbursements are approved, allowable, and calculations
supported.
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.
Finding 2024-003 – Allowable Costs & Activities (Significant Deficiency and Noncompliance)
Information on the Federal Program: U.S. Department of Education, Assistance listing # 84.031
Higher Education Institutional Aid and U.S. Department of Education, Trio Cluster
Criteria: 2 CFR Part 200 Subpart E establishes cost principles to apply in determining costs under
federal awards. Non-federal entities are also required to establish controls over the disbursement
process to ensure compliance with allowable cost requirements.
Condition: We selected a sample of six payroll disbursements for Title III and eleven payroll
disbursements for the Trio programs. Of the six payroll disbursements for Title III, four exceptions
were noted related to approved pay rate documentation. In one instance the position was not in the
grant budget and in three instances, the approved pay rate did not agree to the actual paycheck
amount. Of the eleven payroll disbursements for the Trio Cluster, thirty-two employees were included. Of
these thirty-two, twenty-one exceptions were noted for lack of proper support. Nineteen exceptions
were noted in which the actual pay rate did not agree to the budgeted pay rate; two employees’ job
descriptions did not fall under an allowable position in the grant budget; one journal entry
reclassified payroll costs but the support for pay rate and time charged were not provided; and one
employee received additional pay over the approved letter of appointment, and there was no
support for the percent charged to the program.
Cause: Payroll costs charged to the grants were not properly documented.
Effect: The College did not comply with all allowable cost and activity requirements.
The College did not comply with the exceptions noted for allowable cost and activity requirements.
Questioned Costs: Title III $4,119 and Trio Cluster $25,655.
Recommendation: We recommend the College strengthen its policies and procedures surrounding
payroll grant disbursements to ensure expenses are properly approved and allowable under the
specific grant budget.
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.
Finding 2024-001 – Procurement (Significant Deficiency and Noncompliance)
Information on the Federal Program: U.S. Department of Education, Assistance listing # 84.031
Higher Education Institutional Aid
Criteria: 2 CFR 200.317-327 establishes procurement standards for non-federal entities. This
includes different requirements based on the amount of purchases made from the vendor during the
year.
Condition: Of ten vendors tested, one vendor’s services was not properly bid and one vendor was
paid over the micro-purchase threshold and therefore should have obtained price or rate quotes.
Cause: The College contracted with a vendor for consulting and then retained them for on-going
services. These services were not bid. The other vendor was paid more than the micro-purchase
threshold during the year, but price or rate quotes were not obtained for purchases.
Effect: The College did not comply with federal procurement requirements for these two
exceptions.
Questioned Costs: $856,476
Recommendation: We recommend the College strengthen its policies and procedures over
procurement to ensure vendors are properly procured.
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.
Finding 2024-002 – Allowable Costs & Activities (Significant Deficiency and Noncompliance)
Information on the Federal Program: U.S. Department of Education, Assistance listing # 84.031
Higher Education Institutional Aid and U.S. Department of Education, Trio Cluster
Criteria: 2 CFR Part 200 Subpart E establishes cost principles to apply in determining costs under
federal awards. Non-federal entities are also required to establish controls over the disbursement
process to ensure compliance with allowable cost requirements.Condition: We selected a sample of 25 non-payroll disbursements each for Title III and Trio
programs and three indirect costs for the Trio program. Of the 25 non-payroll disbursements for
Title III, two expenses were allocated but the portion charged to the grant did not tie back to the
invoice, two expenses were incurred in the prior fiscal year but recorded as current year expenses,
and two types of expenses were not in the applicable budgets.
Of the 25 non-payroll disbursements for the Trio Cluster, one type of expense exceeded the budget
amount and of the three indirect cost calculations, one was not calculated correctly.
Cause: On Title III, the College charged a portion of invoices to the grant but the amount could not
be recalculated based on the invoice; meals and subscriptions were charged to the grant but the
type of expense was not in the budget; and services were performed or orders were placed in the
prior year but recognized as current year expenses.
On the Trio Cluster, and equipment expenses were charged to the Trio grant but exceeded the
grant budget. The indirect cost calculation included previously recorded indirect costs in the base
used to recognize and request reimbursement for allowed percentage.
Effect: The College did not comply with the exceptions noted for allowable cost and activity
requirements.
Questioned Costs: Title III $10,261 and Trio Cluster $4,810.
Recommendation: We recommend the College strengthen its policies and procedures surrounding
non-payroll grant disbursements to ensure disbursements are approved, allowable, and calculations
supported.
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.
