2024-002: Procurement over Small Purchase Transactions (Research and Development Grants)
Material Weakness / Material Noncompliance
Federal Program(s): Research and Development Cluster
Assistance Listing Number(s):
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Criteria: Procurement methods established under 2 CFR 200.320, requires price or rate quotations to be obtained from an adequate number of qualified sources when the aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold of $10,000, but less than the simplified acquisition threshold of $250,000.
Condition: The College did not obtain price or rate quotations obtained from different qualified transactions for all small purchase transactions sampled under the Research and Development Cluster Grants.
Cause: The College did not have a procurement policy in place during the year ended June 30, 2024 that required price or rate quotations for small purchases.
Effect or Potential Effect: Noncompliance with procurement requirements could result in unethical purchasing practices or overspending.
Questioned Costs: Undeterminable
Context: We tested 3 small purchase vendor transactions from the Research and Development Cluster totaling approximately $152,000 where no price or rate quotations were obtained prior to payment. The total population of small vendor purchases within this federal program was $422,246.
Repeat Finding: No
Recommendation: We recommend the College review its procurement policy to ensure it is in compliance with 2 CFR 200 Uniform Guidance and implement controls to ensure an audit trail is maintained surrounding the procurement of vendors using federal funds.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-002: Procurement over Small Purchase Transactions (Research and Development Grants)
Material Weakness / Material Noncompliance
Federal Program(s): Research and Development Cluster
Assistance Listing Number(s):
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Criteria: Procurement methods established under 2 CFR 200.320, requires price or rate quotations to be obtained from an adequate number of qualified sources when the aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold of $10,000, but less than the simplified acquisition threshold of $250,000.
Condition: The College did not obtain price or rate quotations obtained from different qualified transactions for all small purchase transactions sampled under the Research and Development Cluster Grants.
Cause: The College did not have a procurement policy in place during the year ended June 30, 2024 that required price or rate quotations for small purchases.
Effect or Potential Effect: Noncompliance with procurement requirements could result in unethical purchasing practices or overspending.
Questioned Costs: Undeterminable
Context: We tested 3 small purchase vendor transactions from the Research and Development Cluster totaling approximately $152,000 where no price or rate quotations were obtained prior to payment. The total population of small vendor purchases within this federal program was $422,246.
Repeat Finding: No
Recommendation: We recommend the College review its procurement policy to ensure it is in compliance with 2 CFR 200 Uniform Guidance and implement controls to ensure an audit trail is maintained surrounding the procurement of vendors using federal funds.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-002: Procurement over Small Purchase Transactions (Research and Development Grants)
Material Weakness / Material Noncompliance
Federal Program(s): Research and Development Cluster
Assistance Listing Number(s):
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Criteria: Procurement methods established under 2 CFR 200.320, requires price or rate quotations to be obtained from an adequate number of qualified sources when the aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold of $10,000, but less than the simplified acquisition threshold of $250,000.
Condition: The College did not obtain price or rate quotations obtained from different qualified transactions for all small purchase transactions sampled under the Research and Development Cluster Grants.
Cause: The College did not have a procurement policy in place during the year ended June 30, 2024 that required price or rate quotations for small purchases.
Effect or Potential Effect: Noncompliance with procurement requirements could result in unethical purchasing practices or overspending.
Questioned Costs: Undeterminable
Context: We tested 3 small purchase vendor transactions from the Research and Development Cluster totaling approximately $152,000 where no price or rate quotations were obtained prior to payment. The total population of small vendor purchases within this federal program was $422,246.
Repeat Finding: No
Recommendation: We recommend the College review its procurement policy to ensure it is in compliance with 2 CFR 200 Uniform Guidance and implement controls to ensure an audit trail is maintained surrounding the procurement of vendors using federal funds.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-002: Procurement over Small Purchase Transactions (Research and Development Grants)
Material Weakness / Material Noncompliance
Federal Program(s): Research and Development Cluster
Assistance Listing Number(s):
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Criteria: Procurement methods established under 2 CFR 200.320, requires price or rate quotations to be obtained from an adequate number of qualified sources when the aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold of $10,000, but less than the simplified acquisition threshold of $250,000.
Condition: The College did not obtain price or rate quotations obtained from different qualified transactions for all small purchase transactions sampled under the Research and Development Cluster Grants.
Cause: The College did not have a procurement policy in place during the year ended June 30, 2024 that required price or rate quotations for small purchases.
Effect or Potential Effect: Noncompliance with procurement requirements could result in unethical purchasing practices or overspending.
Questioned Costs: Undeterminable
Context: We tested 3 small purchase vendor transactions from the Research and Development Cluster totaling approximately $152,000 where no price or rate quotations were obtained prior to payment. The total population of small vendor purchases within this federal program was $422,246.
Repeat Finding: No
Recommendation: We recommend the College review its procurement policy to ensure it is in compliance with 2 CFR 200 Uniform Guidance and implement controls to ensure an audit trail is maintained surrounding the procurement of vendors using federal funds.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-002: Procurement over Small Purchase Transactions (Research and Development Grants)
Material Weakness / Material Noncompliance
Federal Program(s): Research and Development Cluster
Assistance Listing Number(s):
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Criteria: Procurement methods established under 2 CFR 200.320, requires price or rate quotations to be obtained from an adequate number of qualified sources when the aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold of $10,000, but less than the simplified acquisition threshold of $250,000.
Condition: The College did not obtain price or rate quotations obtained from different qualified transactions for all small purchase transactions sampled under the Research and Development Cluster Grants.
Cause: The College did not have a procurement policy in place during the year ended June 30, 2024 that required price or rate quotations for small purchases.
Effect or Potential Effect: Noncompliance with procurement requirements could result in unethical purchasing practices or overspending.
Questioned Costs: Undeterminable
Context: We tested 3 small purchase vendor transactions from the Research and Development Cluster totaling approximately $152,000 where no price or rate quotations were obtained prior to payment. The total population of small vendor purchases within this federal program was $422,246.
Repeat Finding: No
Recommendation: We recommend the College review its procurement policy to ensure it is in compliance with 2 CFR 200 Uniform Guidance and implement controls to ensure an audit trail is maintained surrounding the procurement of vendors using federal funds.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-002: Procurement over Small Purchase Transactions (Research and Development Grants)
Material Weakness / Material Noncompliance
Federal Program(s): Research and Development Cluster
Assistance Listing Number(s):
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Criteria: Procurement methods established under 2 CFR 200.320, requires price or rate quotations to be obtained from an adequate number of qualified sources when the aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold of $10,000, but less than the simplified acquisition threshold of $250,000.
Condition: The College did not obtain price or rate quotations obtained from different qualified transactions for all small purchase transactions sampled under the Research and Development Cluster Grants.
Cause: The College did not have a procurement policy in place during the year ended June 30, 2024 that required price or rate quotations for small purchases.
Effect or Potential Effect: Noncompliance with procurement requirements could result in unethical purchasing practices or overspending.
Questioned Costs: Undeterminable
Context: We tested 3 small purchase vendor transactions from the Research and Development Cluster totaling approximately $152,000 where no price or rate quotations were obtained prior to payment. The total population of small vendor purchases within this federal program was $422,246.
Repeat Finding: No
Recommendation: We recommend the College review its procurement policy to ensure it is in compliance with 2 CFR 200 Uniform Guidance and implement controls to ensure an audit trail is maintained surrounding the procurement of vendors using federal funds.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-002: Procurement over Small Purchase Transactions (Research and Development Grants)
Material Weakness / Material Noncompliance
Federal Program(s): Research and Development Cluster
Assistance Listing Number(s):
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Criteria: Procurement methods established under 2 CFR 200.320, requires price or rate quotations to be obtained from an adequate number of qualified sources when the aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold of $10,000, but less than the simplified acquisition threshold of $250,000.
Condition: The College did not obtain price or rate quotations obtained from different qualified transactions for all small purchase transactions sampled under the Research and Development Cluster Grants.
Cause: The College did not have a procurement policy in place during the year ended June 30, 2024 that required price or rate quotations for small purchases.
Effect or Potential Effect: Noncompliance with procurement requirements could result in unethical purchasing practices or overspending.
Questioned Costs: Undeterminable
Context: We tested 3 small purchase vendor transactions from the Research and Development Cluster totaling approximately $152,000 where no price or rate quotations were obtained prior to payment. The total population of small vendor purchases within this federal program was $422,246.
Repeat Finding: No
Recommendation: We recommend the College review its procurement policy to ensure it is in compliance with 2 CFR 200 Uniform Guidance and implement controls to ensure an audit trail is maintained surrounding the procurement of vendors using federal funds.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-002: Procurement over Small Purchase Transactions (Research and Development Grants)
Material Weakness / Material Noncompliance
Federal Program(s): Research and Development Cluster
Assistance Listing Number(s):
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Criteria: Procurement methods established under 2 CFR 200.320, requires price or rate quotations to be obtained from an adequate number of qualified sources when the aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold of $10,000, but less than the simplified acquisition threshold of $250,000.
Condition: The College did not obtain price or rate quotations obtained from different qualified transactions for all small purchase transactions sampled under the Research and Development Cluster Grants.
Cause: The College did not have a procurement policy in place during the year ended June 30, 2024 that required price or rate quotations for small purchases.
Effect or Potential Effect: Noncompliance with procurement requirements could result in unethical purchasing practices or overspending.
Questioned Costs: Undeterminable
Context: We tested 3 small purchase vendor transactions from the Research and Development Cluster totaling approximately $152,000 where no price or rate quotations were obtained prior to payment. The total population of small vendor purchases within this federal program was $422,246.
Repeat Finding: No
Recommendation: We recommend the College review its procurement policy to ensure it is in compliance with 2 CFR 200 Uniform Guidance and implement controls to ensure an audit trail is maintained surrounding the procurement of vendors using federal funds.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-002: Procurement over Small Purchase Transactions (Research and Development Grants)
Material Weakness / Material Noncompliance
Federal Program(s): Research and Development Cluster
Assistance Listing Number(s):
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Criteria: Procurement methods established under 2 CFR 200.320, requires price or rate quotations to be obtained from an adequate number of qualified sources when the aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold of $10,000, but less than the simplified acquisition threshold of $250,000.
Condition: The College did not obtain price or rate quotations obtained from different qualified transactions for all small purchase transactions sampled under the Research and Development Cluster Grants.
Cause: The College did not have a procurement policy in place during the year ended June 30, 2024 that required price or rate quotations for small purchases.
Effect or Potential Effect: Noncompliance with procurement requirements could result in unethical purchasing practices or overspending.
