Audit 372530

III – Findings and questioned costs for Federal awards US Department of the Treasury Passed through Missouri Department of Higher Education and Workforce Development Program Name: Coronavirus State and Local Fiscal Recovery Fund / American Rescue Plan Act / MoExcels Grant Assistance Listing #: 21.027 Finding: 2024 – 001 SIGNIFICANT DEFICIENCY Reporting Condition: During our original audit, the College initially failed to include $768,053 of Coronavirus State and Local Fiscal Recovery Fund (ARPA) funding received from the State of Missouri on the Schedule of Expenditures of Federal Awards. Additionally, the College incorrectly included $78,539 of 2024-25 SEOG funding that was drawn but not expended in the 2023-24 SEFA, resulting in an overstatement of SEOG expenditures. These errors were identified subsequent to the issuance of the report and require a re-issuance of the related audit reports. The internal control system did not prevent or detect these errors during the SEFA preparation process. Cause: The College's procedures for identifying and reporting federal expenditures were insufficient. The MoExcels grant application was submitted outside of the finance office without early communication to finance personnel regarding the federal funding source. Since the College rarely receives federal funding beyond routine Student Financial Aid programs, finance personnel were initially unaware that the MoExcels funding originated from a federal source and therefore required inclusion on the SEFA. Additionally, the College lacked adequate cutoff procedures to ensure federal expenditures were reported in the correct period based on when costs were incurred rather than when funds were drawn down from federal systems. The absence of formal communication protocols between program staff and the finance staff who prepared the SEFA, combined with insufficient review procedures for year-end federal drawdown cutoff, contributed to these oversights. Effect: The initial errors resulted in an understatement of federal expenditures on the originally issued SEFA by $768,053 for ARPA funds and an overstatement by $78,539 for SEOG funds, for a net understatement of $689,514. While these errors have been corrected, the control deficiency increases the risk that future federal awards could be incorrectly reported on the SEFA, potentially resulting in noncompliance with federal reporting requirements and incomplete or inaccurate identification of major programs subject to audit. Questioned Costs: $0 Criteria: 2 CFR 200.510(b) requires that the auditee prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. Additionally, 2 CFR 200.303 requires that non-federal entities establish and maintain effective internal control over Federal awards that provides reasonable assurance that the non-federal entity is managing the awards in compliance with Federal statutes, regulations, and the terms and conditions of the related awards. Recommendation: We recommend the College implement written procedures for SEFA preparation that include: (1) obtaining and reviewing all grant agreements to identify federal funding sources; (2) establishing regular communication between program and finance departments to identify all federal awards received; (3) maintaining a master listing of all grants that identifies the funding source (federal/state/local) and applicable Assistance Listing Numbers; (4) implementing cutoff procedures to ensure federal expenditures are reported in the correct period based on when eligible costs are incurred, not when funds are drawn down from federal systems; and (5) requiring independent review of the SEFA by someone knowledgeable about federal compliance requirements who verifies completeness against grant documentation and proper period reporting. We note that the College's finance office maintains good communication practices with auditors regarding federal funding when they are aware of such awards; therefore, strengthening the internal identification and cutoff processes will enhance the College's ability to provide complete, accurate, and timely information to auditors about all federal funding sources. Views of responsible personnel and planned corrective actions: Management concurs with this finding. The College has implemented immediate corrective actions including development of a comprehensive grant tracking spreadsheet and establishment of regular meetings between program and finance staff. Additionally, effective immediately, all grant applications must be reviewed and approved by the Controller prior to submission to ensure proper identification of funding sources and compliance requirements. The College will also implement cutoff procedures to ensure federal expenditures are reported in the correct period based on when eligible costs are incurred. The Controller will review all G5 drawdowns near year-end to verify proper period reporting. Formal written procedures for SEFA preparation will be implemented by October 15, 2025. The Controller will maintain the master grant listing and review all grant agreements to determine federal funding sources. Beginning with fiscal year 2026 SEFA preparation, the CFO will perform an independent review for completeness and accuracy, including verification of proper period reporting for all federal expenditures.