Finding 2024-002 – Allowable Costs & Activities (Significant Deficiency and Noncompliance)
Information on the Federal Program: U.S. Department of Education, Assistance listing # 84.031
Higher Education Institutional Aid and U.S. Department of Education, Trio Cluster
Criteria: 2 CFR Part 200 Subpart E establishes cost principles to apply in determining costs under
federal awards. Non-federal entities are also required to establish controls over the disbursement
process to ensure compliance with allowable cost requirements.Condition: We selected a sample of 25 non-payroll disbursements each for Title III and Trio
programs and three indirect costs for the Trio program. Of the 25 non-payroll disbursements for
Title III, two expenses were allocated but the portion charged to the grant did not tie back to the
invoice, two expenses were incurred in the prior fiscal year but recorded as current year expenses,
and two types of expenses were not in the applicable budgets.
Of the 25 non-payroll disbursements for the Trio Cluster, one type of expense exceeded the budget
amount and of the three indirect cost calculations, one was not calculated correctly.
Cause: On Title III, the College charged a portion of invoices to the grant but the amount could not
be recalculated based on the invoice; meals and subscriptions were charged to the grant but the
type of expense was not in the budget; and services were performed or orders were placed in the
prior year but recognized as current year expenses.
On the Trio Cluster, and equipment expenses were charged to the Trio grant but exceeded the
grant budget. The indirect cost calculation included previously recorded indirect costs in the base
used to recognize and request reimbursement for allowed percentage.
Effect: The College did not comply with the exceptions noted for allowable cost and activity
requirements.
Questioned Costs: Title III $10,261 and Trio Cluster $4,810.
Recommendation: We recommend the College strengthen its policies and procedures surrounding
non-payroll grant disbursements to ensure disbursements are approved, allowable, and calculations
supported.
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.
Finding 2024-003 – Allowable Costs & Activities (Significant Deficiency and Noncompliance)
Information on the Federal Program: U.S. Department of Education, Assistance listing # 84.031
Higher Education Institutional Aid and U.S. Department of Education, Trio Cluster
Criteria: 2 CFR Part 200 Subpart E establishes cost principles to apply in determining costs under
federal awards. Non-federal entities are also required to establish controls over the disbursement
process to ensure compliance with allowable cost requirements.
Condition: We selected a sample of six payroll disbursements for Title III and eleven payroll
disbursements for the Trio programs. Of the six payroll disbursements for Title III, four exceptions
were noted related to approved pay rate documentation. In one instance the position was not in the
grant budget and in three instances, the approved pay rate did not agree to the actual paycheck
amount. Of the eleven payroll disbursements for the Trio Cluster, thirty-two employees were included. Of
these thirty-two, twenty-one exceptions were noted for lack of proper support. Nineteen exceptions
were noted in which the actual pay rate did not agree to the budgeted pay rate; two employees’ job
descriptions did not fall under an allowable position in the grant budget; one journal entry
reclassified payroll costs but the support for pay rate and time charged were not provided; and one
employee received additional pay over the approved letter of appointment, and there was no
support for the percent charged to the program.
Cause: Payroll costs charged to the grants were not properly documented.
Effect: The College did not comply with all allowable cost and activity requirements.
The College did not comply with the exceptions noted for allowable cost and activity requirements.
Questioned Costs: Title III $4,119 and Trio Cluster $25,655.
Recommendation: We recommend the College strengthen its policies and procedures surrounding
payroll grant disbursements to ensure expenses are properly approved and allowable under the
specific grant budget.
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.
Finding 2024-003 – Allowable Costs & Activities (Significant Deficiency and Noncompliance)
Information on the Federal Program: U.S. Department of Education, Assistance listing # 84.031
Higher Education Institutional Aid and U.S. Department of Education, Trio Cluster
Criteria: 2 CFR Part 200 Subpart E establishes cost principles to apply in determining costs under
federal awards. Non-federal entities are also required to establish controls over the disbursement
process to ensure compliance with allowable cost requirements.
Condition: We selected a sample of six payroll disbursements for Title III and eleven payroll
disbursements for the Trio programs. Of the six payroll disbursements for Title III, four exceptions
were noted related to approved pay rate documentation. In one instance the position was not in the
grant budget and in three instances, the approved pay rate did not agree to the actual paycheck
amount. Of the eleven payroll disbursements for the Trio Cluster, thirty-two employees were included. Of
these thirty-two, twenty-one exceptions were noted for lack of proper support. Nineteen exceptions
were noted in which the actual pay rate did not agree to the budgeted pay rate; two employees’ job
descriptions did not fall under an allowable position in the grant budget; one journal entry
reclassified payroll costs but the support for pay rate and time charged were not provided; and one
employee received additional pay over the approved letter of appointment, and there was no
support for the percent charged to the program.
Cause: Payroll costs charged to the grants were not properly documented.
Effect: The College did not comply with all allowable cost and activity requirements.