Questioned Costs: Undeterminable
Context: We tested 3 small purchase vendor transactions from the Research and Development Cluster totaling approximately $152,000 where no price or rate quotations were obtained prior to payment. The total population of small vendor purchases within this federal program was $422,246.
Repeat Finding: No
Recommendation: We recommend the College review its procurement policy to ensure it is in compliance with 2 CFR 200 Uniform Guidance and implement controls to ensure an audit trail is maintained surrounding the procurement of vendors using federal funds.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-002: Procurement over Small Purchase Transactions (Research and Development Grants)
Material Weakness / Material Noncompliance
Federal Program(s): Research and Development Cluster
Assistance Listing Number(s):
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Criteria: Procurement methods established under 2 CFR 200.320, requires price or rate quotations to be obtained from an adequate number of qualified sources when the aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold of $10,000, but less than the simplified acquisition threshold of $250,000.
Condition: The College did not obtain price or rate quotations obtained from different qualified transactions for all small purchase transactions sampled under the Research and Development Cluster Grants.
Cause: The College did not have a procurement policy in place during the year ended June 30, 2024 that required price or rate quotations for small purchases.
Effect or Potential Effect: Noncompliance with procurement requirements could result in unethical purchasing practices or overspending.
Questioned Costs: Undeterminable
Context: We tested 3 small purchase vendor transactions from the Research and Development Cluster totaling approximately $152,000 where no price or rate quotations were obtained prior to payment. The total population of small vendor purchases within this federal program was $422,246.
Repeat Finding: No
Recommendation: We recommend the College review its procurement policy to ensure it is in compliance with 2 CFR 200 Uniform Guidance and implement controls to ensure an audit trail is maintained surrounding the procurement of vendors using federal funds.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-003: Procurement over Small Purchase Transactions (Mental and Behavioral Health Education and Training Grants)
Material Weakness / Other Matter Noncompliance
Federal Program(s): Mental and Behavioral Health Education and Training Grants
Assistance Listing Number(s):
• 93.732
Criteria: Procurement methods established under 2 CFR 200.320, requires price or rate quotations to be obtained from an adequate number of qualified sources when the aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold of $10,000, but less than the simplified acquisition threshold of $250,000.
Condition: The College did not obtain price or rate quotations obtained from different qualified transactions for all small purchase transactions sampled under the Mental and Behavioral Health Education and Training Grants.
Cause: The College did not have a procurement policy in place during the year ended June 30, 2024 that required price or rate quotations for small purchases.
Effect or Potential Effect: Noncompliance with procurement requirements could result in unethical purchasing practices or overspending.
Questioned Costs: Undeterminable
Context: We tested 1 small purchase vendor transaction from the Mental and Behavioral Health Education and Training grants in the amount of $13,000 were no price or rate quotations were obtained prior to payment. The total population of small vendor purchases within this federal program was $13,000.
Repeat Finding: No
Recommendation: We recommend the College review its procurement policy to ensure it is in compliance with 2 CFR 200 Uniform Guidance and implement controls to ensure an audit trail is maintained surrounding the procurement of vendors using federal funds.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Material Weakness
Federal Program(s): Research and Development Cluster
Mental and Behavioral Health Education and Training Grants
Assistance Listing Number(s):
Research and Development Cluster
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Mental and Behavioral Health Education and Training Grants
• 93.732
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: Timesheets and time and effort reports used to track time spent on federal programs did not have approval signatures by the employee’s supervisor.
Cause: Ineffective design and implementation of internal controls around approval of timesheets and time and effort reports.
Effect or Potential Effect: Ineffective control procedures could result in unallowable costs or activities being charged to federal grant programs.
Questioned Costs: None
Context: In our sample of 10 payroll transactions of amounts charged to the Research and Development Cluster, 9 of the timesheets or time and effort reports did not have physical indication of review by their supervisors. In our sample of 6 payroll transactions of amounts charged to the Mental and Behavioral Health Education and Training grants, none of the timesheets or time and effort reports had physical indication of review by their supervisors.
Repeat Finding: No
Recommendation: We recommend the College enforce its policy to have physical signatures on each employee’s timesheet or time and effort report after the review takes place to ensure salary costs charged to the federal program are allowable.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Material Weakness
Federal Program(s): Research and Development Cluster
Mental and Behavioral Health Education and Training Grants
Assistance Listing Number(s):
Research and Development Cluster
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Mental and Behavioral Health Education and Training Grants
• 93.732
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: Timesheets and time and effort reports used to track time spent on federal programs did not have approval signatures by the employee’s supervisor.
Cause: Ineffective design and implementation of internal controls around approval of timesheets and time and effort reports.
Effect or Potential Effect: Ineffective control procedures could result in unallowable costs or activities being charged to federal grant programs.
Questioned Costs: None
Context: In our sample of 10 payroll transactions of amounts charged to the Research and Development Cluster, 9 of the timesheets or time and effort reports did not have physical indication of review by their supervisors. In our sample of 6 payroll transactions of amounts charged to the Mental and Behavioral Health Education and Training grants, none of the timesheets or time and effort reports had physical indication of review by their supervisors.
Repeat Finding: No
Recommendation: We recommend the College enforce its policy to have physical signatures on each employee’s timesheet or time and effort report after the review takes place to ensure salary costs charged to the federal program are allowable.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Material Weakness
Federal Program(s): Research and Development Cluster
Mental and Behavioral Health Education and Training Grants
Assistance Listing Number(s):
Research and Development Cluster
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Mental and Behavioral Health Education and Training Grants
• 93.732
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: Timesheets and time and effort reports used to track time spent on federal programs did not have approval signatures by the employee’s supervisor.
Cause: Ineffective design and implementation of internal controls around approval of timesheets and time and effort reports.
Effect or Potential Effect: Ineffective control procedures could result in unallowable costs or activities being charged to federal grant programs.
Questioned Costs: None
Context: In our sample of 10 payroll transactions of amounts charged to the Research and Development Cluster, 9 of the timesheets or time and effort reports did not have physical indication of review by their supervisors. In our sample of 6 payroll transactions of amounts charged to the Mental and Behavioral Health Education and Training grants, none of the timesheets or time and effort reports had physical indication of review by their supervisors.
Repeat Finding: No
Recommendation: We recommend the College enforce its policy to have physical signatures on each employee’s timesheet or time and effort report after the review takes place to ensure salary costs charged to the federal program are allowable.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Material Weakness
Federal Program(s): Research and Development Cluster
Mental and Behavioral Health Education and Training Grants
Assistance Listing Number(s):
Research and Development Cluster
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Mental and Behavioral Health Education and Training Grants
• 93.732
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: Timesheets and time and effort reports used to track time spent on federal programs did not have approval signatures by the employee’s supervisor.
Cause: Ineffective design and implementation of internal controls around approval of timesheets and time and effort reports.
Effect or Potential Effect: Ineffective control procedures could result in unallowable costs or activities being charged to federal grant programs.
Questioned Costs: None
Context: In our sample of 10 payroll transactions of amounts charged to the Research and Development Cluster, 9 of the timesheets or time and effort reports did not have physical indication of review by their supervisors. In our sample of 6 payroll transactions of amounts charged to the Mental and Behavioral Health Education and Training grants, none of the timesheets or time and effort reports had physical indication of review by their supervisors.
Repeat Finding: No
Recommendation: We recommend the College enforce its policy to have physical signatures on each employee’s timesheet or time and effort report after the review takes place to ensure salary costs charged to the federal program are allowable.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Material Weakness
Federal Program(s): Research and Development Cluster
Mental and Behavioral Health Education and Training Grants
Assistance Listing Number(s):
Research and Development Cluster
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Mental and Behavioral Health Education and Training Grants
• 93.732
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: Timesheets and time and effort reports used to track time spent on federal programs did not have approval signatures by the employee’s supervisor.
Cause: Ineffective design and implementation of internal controls around approval of timesheets and time and effort reports.
Effect or Potential Effect: Ineffective control procedures could result in unallowable costs or activities being charged to federal grant programs.
Questioned Costs: None
Context: In our sample of 10 payroll transactions of amounts charged to the Research and Development Cluster, 9 of the timesheets or time and effort reports did not have physical indication of review by their supervisors. In our sample of 6 payroll transactions of amounts charged to the Mental and Behavioral Health Education and Training grants, none of the timesheets or time and effort reports had physical indication of review by their supervisors.
Repeat Finding: No
Recommendation: We recommend the College enforce its policy to have physical signatures on each employee’s timesheet or time and effort report after the review takes place to ensure salary costs charged to the federal program are allowable.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Material Weakness
Federal Program(s): Research and Development Cluster
Mental and Behavioral Health Education and Training Grants
Assistance Listing Number(s):
Research and Development Cluster
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Mental and Behavioral Health Education and Training Grants
• 93.732
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: Timesheets and time and effort reports used to track time spent on federal programs did not have approval signatures by the employee’s supervisor.
Cause: Ineffective design and implementation of internal controls around approval of timesheets and time and effort reports.
Effect or Potential Effect: Ineffective control procedures could result in unallowable costs or activities being charged to federal grant programs.
Questioned Costs: None
Context: In our sample of 10 payroll transactions of amounts charged to the Research and Development Cluster, 9 of the timesheets or time and effort reports did not have physical indication of review by their supervisors. In our sample of 6 payroll transactions of amounts charged to the Mental and Behavioral Health Education and Training grants, none of the timesheets or time and effort reports had physical indication of review by their supervisors.
Repeat Finding: No
Recommendation: We recommend the College enforce its policy to have physical signatures on each employee’s timesheet or time and effort report after the review takes place to ensure salary costs charged to the federal program are allowable.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Material Weakness
Federal Program(s): Research and Development Cluster
Mental and Behavioral Health Education and Training Grants
Assistance Listing Number(s):
Research and Development Cluster
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Mental and Behavioral Health Education and Training Grants
• 93.732
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: Timesheets and time and effort reports used to track time spent on federal programs did not have approval signatures by the employee’s supervisor.
Cause: Ineffective design and implementation of internal controls around approval of timesheets and time and effort reports.
Effect or Potential Effect: Ineffective control procedures could result in unallowable costs or activities being charged to federal grant programs.
Questioned Costs: None
Context: In our sample of 10 payroll transactions of amounts charged to the Research and Development Cluster, 9 of the timesheets or time and effort reports did not have physical indication of review by their supervisors. In our sample of 6 payroll transactions of amounts charged to the Mental and Behavioral Health Education and Training grants, none of the timesheets or time and effort reports had physical indication of review by their supervisors.
