Audit 39087

Condition: The District did not have procedures in place to review the reporting required by the grant for accuracy nor for verification of completion of the reporting requirements in a timely manner. Errors were noted in the June 30, 2022 institutional portion report identified as being the final report with all amounts expended at year-end while there was approximately $82,000 remaining to be spent. In addition, it was noted that one of two quarterly reports sampled were uploaded late by three days. Criteria: The U.S. Department of Education requires institutions that received Higher Education Emergency Relief Funds (HEERF) to publicly post certain information accurately on their website related to the student aid and institutional portions of the funds within 10 days of the end of each quarter. 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Effect: By not having a review process in place to verify the reports were accurate and uploaded timely, the reports were not available to the public within the allowed time after quarter-end. Cause: The District had limited employees involved in the disbursement of the HEERF funds resulting in only one person being able to prepare and review the reports. It is unclear why the quarter reviewed was uploaded late. Recommendation: We recommend implementing a process for a secondary review of the reports being prepared as well as a process for verifying reports are uploaded to the website accurately and timely. Views of Responsible Officials and Planned Corrective Action: The District will implement new procedures to verify reports are accurate and uploaded timely in the future.

Condition: The District did not have procedures in place to review the reporting required by the grant for accuracy nor for verification of completion of the reporting requirements in a timely manner. Errors were noted in the June 30, 2022 institutional portion report identified as being the final report with all amounts expended at year-end while there was approximately $82,000 remaining to be spent. In addition, it was noted that one of two quarterly reports sampled were uploaded late by three days. Criteria: The U.S. Department of Education requires institutions that received Higher Education Emergency Relief Funds (HEERF) to publicly post certain information accurately on their website related to the student aid and institutional portions of the funds within 10 days of the end of each quarter. 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Effect: By not having a review process in place to verify the reports were accurate and uploaded timely, the reports were not available to the public within the allowed time after quarter-end. Cause: The District had limited employees involved in the disbursement of the HEERF funds resulting in only one person being able to prepare and review the reports. It is unclear why the quarter reviewed was uploaded late. Recommendation: We recommend implementing a process for a secondary review of the reports being prepared as well as a process for verifying reports are uploaded to the website accurately and timely. Views of Responsible Officials and Planned Corrective Action: The District will implement new procedures to verify reports are accurate and uploaded timely in the future.

Condition: While testing controls, a group of employees were identified that the District missed when completing their triannual procedures related to obtaining time and effort or personnel activity reports from employees paid from grants. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Effect: In this instance, the District performed time and effort and personnel activity reports as a control procedure not specifically required by the grant, due to the type of payroll. This could have been a much more significant issue if it had been associated with certain other grants. Cause: The grant administrator indicated the employees were likely missed due to timing of posting payroll to the project and the reclassification of costs between projects during the year due to changes from the state level associated with accounting for the Education Stabilization Funds. Recommendation: The District should implement and document standardized processes and procedures to identify employees throughout the District who are required to keep time and effort or personnel activity reports during the year. We also recommend general training be completed for all staff regarding this requirement. Views of Responsible Officials and Planned Corrective Action: The District will consider implementation of more standardized requirements associated with time and effort and personnel activity reporting requirements. The District will also consider additional training associated with these requirements for all grant related staff.

Condition: The District did not have procedures in place to review the reporting required by the grant for accuracy nor for verification of completion of the reporting requirements in a timely manner. Errors were noted in the June 30, 2022 institutional portion report identified as being the final report with all amounts expended at year-end while there was approximately $82,000 remaining to be spent. In addition, it was noted that one of two quarterly reports sampled were uploaded late by three days. Criteria: The U.S. Department of Education requires institutions that received Higher Education Emergency Relief Funds (HEERF) to publicly post certain information accurately on their website related to the student aid and institutional portions of the funds within 10 days of the end of each quarter. 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Effect: By not having a review process in place to verify the reports were accurate and uploaded timely, the reports were not available to the public within the allowed time after quarter-end. Cause: The District had limited employees involved in the disbursement of the HEERF funds resulting in only one person being able to prepare and review the reports. It is unclear why the quarter reviewed was uploaded late. Recommendation: We recommend implementing a process for a secondary review of the reports being prepared as well as a process for verifying reports are uploaded to the website accurately and timely. Views of Responsible Officials and Planned Corrective Action: The District will implement new procedures to verify reports are accurate and uploaded timely in the future.

Condition: The District did not have procedures in place to review the reporting required by the grant for accuracy nor for verification of completion of the reporting requirements in a timely manner. Errors were noted in the June 30, 2022 institutional portion report identified as being the final report with all amounts expended at year-end while there was approximately $82,000 remaining to be spent. In addition, it was noted that one of two quarterly reports sampled were uploaded late by three days. Criteria: The U.S. Department of Education requires institutions that received Higher Education Emergency Relief Funds (HEERF) to publicly post certain information accurately on their website related to the student aid and institutional portions of the funds within 10 days of the end of each quarter. 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Effect: By not having a review process in place to verify the reports were accurate and uploaded timely, the reports were not available to the public within the allowed time after quarter-end. Cause: The District had limited employees involved in the disbursement of the HEERF funds resulting in only one person being able to prepare and review the reports. It is unclear why the quarter reviewed was uploaded late. Recommendation: We recommend implementing a process for a secondary review of the reports being prepared as well as a process for verifying reports are uploaded to the website accurately and timely. Views of Responsible Officials and Planned Corrective Action: The District will implement new procedures to verify reports are accurate and uploaded timely in the future.

Condition: While testing controls, a group of employees were identified that the District missed when completing their triannual procedures related to obtaining time and effort or personnel activity reports from employees paid from grants. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Effect: In this instance, the District performed time and effort and personnel activity reports as a control procedure not specifically required by the grant, due to the type of payroll. This could have been a much more significant issue if it had been associated with certain other grants. Cause: The grant administrator indicated the employees were likely missed due to timing of posting payroll to the project and the reclassification of costs between projects during the year due to changes from the state level associated with accounting for the Education Stabilization Funds. Recommendation: The District should implement and document standardized processes and procedures to identify employees throughout the District who are required to keep time and effort or personnel activity reports during the year. We also recommend general training be completed for all staff regarding this requirement. Views of Responsible Officials and Planned Corrective Action: The District will consider implementation of more standardized requirements associated with time and effort and personnel activity reporting requirements. The District will also consider additional training associated with these requirements for all grant related staff.