The College did not comply with the exceptions noted for allowable cost and activity requirements.
Questioned Costs: Title III $4,119 and Trio Cluster $25,655.
Recommendation: We recommend the College strengthen its policies and procedures surrounding
payroll grant disbursements to ensure expenses are properly approved and allowable under the
specific grant budget.
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.
Finding 2024-002 – Allowable Costs & Activities (Significant Deficiency and Noncompliance)
Information on the Federal Program: U.S. Department of Education, Assistance listing # 84.031
Higher Education Institutional Aid and U.S. Department of Education, Trio Cluster
Criteria: 2 CFR Part 200 Subpart E establishes cost principles to apply in determining costs under
federal awards. Non-federal entities are also required to establish controls over the disbursement
process to ensure compliance with allowable cost requirements.Condition: We selected a sample of 25 non-payroll disbursements each for Title III and Trio
programs and three indirect costs for the Trio program. Of the 25 non-payroll disbursements for
Title III, two expenses were allocated but the portion charged to the grant did not tie back to the
invoice, two expenses were incurred in the prior fiscal year but recorded as current year expenses,
and two types of expenses were not in the applicable budgets.
Of the 25 non-payroll disbursements for the Trio Cluster, one type of expense exceeded the budget
amount and of the three indirect cost calculations, one was not calculated correctly.
Cause: On Title III, the College charged a portion of invoices to the grant but the amount could not
be recalculated based on the invoice; meals and subscriptions were charged to the grant but the
type of expense was not in the budget; and services were performed or orders were placed in the
prior year but recognized as current year expenses.
On the Trio Cluster, and equipment expenses were charged to the Trio grant but exceeded the
grant budget. The indirect cost calculation included previously recorded indirect costs in the base
used to recognize and request reimbursement for allowed percentage.
Effect: The College did not comply with the exceptions noted for allowable cost and activity
requirements.
Questioned Costs: Title III $10,261 and Trio Cluster $4,810.
Recommendation: We recommend the College strengthen its policies and procedures surrounding
non-payroll grant disbursements to ensure disbursements are approved, allowable, and calculations
supported.
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.
Finding 2024-003 – Allowable Costs & Activities (Significant Deficiency and Noncompliance)
Information on the Federal Program: U.S. Department of Education, Assistance listing # 84.031
Higher Education Institutional Aid and U.S. Department of Education, Trio Cluster
Criteria: 2 CFR Part 200 Subpart E establishes cost principles to apply in determining costs under
federal awards. Non-federal entities are also required to establish controls over the disbursement
process to ensure compliance with allowable cost requirements.
Condition: We selected a sample of six payroll disbursements for Title III and eleven payroll
disbursements for the Trio programs. Of the six payroll disbursements for Title III, four exceptions
were noted related to approved pay rate documentation. In one instance the position was not in the
grant budget and in three instances, the approved pay rate did not agree to the actual paycheck
amount. Of the eleven payroll disbursements for the Trio Cluster, thirty-two employees were included. Of
these thirty-two, twenty-one exceptions were noted for lack of proper support. Nineteen exceptions
were noted in which the actual pay rate did not agree to the budgeted pay rate; two employees’ job
descriptions did not fall under an allowable position in the grant budget; one journal entry
reclassified payroll costs but the support for pay rate and time charged were not provided; and one
employee received additional pay over the approved letter of appointment, and there was no
support for the percent charged to the program.
Cause: Payroll costs charged to the grants were not properly documented.
Effect: The College did not comply with all allowable cost and activity requirements.
The College did not comply with the exceptions noted for allowable cost and activity requirements.
Questioned Costs: Title III $4,119 and Trio Cluster $25,655.
Recommendation: We recommend the College strengthen its policies and procedures surrounding
payroll grant disbursements to ensure expenses are properly approved and allowable under the
specific grant budget.
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.
Finding 2024-001 – Procurement (Significant Deficiency and Noncompliance)
Information on the Federal Program: U.S. Department of Education, Assistance listing # 84.031
Higher Education Institutional Aid
Criteria: 2 CFR 200.317-327 establishes procurement standards for non-federal entities. This
includes different requirements based on the amount of purchases made from the vendor during the
year.
Condition: Of ten vendors tested, one vendor’s services was not properly bid and one vendor was
paid over the micro-purchase threshold and therefore should have obtained price or rate quotes.
Cause: The College contracted with a vendor for consulting and then retained them for on-going
services. These services were not bid. The other vendor was paid more than the micro-purchase
threshold during the year, but price or rate quotes were not obtained for purchases.
Effect: The College did not comply with federal procurement requirements for these two
exceptions.
Questioned Costs: $856,476
Recommendation: We recommend the College strengthen its policies and procedures over
procurement to ensure vendors are properly procured.
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.