Repeat Finding: No
Recommendation: We recommend the College enforce its policy to have physical signatures on each employee’s timesheet or time and effort report after the review takes place to ensure salary costs charged to the federal program are allowable.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Material Weakness
Federal Program(s): Research and Development Cluster
Mental and Behavioral Health Education and Training Grants
Assistance Listing Number(s):
Research and Development Cluster
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Mental and Behavioral Health Education and Training Grants
• 93.732
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: Timesheets and time and effort reports used to track time spent on federal programs did not have approval signatures by the employee’s supervisor.
Cause: Ineffective design and implementation of internal controls around approval of timesheets and time and effort reports.
Effect or Potential Effect: Ineffective control procedures could result in unallowable costs or activities being charged to federal grant programs.
Questioned Costs: None
Context: In our sample of 10 payroll transactions of amounts charged to the Research and Development Cluster, 9 of the timesheets or time and effort reports did not have physical indication of review by their supervisors. In our sample of 6 payroll transactions of amounts charged to the Mental and Behavioral Health Education and Training grants, none of the timesheets or time and effort reports had physical indication of review by their supervisors.
Repeat Finding: No
Recommendation: We recommend the College enforce its policy to have physical signatures on each employee’s timesheet or time and effort report after the review takes place to ensure salary costs charged to the federal program are allowable.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Material Weakness
Federal Program(s): Research and Development Cluster
Mental and Behavioral Health Education and Training Grants
Assistance Listing Number(s):
Research and Development Cluster
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Mental and Behavioral Health Education and Training Grants
• 93.732
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: Timesheets and time and effort reports used to track time spent on federal programs did not have approval signatures by the employee’s supervisor.
Cause: Ineffective design and implementation of internal controls around approval of timesheets and time and effort reports.
Effect or Potential Effect: Ineffective control procedures could result in unallowable costs or activities being charged to federal grant programs.
Questioned Costs: None
Context: In our sample of 10 payroll transactions of amounts charged to the Research and Development Cluster, 9 of the timesheets or time and effort reports did not have physical indication of review by their supervisors. In our sample of 6 payroll transactions of amounts charged to the Mental and Behavioral Health Education and Training grants, none of the timesheets or time and effort reports had physical indication of review by their supervisors.
Repeat Finding: No
Recommendation: We recommend the College enforce its policy to have physical signatures on each employee’s timesheet or time and effort report after the review takes place to ensure salary costs charged to the federal program are allowable.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Material Weakness
Federal Program(s): Research and Development Cluster
Mental and Behavioral Health Education and Training Grants
Assistance Listing Number(s):
Research and Development Cluster
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Mental and Behavioral Health Education and Training Grants
• 93.732
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: Timesheets and time and effort reports used to track time spent on federal programs did not have approval signatures by the employee’s supervisor.
Cause: Ineffective design and implementation of internal controls around approval of timesheets and time and effort reports.
Effect or Potential Effect: Ineffective control procedures could result in unallowable costs or activities being charged to federal grant programs.
Questioned Costs: None
Context: In our sample of 10 payroll transactions of amounts charged to the Research and Development Cluster, 9 of the timesheets or time and effort reports did not have physical indication of review by their supervisors. In our sample of 6 payroll transactions of amounts charged to the Mental and Behavioral Health Education and Training grants, none of the timesheets or time and effort reports had physical indication of review by their supervisors.
Repeat Finding: No
Recommendation: We recommend the College enforce its policy to have physical signatures on each employee’s timesheet or time and effort report after the review takes place to ensure salary costs charged to the federal program are allowable.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Material Weakness
Federal Program(s): Research and Development Cluster
Mental and Behavioral Health Education and Training Grants
Assistance Listing Number(s):
Research and Development Cluster
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Mental and Behavioral Health Education and Training Grants
• 93.732
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: Timesheets and time and effort reports used to track time spent on federal programs did not have approval signatures by the employee’s supervisor.
Cause: Ineffective design and implementation of internal controls around approval of timesheets and time and effort reports.
Effect or Potential Effect: Ineffective control procedures could result in unallowable costs or activities being charged to federal grant programs.
Questioned Costs: None
Context: In our sample of 10 payroll transactions of amounts charged to the Research and Development Cluster, 9 of the timesheets or time and effort reports did not have physical indication of review by their supervisors. In our sample of 6 payroll transactions of amounts charged to the Mental and Behavioral Health Education and Training grants, none of the timesheets or time and effort reports had physical indication of review by their supervisors.
Repeat Finding: No
Recommendation: We recommend the College enforce its policy to have physical signatures on each employee’s timesheet or time and effort report after the review takes place to ensure salary costs charged to the federal program are allowable.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-005: Enrollment Reporting – Student Financial Aid Special Test
Material Weakness / Other Matter Noncompliance
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.063
• 84.268
Criteria: To comply with enrollment reporting requirements, institutions must accurately and timely report student enrollment status changes to the National Student Loan Data System (NSLDS) within 60 days of determining the change, as outlined in Federal Regulations 34 CFR 682.610 and 685.309.
Condition: There is no control in place by the College to review information submitted to the NSLDS for student enrollment status changes. There were instances of noncompliance where students with enrollment status changes were received by the NSLDS outside of the 60-day requirement.
Cause: Lack of control in place over enrollment status changes reported to the NSLDS.
Effect or Potential Effect: Lack of controls in place could result in instances of noncompliance with Department of Education and Federal regulations.
Questioned Costs: None
Context: In our sample of 40 students with enrollment status changes during the year ended June 30, 2024, 4 were reported to the NSLDS outside of the 60-day requirement. While the College ensures accurate status change data is sent to the National Student Clearinghouse (third party who submits enrollment status changes to the NSLDS), the College does not have controls in place to ensure information was submitted to the NSLDS accurately and timely.
Repeat Finding: No
Recommendation: We recommend the College implement controls where there is an independent review of the submissions received by NSLDS to ensure enrollment status changes are reported accurately and timely.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-005: Enrollment Reporting – Student Financial Aid Special Test
Material Weakness / Other Matter Noncompliance
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.063
• 84.268
Criteria: To comply with enrollment reporting requirements, institutions must accurately and timely report student enrollment status changes to the National Student Loan Data System (NSLDS) within 60 days of determining the change, as outlined in Federal Regulations 34 CFR 682.610 and 685.309.
Condition: There is no control in place by the College to review information submitted to the NSLDS for student enrollment status changes. There were instances of noncompliance where students with enrollment status changes were received by the NSLDS outside of the 60-day requirement.
Cause: Lack of control in place over enrollment status changes reported to the NSLDS.
Effect or Potential Effect: Lack of controls in place could result in instances of noncompliance with Department of Education and Federal regulations.
Questioned Costs: None
Context: In our sample of 40 students with enrollment status changes during the year ended June 30, 2024, 4 were reported to the NSLDS outside of the 60-day requirement. While the College ensures accurate status change data is sent to the National Student Clearinghouse (third party who submits enrollment status changes to the NSLDS), the College does not have controls in place to ensure information was submitted to the NSLDS accurately and timely.
Repeat Finding: No
Recommendation: We recommend the College implement controls where there is an independent review of the submissions received by NSLDS to ensure enrollment status changes are reported accurately and timely.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-006: Perkins Loan Recordkeeping and Record Retention
Significant Deficiency/Other Matter Noncompliance
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.038
Criteria: Institutions must properly maintain its Perkins loan records in the manner set forth in 34 CFR 674.19.(e). Institutions are required to keep original paper promissory notes or original paper master promissory notes (MPNs) and repayment schedules in a locked, fireproof container. The original promissory notes and repayment schedules must be kept until the loans are satisfied. An institution shall retain repayment records, including cancellation and deferment requests for at least three years from the date on which a loan is assigned to the secretary, canceled, or repaid. An institution shall retain disbursement and electronic authentication and signature records for each loan made using an MPN for at least three years from the date the loan is canceled, repaid, or otherwise satisfied.
Condition: The College could not locate promissory notes or MPNs for some of its Perkins loans when requested by the auditors.
Cause: Improper recordkeeping and retention processes and controls.
Effect or Potential Effect: Noncompliance with the Department of Education and record retention requirements set forth in 34 CFR 674.19.(e).
Questioned Costs: None
Context: In our sample of 40 students with open Perkins loans as of June 30, 2024, the College could not locate the original promissory note for 1 student. In our sample of 40 students with retired or assigned loans in the current year and prior three years, the College could not locate the promissory note and repayment records for 3 students.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for recordkeeping and retention over both open loans and retired or assigned loans for the past 3 years, to ensure required documents are adequately maintained and stored.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-007: Student Credit Balances from Title IV Awards
Significant Deficiency
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.007
• 84.033
• 84.038
• 84.063
• 84.268
• 84.379
• 93.925
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, food and housing, and other authorized charges assessed the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. The College does not have a control in place with physical indication of review over refund process for student credit balances.
Cause: Lack of control in place over refunds from student credit balances
Effect or Potential Effect: Student credit balances may not be refunded within the 14-day requirement.
Questioned Costs: None
Context: During our control assessment over student credit balance refunds, we noted there is no control in place and no physical indication of review taking place to ensure student credit balances are properly refunded within the 14-day requirement.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for student credit balances to include an independent review and sufficient documentation to support the application of the control.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-007: Student Credit Balances from Title IV Awards
Significant Deficiency
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.007
• 84.033
• 84.038
• 84.063
• 84.268
• 84.379
• 93.925
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, food and housing, and other authorized charges assessed the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. The College does not have a control in place with physical indication of review over refund process for student credit balances.
Cause: Lack of control in place over refunds from student credit balances
Effect or Potential Effect: Student credit balances may not be refunded within the 14-day requirement.
Questioned Costs: None
Context: During our control assessment over student credit balance refunds, we noted there is no control in place and no physical indication of review taking place to ensure student credit balances are properly refunded within the 14-day requirement.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for student credit balances to include an independent review and sufficient documentation to support the application of the control.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-007: Student Credit Balances from Title IV Awards
Significant Deficiency
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.007
• 84.033
• 84.038
• 84.063
• 84.268
• 84.379
• 93.925
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, food and housing, and other authorized charges assessed the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. The College does not have a control in place with physical indication of review over refund process for student credit balances.
Cause: Lack of control in place over refunds from student credit balances
Effect or Potential Effect: Student credit balances may not be refunded within the 14-day requirement.
