Audit 340980

FY End
2024-06-30
Total Expended
$12.72M
Findings
4
Programs
11
Organization: Northwestern Michigan College (MI)
Year: 2024 Accepted: 2025-02-03

Organization Exclusion Status:

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Findings

ID Ref Severity Repeat Requirement
521069 2024-001 Material Weakness - N
521070 2024-002 Material Weakness - B
1097511 2024-001 Material Weakness - N
1097512 2024-002 Material Weakness - B

Contacts

Name Title Type
KZAJC42FB5D3 Lindsey Lipke Auditee
2319951943 Katie Thornton Auditor
No contacts on file

Notes to SEFA

Accounting Policies: The accompanying schedule of expenditures of federal awards (the “Schedule”) includes the federal grant activity of Northwestern Michigan College (the “College”) under programs of the federal government for the year ended June 30, 2024. The information in the Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the “Uniform Guidance”). Because the Schedule presents only a selected portion of the operations of the College, it is not intended to and does not present the financial position, changes in net position, or cash flows of the College. Expenditures reported in the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. The pass through entity identifying numbers are presented where available. The College has elected not to use the 10 percent de minimis indirect cost rate to recover indirect costs, as allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: The College has elected not to use the 10 percent de minimis indirect cost rate to recover indirect costs, as allowed under the Uniform Guidance.

Finding Details

Assistance Listing, Federal Agency, and Program Name - 84.268, U.S. Department of Education, Student Financial Assistance Program - Federal Direct Student Loan Program Federal Award Identification Number and Year - P268K241647, 2023 2024 Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - For direct loan disbursement, the institution must provide timely notification to the student of the (1) date and amount of the disbursement, (2 student/parent’s right to cancel, and (3) procedure and time by which the student or parent must notify the institution that he or she wishes to cancel (34 CFR 668.165). Condition - The College did not provide notifications to certain students related to direct loan disbursements. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were 16 students receiving direct loans in a sample of 25 students for disbursements did not receive the notification. Cause and Effect - A control was lacking to ensure the notifications were sent to all students receiving direct loans. Recommendation - We recommend a control be implemented to ensure notifications are sent to all students receiving direct loans. Views of Responsible Officials and Corrective Action Plan - While the College has documented procedures in place for the disbursement of federal funds and required post disbursement notifications to students, the College did not properly send a post disbursement notification to 591 out of 659 students who received federal financial aid loans in Fall 2023. The College will adjust its internal processes to ensure all students who receive federal loans are sent post disbursement email notifications by performing a weekly review of the report that generates a names list of students that are receiving federal loans. If names exist on the report, a verification in the student record will be conducted to be sure the email was sent. After further investigation, all 608 students that received federal loans in spring semester of 2024 and all 56 students in summer of 2024 received a post disbursement notification.
Assistance Listing, Federal Agency, and Program Name - 21.027, Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of Treasury, ADN to BSN Completion Grant Program Federal Award Identification Number and Year - SLFRP0127, 2023 2026 Pass-through Entity - Michigan Department of Labor and Economic Opportunity Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in Standards for Internal Control in the Federal Government, issued by the Comptroller General of the United States, or the Internal Control Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Costs must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E. Condition - The College's internal control in place for manual journal entries did not identify unallowable costs reported in the SEFA. Questioned Costs - $326,781 Identification of How Questioned Costs Were Computed - Questioned costs are made up of unallowable direct costs of $233,415 and the related indirect cost at 40 percent of $93,366, totaling $326,781. Context - A manual journal entry reviewed and approved included unallowable costs, which also impacted the determination of indirect costs charged to the grant in a separate manual journal entry. Therefore, the error is made up of two manual journal entries selected for testing out of 40 total expenditures. The error represented 36 percent of the original amount reported on the SEFA, or $880,303. As a result, $326,781 was removed from the SEFA. Cause and Effect - Due to an ineffective review of manual journal entries, the grant expenditures reported to the grantor and the amount reported on the original SEFA provided by management for the grant were overstated. Recommendation - We recommend an effective review of manual journal entries be put in place. Views of Responsible Officials and Planned Corrective Actions - While the College currently has controls in place to review all manual journal entries, we will adjust our review process going forward to incorporate additional oversight for any manual journal entries impacting federal grants. Going forward, the controller will review all manual journal entries impacting federal grants, and the vice president of finance will provide a second level review of any such entries that equal or exceed $50,000.
Assistance Listing, Federal Agency, and Program Name - 84.268, U.S. Department of Education, Student Financial Assistance Program - Federal Direct Student Loan Program Federal Award Identification Number and Year - P268K241647, 2023 2024 Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - For direct loan disbursement, the institution must provide timely notification to the student of the (1) date and amount of the disbursement, (2 student/parent’s right to cancel, and (3) procedure and time by which the student or parent must notify the institution that he or she wishes to cancel (34 CFR 668.165). Condition - The College did not provide notifications to certain students related to direct loan disbursements. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were 16 students receiving direct loans in a sample of 25 students for disbursements did not receive the notification. Cause and Effect - A control was lacking to ensure the notifications were sent to all students receiving direct loans. Recommendation - We recommend a control be implemented to ensure notifications are sent to all students receiving direct loans. Views of Responsible Officials and Corrective Action Plan - While the College has documented procedures in place for the disbursement of federal funds and required post disbursement notifications to students, the College did not properly send a post disbursement notification to 591 out of 659 students who received federal financial aid loans in Fall 2023. The College will adjust its internal processes to ensure all students who receive federal loans are sent post disbursement email notifications by performing a weekly review of the report that generates a names list of students that are receiving federal loans. If names exist on the report, a verification in the student record will be conducted to be sure the email was sent. After further investigation, all 608 students that received federal loans in spring semester of 2024 and all 56 students in summer of 2024 received a post disbursement notification.
Assistance Listing, Federal Agency, and Program Name - 21.027, Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of Treasury, ADN to BSN Completion Grant Program Federal Award Identification Number and Year - SLFRP0127, 2023 2026 Pass-through Entity - Michigan Department of Labor and Economic Opportunity Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in Standards for Internal Control in the Federal Government, issued by the Comptroller General of the United States, or the Internal Control Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Costs must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E. Condition - The College's internal control in place for manual journal entries did not identify unallowable costs reported in the SEFA. Questioned Costs - $326,781 Identification of How Questioned Costs Were Computed - Questioned costs are made up of unallowable direct costs of $233,415 and the related indirect cost at 40 percent of $93,366, totaling $326,781. Context - A manual journal entry reviewed and approved included unallowable costs, which also impacted the determination of indirect costs charged to the grant in a separate manual journal entry. Therefore, the error is made up of two manual journal entries selected for testing out of 40 total expenditures. The error represented 36 percent of the original amount reported on the SEFA, or $880,303. As a result, $326,781 was removed from the SEFA. Cause and Effect - Due to an ineffective review of manual journal entries, the grant expenditures reported to the grantor and the amount reported on the original SEFA provided by management for the grant were overstated. Recommendation - We recommend an effective review of manual journal entries be put in place. Views of Responsible Officials and Planned Corrective Actions - While the College currently has controls in place to review all manual journal entries, we will adjust our review process going forward to incorporate additional oversight for any manual journal entries impacting federal grants. Going forward, the controller will review all manual journal entries impacting federal grants, and the vice president of finance will provide a second level review of any such entries that equal or exceed $50,000.