Questioned Costs: None
Context: During our control assessment over student credit balance refunds, we noted there is no control in place and no physical indication of review taking place to ensure student credit balances are properly refunded within the 14-day requirement.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for student credit balances to include an independent review and sufficient documentation to support the application of the control.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-007: Student Credit Balances from Title IV Awards
Significant Deficiency
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.007
• 84.033
• 84.038
• 84.063
• 84.268
• 84.379
• 93.925
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, food and housing, and other authorized charges assessed the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. The College does not have a control in place with physical indication of review over refund process for student credit balances.
Cause: Lack of control in place over refunds from student credit balances
Effect or Potential Effect: Student credit balances may not be refunded within the 14-day requirement.
Questioned Costs: None
Context: During our control assessment over student credit balance refunds, we noted there is no control in place and no physical indication of review taking place to ensure student credit balances are properly refunded within the 14-day requirement.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for student credit balances to include an independent review and sufficient documentation to support the application of the control.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-007: Student Credit Balances from Title IV Awards
Significant Deficiency
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.007
• 84.033
• 84.038
• 84.063
• 84.268
• 84.379
• 93.925
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, food and housing, and other authorized charges assessed the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. The College does not have a control in place with physical indication of review over refund process for student credit balances.
Cause: Lack of control in place over refunds from student credit balances
Effect or Potential Effect: Student credit balances may not be refunded within the 14-day requirement.
Questioned Costs: None
Context: During our control assessment over student credit balance refunds, we noted there is no control in place and no physical indication of review taking place to ensure student credit balances are properly refunded within the 14-day requirement.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for student credit balances to include an independent review and sufficient documentation to support the application of the control.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-007: Student Credit Balances from Title IV Awards
Significant Deficiency
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.007
• 84.033
• 84.038
• 84.063
• 84.268
• 84.379
• 93.925
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, food and housing, and other authorized charges assessed the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. The College does not have a control in place with physical indication of review over refund process for student credit balances.
Cause: Lack of control in place over refunds from student credit balances
Effect or Potential Effect: Student credit balances may not be refunded within the 14-day requirement.
Questioned Costs: None
Context: During our control assessment over student credit balance refunds, we noted there is no control in place and no physical indication of review taking place to ensure student credit balances are properly refunded within the 14-day requirement.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for student credit balances to include an independent review and sufficient documentation to support the application of the control.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-007: Student Credit Balances from Title IV Awards
Significant Deficiency
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.007
• 84.033
• 84.038
• 84.063
• 84.268
• 84.379
• 93.925
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, food and housing, and other authorized charges assessed the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. The College does not have a control in place with physical indication of review over refund process for student credit balances.
Cause: Lack of control in place over refunds from student credit balances
Effect or Potential Effect: Student credit balances may not be refunded within the 14-day requirement.
Questioned Costs: None
Context: During our control assessment over student credit balance refunds, we noted there is no control in place and no physical indication of review taking place to ensure student credit balances are properly refunded within the 14-day requirement.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for student credit balances to include an independent review and sufficient documentation to support the application of the control.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-008: Return of Title IV Funds
Significant Deficiency / Other Matter Noncompliance
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.007
• 84.033
• 84.038
• 84.063
• 84.268
• 84.379
• 93.925
Criteria: When a student withdraws, institutions must comply with the "Return of Title IV Funds" requirements outlined in 34 CFR 668.22, ensuring any unearned funds are returned to the Department of Education within 45 days of determining the student's withdrawal.
Condition: We identified instances of unearned funds not returned to the Department of Education within the 45-day requirement.
Cause: Lack of control in place over returns of Title IV funding
Effect or Potential Effect: Returns of Title IV Funds may not be refunded within the 45-day requirement and result in instances of noncompliance with the Department of Education.
Questioned Costs: $9,259
Context: During our sample of 12 students who withdrew during the fiscal year ended June 30, 2024, we identified 3 students whose date withdrawn from the College resulted in unearned funds required to be returned to the Department of Education. The return of funds calculation was not completed for these students, resulting in unearned funds not returned within the 45-day requirement.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for calculating refunds from Title IV and include an independent review and sufficient documentation to support the application of the control.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-008: Return of Title IV Funds
Significant Deficiency / Other Matter Noncompliance
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.007
• 84.033
• 84.038
• 84.063
• 84.268
• 84.379
• 93.925
Criteria: When a student withdraws, institutions must comply with the "Return of Title IV Funds" requirements outlined in 34 CFR 668.22, ensuring any unearned funds are returned to the Department of Education within 45 days of determining the student's withdrawal.
Condition: We identified instances of unearned funds not returned to the Department of Education within the 45-day requirement.
Cause: Lack of control in place over returns of Title IV funding
Effect or Potential Effect: Returns of Title IV Funds may not be refunded within the 45-day requirement and result in instances of noncompliance with the Department of Education.
Questioned Costs: $9,259
Context: During our sample of 12 students who withdrew during the fiscal year ended June 30, 2024, we identified 3 students whose date withdrawn from the College resulted in unearned funds required to be returned to the Department of Education. The return of funds calculation was not completed for these students, resulting in unearned funds not returned within the 45-day requirement.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for calculating refunds from Title IV and include an independent review and sufficient documentation to support the application of the control.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-008: Return of Title IV Funds
Significant Deficiency / Other Matter Noncompliance
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.007
• 84.033
• 84.038
• 84.063
• 84.268
• 84.379
• 93.925
Criteria: When a student withdraws, institutions must comply with the "Return of Title IV Funds" requirements outlined in 34 CFR 668.22, ensuring any unearned funds are returned to the Department of Education within 45 days of determining the student's withdrawal.
Condition: We identified instances of unearned funds not returned to the Department of Education within the 45-day requirement.
Cause: Lack of control in place over returns of Title IV funding
Effect or Potential Effect: Returns of Title IV Funds may not be refunded within the 45-day requirement and result in instances of noncompliance with the Department of Education.
Questioned Costs: $9,259
Context: During our sample of 12 students who withdrew during the fiscal year ended June 30, 2024, we identified 3 students whose date withdrawn from the College resulted in unearned funds required to be returned to the Department of Education. The return of funds calculation was not completed for these students, resulting in unearned funds not returned within the 45-day requirement.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for calculating refunds from Title IV and include an independent review and sufficient documentation to support the application of the control.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-008: Return of Title IV Funds
Significant Deficiency / Other Matter Noncompliance
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.007
• 84.033
• 84.038
• 84.063
• 84.268
• 84.379
• 93.925
Criteria: When a student withdraws, institutions must comply with the "Return of Title IV Funds" requirements outlined in 34 CFR 668.22, ensuring any unearned funds are returned to the Department of Education within 45 days of determining the student's withdrawal.
Condition: We identified instances of unearned funds not returned to the Department of Education within the 45-day requirement.
Cause: Lack of control in place over returns of Title IV funding
Effect or Potential Effect: Returns of Title IV Funds may not be refunded within the 45-day requirement and result in instances of noncompliance with the Department of Education.
Questioned Costs: $9,259
Context: During our sample of 12 students who withdrew during the fiscal year ended June 30, 2024, we identified 3 students whose date withdrawn from the College resulted in unearned funds required to be returned to the Department of Education. The return of funds calculation was not completed for these students, resulting in unearned funds not returned within the 45-day requirement.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for calculating refunds from Title IV and include an independent review and sufficient documentation to support the application of the control.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-008: Return of Title IV Funds
Significant Deficiency / Other Matter Noncompliance
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.007
• 84.033
• 84.038
• 84.063
• 84.268
• 84.379
• 93.925
Criteria: When a student withdraws, institutions must comply with the "Return of Title IV Funds" requirements outlined in 34 CFR 668.22, ensuring any unearned funds are returned to the Department of Education within 45 days of determining the student's withdrawal.
Condition: We identified instances of unearned funds not returned to the Department of Education within the 45-day requirement.
Cause: Lack of control in place over returns of Title IV funding
Effect or Potential Effect: Returns of Title IV Funds may not be refunded within the 45-day requirement and result in instances of noncompliance with the Department of Education.
Questioned Costs: $9,259
Context: During our sample of 12 students who withdrew during the fiscal year ended June 30, 2024, we identified 3 students whose date withdrawn from the College resulted in unearned funds required to be returned to the Department of Education. The return of funds calculation was not completed for these students, resulting in unearned funds not returned within the 45-day requirement.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for calculating refunds from Title IV and include an independent review and sufficient documentation to support the application of the control.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-008: Return of Title IV Funds
Significant Deficiency / Other Matter Noncompliance
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.007
• 84.033
• 84.038
• 84.063
• 84.268
• 84.379
• 93.925
Criteria: When a student withdraws, institutions must comply with the "Return of Title IV Funds" requirements outlined in 34 CFR 668.22, ensuring any unearned funds are returned to the Department of Education within 45 days of determining the student's withdrawal.
Condition: We identified instances of unearned funds not returned to the Department of Education within the 45-day requirement.
Cause: Lack of control in place over returns of Title IV funding
Effect or Potential Effect: Returns of Title IV Funds may not be refunded within the 45-day requirement and result in instances of noncompliance with the Department of Education.
Questioned Costs: $9,259
Context: During our sample of 12 students who withdrew during the fiscal year ended June 30, 2024, we identified 3 students whose date withdrawn from the College resulted in unearned funds required to be returned to the Department of Education. The return of funds calculation was not completed for these students, resulting in unearned funds not returned within the 45-day requirement.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for calculating refunds from Title IV and include an independent review and sufficient documentation to support the application of the control.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-008: Return of Title IV Funds
Significant Deficiency / Other Matter Noncompliance
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.007
• 84.033
• 84.038
• 84.063
• 84.268
• 84.379
• 93.925
Criteria: When a student withdraws, institutions must comply with the "Return of Title IV Funds" requirements outlined in 34 CFR 668.22, ensuring any unearned funds are returned to the Department of Education within 45 days of determining the student's withdrawal.
Condition: We identified instances of unearned funds not returned to the Department of Education within the 45-day requirement.
Cause: Lack of control in place over returns of Title IV funding
Effect or Potential Effect: Returns of Title IV Funds may not be refunded within the 45-day requirement and result in instances of noncompliance with the Department of Education.
Questioned Costs: $9,259
Context: During our sample of 12 students who withdrew during the fiscal year ended June 30, 2024, we identified 3 students whose date withdrawn from the College resulted in unearned funds required to be returned to the Department of Education. The return of funds calculation was not completed for these students, resulting in unearned funds not returned within the 45-day requirement.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for calculating refunds from Title IV and include an independent review and sufficient documentation to support the application of the control.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-002: Procurement over Small Purchase Transactions (Research and Development Grants)
Material Weakness / Material Noncompliance
Federal Program(s): Research and Development Cluster
Assistance Listing Number(s):
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Criteria: Procurement methods established under 2 CFR 200.320, requires price or rate quotations to be obtained from an adequate number of qualified sources when the aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold of $10,000, but less than the simplified acquisition threshold of $250,000.
Condition: The College did not obtain price or rate quotations obtained from different qualified transactions for all small purchase transactions sampled under the Research and Development Cluster Grants.
Cause: The College did not have a procurement policy in place during the year ended June 30, 2024 that required price or rate quotations for small purchases.
Effect or Potential Effect: Noncompliance with procurement requirements could result in unethical purchasing practices or overspending.
Questioned Costs: Undeterminable
Context: We tested 3 small purchase vendor transactions from the Research and Development Cluster totaling approximately $152,000 where no price or rate quotations were obtained prior to payment. The total population of small vendor purchases within this federal program was $422,246.
Repeat Finding: No
Recommendation: We recommend the College review its procurement policy to ensure it is in compliance with 2 CFR 200 Uniform Guidance and implement controls to ensure an audit trail is maintained surrounding the procurement of vendors using federal funds.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-002: Procurement over Small Purchase Transactions (Research and Development Grants)
Material Weakness / Material Noncompliance
Federal Program(s): Research and Development Cluster
Assistance Listing Number(s):
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Criteria: Procurement methods established under 2 CFR 200.320, requires price or rate quotations to be obtained from an adequate number of qualified sources when the aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold of $10,000, but less than the simplified acquisition threshold of $250,000.
Condition: The College did not obtain price or rate quotations obtained from different qualified transactions for all small purchase transactions sampled under the Research and Development Cluster Grants.
Cause: The College did not have a procurement policy in place during the year ended June 30, 2024 that required price or rate quotations for small purchases.
Effect or Potential Effect: Noncompliance with procurement requirements could result in unethical purchasing practices or overspending.
Questioned Costs: Undeterminable
Context: We tested 3 small purchase vendor transactions from the Research and Development Cluster totaling approximately $152,000 where no price or rate quotations were obtained prior to payment. The total population of small vendor purchases within this federal program was $422,246.
Repeat Finding: No
Recommendation: We recommend the College review its procurement policy to ensure it is in compliance with 2 CFR 200 Uniform Guidance and implement controls to ensure an audit trail is maintained surrounding the procurement of vendors using federal funds.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-002: Procurement over Small Purchase Transactions (Research and Development Grants)
Material Weakness / Material Noncompliance
Federal Program(s): Research and Development Cluster
Assistance Listing Number(s):
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Criteria: Procurement methods established under 2 CFR 200.320, requires price or rate quotations to be obtained from an adequate number of qualified sources when the aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold of $10,000, but less than the simplified acquisition threshold of $250,000.
Condition: The College did not obtain price or rate quotations obtained from different qualified transactions for all small purchase transactions sampled under the Research and Development Cluster Grants.
Cause: The College did not have a procurement policy in place during the year ended June 30, 2024 that required price or rate quotations for small purchases.
Effect or Potential Effect: Noncompliance with procurement requirements could result in unethical purchasing practices or overspending.
Questioned Costs: Undeterminable
Context: We tested 3 small purchase vendor transactions from the Research and Development Cluster totaling approximately $152,000 where no price or rate quotations were obtained prior to payment. The total population of small vendor purchases within this federal program was $422,246.
Repeat Finding: No
Recommendation: We recommend the College review its procurement policy to ensure it is in compliance with 2 CFR 200 Uniform Guidance and implement controls to ensure an audit trail is maintained surrounding the procurement of vendors using federal funds.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-002: Procurement over Small Purchase Transactions (Research and Development Grants)
Material Weakness / Material Noncompliance
Federal Program(s): Research and Development Cluster
Assistance Listing Number(s):
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Criteria: Procurement methods established under 2 CFR 200.320, requires price or rate quotations to be obtained from an adequate number of qualified sources when the aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold of $10,000, but less than the simplified acquisition threshold of $250,000.
Condition: The College did not obtain price or rate quotations obtained from different qualified transactions for all small purchase transactions sampled under the Research and Development Cluster Grants.
Cause: The College did not have a procurement policy in place during the year ended June 30, 2024 that required price or rate quotations for small purchases.
Effect or Potential Effect: Noncompliance with procurement requirements could result in unethical purchasing practices or overspending.
Questioned Costs: Undeterminable
Context: We tested 3 small purchase vendor transactions from the Research and Development Cluster totaling approximately $152,000 where no price or rate quotations were obtained prior to payment. The total population of small vendor purchases within this federal program was $422,246.
Repeat Finding: No
Recommendation: We recommend the College review its procurement policy to ensure it is in compliance with 2 CFR 200 Uniform Guidance and implement controls to ensure an audit trail is maintained surrounding the procurement of vendors using federal funds.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-002: Procurement over Small Purchase Transactions (Research and Development Grants)
Material Weakness / Material Noncompliance
Federal Program(s): Research and Development Cluster
Assistance Listing Number(s):
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Criteria: Procurement methods established under 2 CFR 200.320, requires price or rate quotations to be obtained from an adequate number of qualified sources when the aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold of $10,000, but less than the simplified acquisition threshold of $250,000.
Condition: The College did not obtain price or rate quotations obtained from different qualified transactions for all small purchase transactions sampled under the Research and Development Cluster Grants.
Cause: The College did not have a procurement policy in place during the year ended June 30, 2024 that required price or rate quotations for small purchases.
Effect or Potential Effect: Noncompliance with procurement requirements could result in unethical purchasing practices or overspending.
Questioned Costs: Undeterminable
Context: We tested 3 small purchase vendor transactions from the Research and Development Cluster totaling approximately $152,000 where no price or rate quotations were obtained prior to payment. The total population of small vendor purchases within this federal program was $422,246.
Repeat Finding: No
Recommendation: We recommend the College review its procurement policy to ensure it is in compliance with 2 CFR 200 Uniform Guidance and implement controls to ensure an audit trail is maintained surrounding the procurement of vendors using federal funds.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-002: Procurement over Small Purchase Transactions (Research and Development Grants)
Material Weakness / Material Noncompliance
Federal Program(s): Research and Development Cluster
Assistance Listing Number(s):
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Criteria: Procurement methods established under 2 CFR 200.320, requires price or rate quotations to be obtained from an adequate number of qualified sources when the aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold of $10,000, but less than the simplified acquisition threshold of $250,000.
Condition: The College did not obtain price or rate quotations obtained from different qualified transactions for all small purchase transactions sampled under the Research and Development Cluster Grants.
Cause: The College did not have a procurement policy in place during the year ended June 30, 2024 that required price or rate quotations for small purchases.
Effect or Potential Effect: Noncompliance with procurement requirements could result in unethical purchasing practices or overspending.
Questioned Costs: Undeterminable
Context: We tested 3 small purchase vendor transactions from the Research and Development Cluster totaling approximately $152,000 where no price or rate quotations were obtained prior to payment. The total population of small vendor purchases within this federal program was $422,246.
Repeat Finding: No
Recommendation: We recommend the College review its procurement policy to ensure it is in compliance with 2 CFR 200 Uniform Guidance and implement controls to ensure an audit trail is maintained surrounding the procurement of vendors using federal funds.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-002: Procurement over Small Purchase Transactions (Research and Development Grants)
Material Weakness / Material Noncompliance
Federal Program(s): Research and Development Cluster
Assistance Listing Number(s):
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Criteria: Procurement methods established under 2 CFR 200.320, requires price or rate quotations to be obtained from an adequate number of qualified sources when the aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold of $10,000, but less than the simplified acquisition threshold of $250,000.
Condition: The College did not obtain price or rate quotations obtained from different qualified transactions for all small purchase transactions sampled under the Research and Development Cluster Grants.
Cause: The College did not have a procurement policy in place during the year ended June 30, 2024 that required price or rate quotations for small purchases.
Effect or Potential Effect: Noncompliance with procurement requirements could result in unethical purchasing practices or overspending.
Questioned Costs: Undeterminable
Context: We tested 3 small purchase vendor transactions from the Research and Development Cluster totaling approximately $152,000 where no price or rate quotations were obtained prior to payment. The total population of small vendor purchases within this federal program was $422,246.
Repeat Finding: No
Recommendation: We recommend the College review its procurement policy to ensure it is in compliance with 2 CFR 200 Uniform Guidance and implement controls to ensure an audit trail is maintained surrounding the procurement of vendors using federal funds.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-002: Procurement over Small Purchase Transactions (Research and Development Grants)
Material Weakness / Material Noncompliance
Federal Program(s): Research and Development Cluster
Assistance Listing Number(s):
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Criteria: Procurement methods established under 2 CFR 200.320, requires price or rate quotations to be obtained from an adequate number of qualified sources when the aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold of $10,000, but less than the simplified acquisition threshold of $250,000.
Condition: The College did not obtain price or rate quotations obtained from different qualified transactions for all small purchase transactions sampled under the Research and Development Cluster Grants.
Cause: The College did not have a procurement policy in place during the year ended June 30, 2024 that required price or rate quotations for small purchases.
Effect or Potential Effect: Noncompliance with procurement requirements could result in unethical purchasing practices or overspending.
Questioned Costs: Undeterminable
Context: We tested 3 small purchase vendor transactions from the Research and Development Cluster totaling approximately $152,000 where no price or rate quotations were obtained prior to payment. The total population of small vendor purchases within this federal program was $422,246.
Repeat Finding: No
Recommendation: We recommend the College review its procurement policy to ensure it is in compliance with 2 CFR 200 Uniform Guidance and implement controls to ensure an audit trail is maintained surrounding the procurement of vendors using federal funds.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-002: Procurement over Small Purchase Transactions (Research and Development Grants)
Material Weakness / Material Noncompliance
Federal Program(s): Research and Development Cluster
Assistance Listing Number(s):
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Criteria: Procurement methods established under 2 CFR 200.320, requires price or rate quotations to be obtained from an adequate number of qualified sources when the aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold of $10,000, but less than the simplified acquisition threshold of $250,000.
Condition: The College did not obtain price or rate quotations obtained from different qualified transactions for all small purchase transactions sampled under the Research and Development Cluster Grants.
Cause: The College did not have a procurement policy in place during the year ended June 30, 2024 that required price or rate quotations for small purchases.
Effect or Potential Effect: Noncompliance with procurement requirements could result in unethical purchasing practices or overspending.
Questioned Costs: Undeterminable
Context: We tested 3 small purchase vendor transactions from the Research and Development Cluster totaling approximately $152,000 where no price or rate quotations were obtained prior to payment. The total population of small vendor purchases within this federal program was $422,246.
Repeat Finding: No
Recommendation: We recommend the College review its procurement policy to ensure it is in compliance with 2 CFR 200 Uniform Guidance and implement controls to ensure an audit trail is maintained surrounding the procurement of vendors using federal funds.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-002: Procurement over Small Purchase Transactions (Research and Development Grants)
Material Weakness / Material Noncompliance
Federal Program(s): Research and Development Cluster
Assistance Listing Number(s):
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Criteria: Procurement methods established under 2 CFR 200.320, requires price or rate quotations to be obtained from an adequate number of qualified sources when the aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold of $10,000, but less than the simplified acquisition threshold of $250,000.
Condition: The College did not obtain price or rate quotations obtained from different qualified transactions for all small purchase transactions sampled under the Research and Development Cluster Grants.
Cause: The College did not have a procurement policy in place during the year ended June 30, 2024 that required price or rate quotations for small purchases.
Effect or Potential Effect: Noncompliance with procurement requirements could result in unethical purchasing practices or overspending.
Questioned Costs: Undeterminable
Context: We tested 3 small purchase vendor transactions from the Research and Development Cluster totaling approximately $152,000 where no price or rate quotations were obtained prior to payment. The total population of small vendor purchases within this federal program was $422,246.
Repeat Finding: No
Recommendation: We recommend the College review its procurement policy to ensure it is in compliance with 2 CFR 200 Uniform Guidance and implement controls to ensure an audit trail is maintained surrounding the procurement of vendors using federal funds.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-003: Procurement over Small Purchase Transactions (Mental and Behavioral Health Education and Training Grants)
Material Weakness / Other Matter Noncompliance
Federal Program(s): Mental and Behavioral Health Education and Training Grants
Assistance Listing Number(s):
• 93.732
Criteria: Procurement methods established under 2 CFR 200.320, requires price or rate quotations to be obtained from an adequate number of qualified sources when the aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold of $10,000, but less than the simplified acquisition threshold of $250,000.
Condition: The College did not obtain price or rate quotations obtained from different qualified transactions for all small purchase transactions sampled under the Mental and Behavioral Health Education and Training Grants.
Cause: The College did not have a procurement policy in place during the year ended June 30, 2024 that required price or rate quotations for small purchases.
Effect or Potential Effect: Noncompliance with procurement requirements could result in unethical purchasing practices or overspending.
Questioned Costs: Undeterminable
Context: We tested 1 small purchase vendor transaction from the Mental and Behavioral Health Education and Training grants in the amount of $13,000 were no price or rate quotations were obtained prior to payment. The total population of small vendor purchases within this federal program was $13,000.
Repeat Finding: No
Recommendation: We recommend the College review its procurement policy to ensure it is in compliance with 2 CFR 200 Uniform Guidance and implement controls to ensure an audit trail is maintained surrounding the procurement of vendors using federal funds.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Material Weakness
Federal Program(s): Research and Development Cluster
Mental and Behavioral Health Education and Training Grants
Assistance Listing Number(s):
Research and Development Cluster
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Mental and Behavioral Health Education and Training Grants
• 93.732
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: Timesheets and time and effort reports used to track time spent on federal programs did not have approval signatures by the employee’s supervisor.
Cause: Ineffective design and implementation of internal controls around approval of timesheets and time and effort reports.
Effect or Potential Effect: Ineffective control procedures could result in unallowable costs or activities being charged to federal grant programs.
Questioned Costs: None
Context: In our sample of 10 payroll transactions of amounts charged to the Research and Development Cluster, 9 of the timesheets or time and effort reports did not have physical indication of review by their supervisors. In our sample of 6 payroll transactions of amounts charged to the Mental and Behavioral Health Education and Training grants, none of the timesheets or time and effort reports had physical indication of review by their supervisors.
Repeat Finding: No
Recommendation: We recommend the College enforce its policy to have physical signatures on each employee’s timesheet or time and effort report after the review takes place to ensure salary costs charged to the federal program are allowable.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Material Weakness
Federal Program(s): Research and Development Cluster
Mental and Behavioral Health Education and Training Grants
Assistance Listing Number(s):
Research and Development Cluster
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Mental and Behavioral Health Education and Training Grants
• 93.732
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: Timesheets and time and effort reports used to track time spent on federal programs did not have approval signatures by the employee’s supervisor.
Cause: Ineffective design and implementation of internal controls around approval of timesheets and time and effort reports.
Effect or Potential Effect: Ineffective control procedures could result in unallowable costs or activities being charged to federal grant programs.
Questioned Costs: None
Context: In our sample of 10 payroll transactions of amounts charged to the Research and Development Cluster, 9 of the timesheets or time and effort reports did not have physical indication of review by their supervisors. In our sample of 6 payroll transactions of amounts charged to the Mental and Behavioral Health Education and Training grants, none of the timesheets or time and effort reports had physical indication of review by their supervisors.
Repeat Finding: No
Recommendation: We recommend the College enforce its policy to have physical signatures on each employee’s timesheet or time and effort report after the review takes place to ensure salary costs charged to the federal program are allowable.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Material Weakness
Federal Program(s): Research and Development Cluster
Mental and Behavioral Health Education and Training Grants
Assistance Listing Number(s):
Research and Development Cluster
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Mental and Behavioral Health Education and Training Grants
• 93.732
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: Timesheets and time and effort reports used to track time spent on federal programs did not have approval signatures by the employee’s supervisor.
Cause: Ineffective design and implementation of internal controls around approval of timesheets and time and effort reports.
Effect or Potential Effect: Ineffective control procedures could result in unallowable costs or activities being charged to federal grant programs.
Questioned Costs: None
Context: In our sample of 10 payroll transactions of amounts charged to the Research and Development Cluster, 9 of the timesheets or time and effort reports did not have physical indication of review by their supervisors. In our sample of 6 payroll transactions of amounts charged to the Mental and Behavioral Health Education and Training grants, none of the timesheets or time and effort reports had physical indication of review by their supervisors.
Repeat Finding: No
Recommendation: We recommend the College enforce its policy to have physical signatures on each employee’s timesheet or time and effort report after the review takes place to ensure salary costs charged to the federal program are allowable.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Material Weakness
Federal Program(s): Research and Development Cluster
Mental and Behavioral Health Education and Training Grants
Assistance Listing Number(s):
Research and Development Cluster
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Mental and Behavioral Health Education and Training Grants
• 93.732
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: Timesheets and time and effort reports used to track time spent on federal programs did not have approval signatures by the employee’s supervisor.
Cause: Ineffective design and implementation of internal controls around approval of timesheets and time and effort reports.
Effect or Potential Effect: Ineffective control procedures could result in unallowable costs or activities being charged to federal grant programs.
Questioned Costs: None
Context: In our sample of 10 payroll transactions of amounts charged to the Research and Development Cluster, 9 of the timesheets or time and effort reports did not have physical indication of review by their supervisors. In our sample of 6 payroll transactions of amounts charged to the Mental and Behavioral Health Education and Training grants, none of the timesheets or time and effort reports had physical indication of review by their supervisors.
Repeat Finding: No
Recommendation: We recommend the College enforce its policy to have physical signatures on each employee’s timesheet or time and effort report after the review takes place to ensure salary costs charged to the federal program are allowable.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Material Weakness
Federal Program(s): Research and Development Cluster
Mental and Behavioral Health Education and Training Grants
Assistance Listing Number(s):
Research and Development Cluster
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Mental and Behavioral Health Education and Training Grants
• 93.732
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: Timesheets and time and effort reports used to track time spent on federal programs did not have approval signatures by the employee’s supervisor.
Cause: Ineffective design and implementation of internal controls around approval of timesheets and time and effort reports.
Effect or Potential Effect: Ineffective control procedures could result in unallowable costs or activities being charged to federal grant programs.
Questioned Costs: None
Context: In our sample of 10 payroll transactions of amounts charged to the Research and Development Cluster, 9 of the timesheets or time and effort reports did not have physical indication of review by their supervisors. In our sample of 6 payroll transactions of amounts charged to the Mental and Behavioral Health Education and Training grants, none of the timesheets or time and effort reports had physical indication of review by their supervisors.
Repeat Finding: No
Recommendation: We recommend the College enforce its policy to have physical signatures on each employee’s timesheet or time and effort report after the review takes place to ensure salary costs charged to the federal program are allowable.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Material Weakness
Federal Program(s): Research and Development Cluster
Mental and Behavioral Health Education and Training Grants
Assistance Listing Number(s):
Research and Development Cluster
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Mental and Behavioral Health Education and Training Grants
• 93.732
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: Timesheets and time and effort reports used to track time spent on federal programs did not have approval signatures by the employee’s supervisor.
Cause: Ineffective design and implementation of internal controls around approval of timesheets and time and effort reports.
Effect or Potential Effect: Ineffective control procedures could result in unallowable costs or activities being charged to federal grant programs.
Questioned Costs: None
Context: In our sample of 10 payroll transactions of amounts charged to the Research and Development Cluster, 9 of the timesheets or time and effort reports did not have physical indication of review by their supervisors. In our sample of 6 payroll transactions of amounts charged to the Mental and Behavioral Health Education and Training grants, none of the timesheets or time and effort reports had physical indication of review by their supervisors.
Repeat Finding: No
Recommendation: We recommend the College enforce its policy to have physical signatures on each employee’s timesheet or time and effort report after the review takes place to ensure salary costs charged to the federal program are allowable.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Material Weakness
Federal Program(s): Research and Development Cluster
Mental and Behavioral Health Education and Training Grants
Assistance Listing Number(s):
Research and Development Cluster
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Mental and Behavioral Health Education and Training Grants
• 93.732
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: Timesheets and time and effort reports used to track time spent on federal programs did not have approval signatures by the employee’s supervisor.
Cause: Ineffective design and implementation of internal controls around approval of timesheets and time and effort reports.
Effect or Potential Effect: Ineffective control procedures could result in unallowable costs or activities being charged to federal grant programs.
Questioned Costs: None
Context: In our sample of 10 payroll transactions of amounts charged to the Research and Development Cluster, 9 of the timesheets or time and effort reports did not have physical indication of review by their supervisors. In our sample of 6 payroll transactions of amounts charged to the Mental and Behavioral Health Education and Training grants, none of the timesheets or time and effort reports had physical indication of review by their supervisors.
Repeat Finding: No
Recommendation: We recommend the College enforce its policy to have physical signatures on each employee’s timesheet or time and effort report after the review takes place to ensure salary costs charged to the federal program are allowable.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Material Weakness
Federal Program(s): Research and Development Cluster
Mental and Behavioral Health Education and Training Grants
Assistance Listing Number(s):
Research and Development Cluster
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Mental and Behavioral Health Education and Training Grants
• 93.732
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: Timesheets and time and effort reports used to track time spent on federal programs did not have approval signatures by the employee’s supervisor.
Cause: Ineffective design and implementation of internal controls around approval of timesheets and time and effort reports.
Effect or Potential Effect: Ineffective control procedures could result in unallowable costs or activities being charged to federal grant programs.
Questioned Costs: None
Context: In our sample of 10 payroll transactions of amounts charged to the Research and Development Cluster, 9 of the timesheets or time and effort reports did not have physical indication of review by their supervisors. In our sample of 6 payroll transactions of amounts charged to the Mental and Behavioral Health Education and Training grants, none of the timesheets or time and effort reports had physical indication of review by their supervisors.
Repeat Finding: No
Recommendation: We recommend the College enforce its policy to have physical signatures on each employee’s timesheet or time and effort report after the review takes place to ensure salary costs charged to the federal program are allowable.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Material Weakness
Federal Program(s): Research and Development Cluster
Mental and Behavioral Health Education and Training Grants
Assistance Listing Number(s):
Research and Development Cluster
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Mental and Behavioral Health Education and Training Grants
• 93.732
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: Timesheets and time and effort reports used to track time spent on federal programs did not have approval signatures by the employee’s supervisor.
Cause: Ineffective design and implementation of internal controls around approval of timesheets and time and effort reports.
Effect or Potential Effect: Ineffective control procedures could result in unallowable costs or activities being charged to federal grant programs.
Questioned Costs: None
Context: In our sample of 10 payroll transactions of amounts charged to the Research and Development Cluster, 9 of the timesheets or time and effort reports did not have physical indication of review by their supervisors. In our sample of 6 payroll transactions of amounts charged to the Mental and Behavioral Health Education and Training grants, none of the timesheets or time and effort reports had physical indication of review by their supervisors.
Repeat Finding: No
Recommendation: We recommend the College enforce its policy to have physical signatures on each employee’s timesheet or time and effort report after the review takes place to ensure salary costs charged to the federal program are allowable.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Material Weakness
Federal Program(s): Research and Development Cluster
Mental and Behavioral Health Education and Training Grants
Assistance Listing Number(s):
Research and Development Cluster
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Mental and Behavioral Health Education and Training Grants
• 93.732
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: Timesheets and time and effort reports used to track time spent on federal programs did not have approval signatures by the employee’s supervisor.
Cause: Ineffective design and implementation of internal controls around approval of timesheets and time and effort reports.
Effect or Potential Effect: Ineffective control procedures could result in unallowable costs or activities being charged to federal grant programs.
Questioned Costs: None
Context: In our sample of 10 payroll transactions of amounts charged to the Research and Development Cluster, 9 of the timesheets or time and effort reports did not have physical indication of review by their supervisors. In our sample of 6 payroll transactions of amounts charged to the Mental and Behavioral Health Education and Training grants, none of the timesheets or time and effort reports had physical indication of review by their supervisors.
Repeat Finding: No
Recommendation: We recommend the College enforce its policy to have physical signatures on each employee’s timesheet or time and effort report after the review takes place to ensure salary costs charged to the federal program are allowable.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Material Weakness
Federal Program(s): Research and Development Cluster
Mental and Behavioral Health Education and Training Grants
Assistance Listing Number(s):
Research and Development Cluster
• 11.417
• 12.420
• 12.905
• 84.116Z
• 84.019A
• 47.076
• 47.050
Mental and Behavioral Health Education and Training Grants
• 93.732
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: Timesheets and time and effort reports used to track time spent on federal programs did not have approval signatures by the employee’s supervisor.
Cause: Ineffective design and implementation of internal controls around approval of timesheets and time and effort reports.
Effect or Potential Effect: Ineffective control procedures could result in unallowable costs or activities being charged to federal grant programs.
Questioned Costs: None
Context: In our sample of 10 payroll transactions of amounts charged to the Research and Development Cluster, 9 of the timesheets or time and effort reports did not have physical indication of review by their supervisors. In our sample of 6 payroll transactions of amounts charged to the Mental and Behavioral Health Education and Training grants, none of the timesheets or time and effort reports had physical indication of review by their supervisors.
Repeat Finding: No
Recommendation: We recommend the College enforce its policy to have physical signatures on each employee’s timesheet or time and effort report after the review takes place to ensure salary costs charged to the federal program are allowable.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-005: Enrollment Reporting – Student Financial Aid Special Test
Material Weakness / Other Matter Noncompliance
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.063
• 84.268
Criteria: To comply with enrollment reporting requirements, institutions must accurately and timely report student enrollment status changes to the National Student Loan Data System (NSLDS) within 60 days of determining the change, as outlined in Federal Regulations 34 CFR 682.610 and 685.309.
Condition: There is no control in place by the College to review information submitted to the NSLDS for student enrollment status changes. There were instances of noncompliance where students with enrollment status changes were received by the NSLDS outside of the 60-day requirement.
Cause: Lack of control in place over enrollment status changes reported to the NSLDS.
Effect or Potential Effect: Lack of controls in place could result in instances of noncompliance with Department of Education and Federal regulations.
Questioned Costs: None
Context: In our sample of 40 students with enrollment status changes during the year ended June 30, 2024, 4 were reported to the NSLDS outside of the 60-day requirement. While the College ensures accurate status change data is sent to the National Student Clearinghouse (third party who submits enrollment status changes to the NSLDS), the College does not have controls in place to ensure information was submitted to the NSLDS accurately and timely.
Repeat Finding: No
Recommendation: We recommend the College implement controls where there is an independent review of the submissions received by NSLDS to ensure enrollment status changes are reported accurately and timely.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-005: Enrollment Reporting – Student Financial Aid Special Test
Material Weakness / Other Matter Noncompliance
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.063
• 84.268
Criteria: To comply with enrollment reporting requirements, institutions must accurately and timely report student enrollment status changes to the National Student Loan Data System (NSLDS) within 60 days of determining the change, as outlined in Federal Regulations 34 CFR 682.610 and 685.309.
Condition: There is no control in place by the College to review information submitted to the NSLDS for student enrollment status changes. There were instances of noncompliance where students with enrollment status changes were received by the NSLDS outside of the 60-day requirement.
Cause: Lack of control in place over enrollment status changes reported to the NSLDS.
Effect or Potential Effect: Lack of controls in place could result in instances of noncompliance with Department of Education and Federal regulations.
Questioned Costs: None
Context: In our sample of 40 students with enrollment status changes during the year ended June 30, 2024, 4 were reported to the NSLDS outside of the 60-day requirement. While the College ensures accurate status change data is sent to the National Student Clearinghouse (third party who submits enrollment status changes to the NSLDS), the College does not have controls in place to ensure information was submitted to the NSLDS accurately and timely.
Repeat Finding: No
Recommendation: We recommend the College implement controls where there is an independent review of the submissions received by NSLDS to ensure enrollment status changes are reported accurately and timely.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-006: Perkins Loan Recordkeeping and Record Retention
Significant Deficiency/Other Matter Noncompliance
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.038
Criteria: Institutions must properly maintain its Perkins loan records in the manner set forth in 34 CFR 674.19.(e). Institutions are required to keep original paper promissory notes or original paper master promissory notes (MPNs) and repayment schedules in a locked, fireproof container. The original promissory notes and repayment schedules must be kept until the loans are satisfied. An institution shall retain repayment records, including cancellation and deferment requests for at least three years from the date on which a loan is assigned to the secretary, canceled, or repaid. An institution shall retain disbursement and electronic authentication and signature records for each loan made using an MPN for at least three years from the date the loan is canceled, repaid, or otherwise satisfied.
Condition: The College could not locate promissory notes or MPNs for some of its Perkins loans when requested by the auditors.
Cause: Improper recordkeeping and retention processes and controls.
Effect or Potential Effect: Noncompliance with the Department of Education and record retention requirements set forth in 34 CFR 674.19.(e).
Questioned Costs: None
Context: In our sample of 40 students with open Perkins loans as of June 30, 2024, the College could not locate the original promissory note for 1 student. In our sample of 40 students with retired or assigned loans in the current year and prior three years, the College could not locate the promissory note and repayment records for 3 students.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for recordkeeping and retention over both open loans and retired or assigned loans for the past 3 years, to ensure required documents are adequately maintained and stored.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-007: Student Credit Balances from Title IV Awards
Significant Deficiency
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.007
• 84.033
• 84.038
• 84.063
• 84.268
• 84.379
• 93.925
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, food and housing, and other authorized charges assessed the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. The College does not have a control in place with physical indication of review over refund process for student credit balances.
Cause: Lack of control in place over refunds from student credit balances
Effect or Potential Effect: Student credit balances may not be refunded within the 14-day requirement.
Questioned Costs: None
Context: During our control assessment over student credit balance refunds, we noted there is no control in place and no physical indication of review taking place to ensure student credit balances are properly refunded within the 14-day requirement.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for student credit balances to include an independent review and sufficient documentation to support the application of the control.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-007: Student Credit Balances from Title IV Awards
Significant Deficiency
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.007
• 84.033
• 84.038
• 84.063
• 84.268
• 84.379
• 93.925
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, food and housing, and other authorized charges assessed the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. The College does not have a control in place with physical indication of review over refund process for student credit balances.
Cause: Lack of control in place over refunds from student credit balances
Effect or Potential Effect: Student credit balances may not be refunded within the 14-day requirement.
Questioned Costs: None
Context: During our control assessment over student credit balance refunds, we noted there is no control in place and no physical indication of review taking place to ensure student credit balances are properly refunded within the 14-day requirement.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for student credit balances to include an independent review and sufficient documentation to support the application of the control.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-007: Student Credit Balances from Title IV Awards
Significant Deficiency
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.007
• 84.033
• 84.038
• 84.063
• 84.268
• 84.379
• 93.925
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, food and housing, and other authorized charges assessed the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. The College does not have a control in place with physical indication of review over refund process for student credit balances.
Cause: Lack of control in place over refunds from student credit balances
Effect or Potential Effect: Student credit balances may not be refunded within the 14-day requirement.
Questioned Costs: None
Context: During our control assessment over student credit balance refunds, we noted there is no control in place and no physical indication of review taking place to ensure student credit balances are properly refunded within the 14-day requirement.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for student credit balances to include an independent review and sufficient documentation to support the application of the control.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-007: Student Credit Balances from Title IV Awards
Significant Deficiency
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.007
• 84.033
• 84.038
• 84.063
• 84.268
• 84.379
• 93.925
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, food and housing, and other authorized charges assessed the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. The College does not have a control in place with physical indication of review over refund process for student credit balances.
Cause: Lack of control in place over refunds from student credit balances
Effect or Potential Effect: Student credit balances may not be refunded within the 14-day requirement.
Questioned Costs: None
Context: During our control assessment over student credit balance refunds, we noted there is no control in place and no physical indication of review taking place to ensure student credit balances are properly refunded within the 14-day requirement.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for student credit balances to include an independent review and sufficient documentation to support the application of the control.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-007: Student Credit Balances from Title IV Awards
Significant Deficiency
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.007
• 84.033
• 84.038
• 84.063
• 84.268
• 84.379
• 93.925
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, food and housing, and other authorized charges assessed the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. The College does not have a control in place with physical indication of review over refund process for student credit balances.
Cause: Lack of control in place over refunds from student credit balances
Effect or Potential Effect: Student credit balances may not be refunded within the 14-day requirement.
Questioned Costs: None
Context: During our control assessment over student credit balance refunds, we noted there is no control in place and no physical indication of review taking place to ensure student credit balances are properly refunded within the 14-day requirement.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for student credit balances to include an independent review and sufficient documentation to support the application of the control.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-007: Student Credit Balances from Title IV Awards
Significant Deficiency
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.007
• 84.033
• 84.038
• 84.063
• 84.268
• 84.379
• 93.925
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, food and housing, and other authorized charges assessed the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. The College does not have a control in place with physical indication of review over refund process for student credit balances.
Cause: Lack of control in place over refunds from student credit balances
Effect or Potential Effect: Student credit balances may not be refunded within the 14-day requirement.
Questioned Costs: None
Context: During our control assessment over student credit balance refunds, we noted there is no control in place and no physical indication of review taking place to ensure student credit balances are properly refunded within the 14-day requirement.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for student credit balances to include an independent review and sufficient documentation to support the application of the control.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-007: Student Credit Balances from Title IV Awards
Significant Deficiency
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.007
• 84.033
• 84.038
• 84.063
• 84.268
• 84.379
• 93.925
Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to 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 a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, food and housing, and other authorized charges assessed the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. The College does not have a control in place with physical indication of review over refund process for student credit balances.
Cause: Lack of control in place over refunds from student credit balances
Effect or Potential Effect: Student credit balances may not be refunded within the 14-day requirement.
Questioned Costs: None
Context: During our control assessment over student credit balance refunds, we noted there is no control in place and no physical indication of review taking place to ensure student credit balances are properly refunded within the 14-day requirement.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for student credit balances to include an independent review and sufficient documentation to support the application of the control.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-008: Return of Title IV Funds
Significant Deficiency / Other Matter Noncompliance
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.007
• 84.033
• 84.038
• 84.063
• 84.268
• 84.379
• 93.925
Criteria: When a student withdraws, institutions must comply with the "Return of Title IV Funds" requirements outlined in 34 CFR 668.22, ensuring any unearned funds are returned to the Department of Education within 45 days of determining the student's withdrawal.
Condition: We identified instances of unearned funds not returned to the Department of Education within the 45-day requirement.
Cause: Lack of control in place over returns of Title IV funding
Effect or Potential Effect: Returns of Title IV Funds may not be refunded within the 45-day requirement and result in instances of noncompliance with the Department of Education.
Questioned Costs: $9,259
Context: During our sample of 12 students who withdrew during the fiscal year ended June 30, 2024, we identified 3 students whose date withdrawn from the College resulted in unearned funds required to be returned to the Department of Education. The return of funds calculation was not completed for these students, resulting in unearned funds not returned within the 45-day requirement.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for calculating refunds from Title IV and include an independent review and sufficient documentation to support the application of the control.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-008: Return of Title IV Funds
Significant Deficiency / Other Matter Noncompliance
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.007
• 84.033
• 84.038
• 84.063
• 84.268
• 84.379
• 93.925
Criteria: When a student withdraws, institutions must comply with the "Return of Title IV Funds" requirements outlined in 34 CFR 668.22, ensuring any unearned funds are returned to the Department of Education within 45 days of determining the student's withdrawal.
Condition: We identified instances of unearned funds not returned to the Department of Education within the 45-day requirement.
Cause: Lack of control in place over returns of Title IV funding
Effect or Potential Effect: Returns of Title IV Funds may not be refunded within the 45-day requirement and result in instances of noncompliance with the Department of Education.
Questioned Costs: $9,259
Context: During our sample of 12 students who withdrew during the fiscal year ended June 30, 2024, we identified 3 students whose date withdrawn from the College resulted in unearned funds required to be returned to the Department of Education. The return of funds calculation was not completed for these students, resulting in unearned funds not returned within the 45-day requirement.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for calculating refunds from Title IV and include an independent review and sufficient documentation to support the application of the control.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-008: Return of Title IV Funds
Significant Deficiency / Other Matter Noncompliance
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.007
• 84.033
• 84.038
• 84.063
• 84.268
• 84.379
• 93.925
Criteria: When a student withdraws, institutions must comply with the "Return of Title IV Funds" requirements outlined in 34 CFR 668.22, ensuring any unearned funds are returned to the Department of Education within 45 days of determining the student's withdrawal.
Condition: We identified instances of unearned funds not returned to the Department of Education within the 45-day requirement.
Cause: Lack of control in place over returns of Title IV funding
Effect or Potential Effect: Returns of Title IV Funds may not be refunded within the 45-day requirement and result in instances of noncompliance with the Department of Education.
Questioned Costs: $9,259
Context: During our sample of 12 students who withdrew during the fiscal year ended June 30, 2024, we identified 3 students whose date withdrawn from the College resulted in unearned funds required to be returned to the Department of Education. The return of funds calculation was not completed for these students, resulting in unearned funds not returned within the 45-day requirement.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for calculating refunds from Title IV and include an independent review and sufficient documentation to support the application of the control.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-008: Return of Title IV Funds
Significant Deficiency / Other Matter Noncompliance
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.007
• 84.033
• 84.038
• 84.063
• 84.268
• 84.379
• 93.925
Criteria: When a student withdraws, institutions must comply with the "Return of Title IV Funds" requirements outlined in 34 CFR 668.22, ensuring any unearned funds are returned to the Department of Education within 45 days of determining the student's withdrawal.
Condition: We identified instances of unearned funds not returned to the Department of Education within the 45-day requirement.
Cause: Lack of control in place over returns of Title IV funding
Effect or Potential Effect: Returns of Title IV Funds may not be refunded within the 45-day requirement and result in instances of noncompliance with the Department of Education.
Questioned Costs: $9,259
Context: During our sample of 12 students who withdrew during the fiscal year ended June 30, 2024, we identified 3 students whose date withdrawn from the College resulted in unearned funds required to be returned to the Department of Education. The return of funds calculation was not completed for these students, resulting in unearned funds not returned within the 45-day requirement.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for calculating refunds from Title IV and include an independent review and sufficient documentation to support the application of the control.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-008: Return of Title IV Funds
Significant Deficiency / Other Matter Noncompliance
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.007
• 84.033
• 84.038
• 84.063
• 84.268
• 84.379
• 93.925
Criteria: When a student withdraws, institutions must comply with the "Return of Title IV Funds" requirements outlined in 34 CFR 668.22, ensuring any unearned funds are returned to the Department of Education within 45 days of determining the student's withdrawal.
Condition: We identified instances of unearned funds not returned to the Department of Education within the 45-day requirement.
Cause: Lack of control in place over returns of Title IV funding
Effect or Potential Effect: Returns of Title IV Funds may not be refunded within the 45-day requirement and result in instances of noncompliance with the Department of Education.
Questioned Costs: $9,259
Context: During our sample of 12 students who withdrew during the fiscal year ended June 30, 2024, we identified 3 students whose date withdrawn from the College resulted in unearned funds required to be returned to the Department of Education. The return of funds calculation was not completed for these students, resulting in unearned funds not returned within the 45-day requirement.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for calculating refunds from Title IV and include an independent review and sufficient documentation to support the application of the control.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-008: Return of Title IV Funds
Significant Deficiency / Other Matter Noncompliance
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.007
• 84.033
• 84.038
• 84.063
• 84.268
• 84.379
• 93.925
Criteria: When a student withdraws, institutions must comply with the "Return of Title IV Funds" requirements outlined in 34 CFR 668.22, ensuring any unearned funds are returned to the Department of Education within 45 days of determining the student's withdrawal.
Condition: We identified instances of unearned funds not returned to the Department of Education within the 45-day requirement.
Cause: Lack of control in place over returns of Title IV funding
Effect or Potential Effect: Returns of Title IV Funds may not be refunded within the 45-day requirement and result in instances of noncompliance with the Department of Education.
Questioned Costs: $9,259
Context: During our sample of 12 students who withdrew during the fiscal year ended June 30, 2024, we identified 3 students whose date withdrawn from the College resulted in unearned funds required to be returned to the Department of Education. The return of funds calculation was not completed for these students, resulting in unearned funds not returned within the 45-day requirement.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for calculating refunds from Title IV and include an independent review and sufficient documentation to support the application of the control.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
2024-008: Return of Title IV Funds
Significant Deficiency / Other Matter Noncompliance
Federal Program: Student Financial Assistance Cluster
Assistance Listing Number(s):
Student Financial Assistance Cluster
• 84.007
• 84.033
• 84.038
• 84.063
• 84.268
• 84.379
• 93.925
Criteria: When a student withdraws, institutions must comply with the "Return of Title IV Funds" requirements outlined in 34 CFR 668.22, ensuring any unearned funds are returned to the Department of Education within 45 days of determining the student's withdrawal.
Condition: We identified instances of unearned funds not returned to the Department of Education within the 45-day requirement.
Cause: Lack of control in place over returns of Title IV funding
Effect or Potential Effect: Returns of Title IV Funds may not be refunded within the 45-day requirement and result in instances of noncompliance with the Department of Education.
Questioned Costs: $9,259
Context: During our sample of 12 students who withdrew during the fiscal year ended June 30, 2024, we identified 3 students whose date withdrawn from the College resulted in unearned funds required to be returned to the Department of Education. The return of funds calculation was not completed for these students, resulting in unearned funds not returned within the 45-day requirement.
Repeat Finding: No
Recommendation: We recommend the College review its process and controls in place for calculating refunds from Title IV and include an independent review and sufficient documentation to support the application of the control.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.