2024-011 (2023-005) INADEQUATE POLICIES AND PROCEDURES Federal Agency: U.S. Department of Education Federal Program Title and Assistance Listing Number: Higher Educational Institutional Aid, 84.031 Type of Finding: Significant Deficiency Compliance Area: Other - Inadequate Policies and Procedures Federal Award Year: 2024 Questioned Costs: None Condition The College does not maintain written procedures as required by 2 CFR 200, Subparts D and E of the Uniform Guidance. Criteria Per 2 CFR 200.302(b)(6), Financial Management, the financial management system of each non-federal entity must provide the following: Written procedures to implement the requirements of 200.305 Federal Payment. Per 2 CFR 200.302(b)(7), Financial Management, the financial management system of each nonfederal entity must provide the following: Written procedures for determining the allowability of costs in accordance with Subpart E – Cost Principles of this part and the terms and conditions of the Federal award. Cause The College does not have written procedures for the federal program financial management requirements. Effect Not having written procedures for the aforementioned puts the College in direct violation of Federal requirements over Federal programs under the Uniform Guidance, which could result in a loss of programs, funds and/or repayment of federal monies already awarded back to the Federal government.
2024-012 (2023-006) PAYROLL Federal Agency: U.S. Department of Education Federal Program Title and Assistance Listing Number: Higher Educational Institutional Aid, 84.031 Type of Finding: Significant Deficiency in Internal Controls over Compliance/Material Non-compliance Compliance Area: Activities Allowed or unallowed, Allowable cost/cost principles Federal Award Year: 2024 Questioned Costs: None Condition The College’s supporting documentation did not agree to the amount of employee’s pay charged to grant. Of the 40 payroll disbursement samples tested, 10 samples (25%) lacked time sheets with evidence of supervisory approval or review. Management indicated that the College no longer has access to ADP, the payroll system used during the first half of FY2024, and therefore was unable to provide the required supporting documentation Criteria Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.430(i)(1) – Compensation – personal services, Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Cause The College does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. Effect Lack of approval and inaccurate documentation for costs charged to grants puts the College at risk of charging unallowable costs, which in turn could result in required repayment to grantor agencies.
2024-014- TIMELY FILING OF THE DISCAL REPORT AND APPLICATION TO PARTICIPATE Federal Agency: U.S. Department of Education Federal Program Title and Assistance Listing Number: Student Financial Assistance Cluster of Programs; Federal Pell Grant Program, 84.063, Federal Direct Student Loans 84.268 Type of Finding: Significant Deficiency in Internal Control over Compliance, Non-compliance Compliance Area: Other - Timely Filing of Fiscal Report Federal Award Year: 2024 Questioned Costs: None Condition The College did not submit its Fiscal Operations Report and Application to Participate (FISAP)report by the specified annual deadline of October 1, 2024. Criteria Per 34 C.F.R. § 668.171(e) and annual ED electronic announcements, institutions must submit their FISAP by the specified date to remain eligible for Title IV campus-based funds. Cause The College was not familiar with the required timing for this report. The June 30, 2024 was the first FISAP reported by the College. For the year ended June 30, 2023, the College’s FISAP information was included in New Mexico State University’s FISAP. Effect Potential loss of all campus-based funding (FSEOG and FWS) for the upcoming award year and a requirement to return any funds already drawn down for the current year.
2024-013 (2023-008) PROCUREMENT, ABOVE SIMPLE ACQUISITION THRESHOLD Federal Agency: U.S. Department of Energy Federal Program Title and Assistance Listing Number: Environmental Remediation and Waste Processing and Disposal, 81.104 Type of Finding: Significant Deficiency in Internal Controls over Compliance Compliance Area: Procurement and suspension and debarment Federal Award Year: 2024 Questioned Costs: None Condition During our review of procurement testing, the College acquired a training simulator through a sole source procurement. The College displayed on their website the “vendor’s determination”, not the “College’s determination”. In 2024, the College prepaid $1,577,250 on this procurement. Criteria Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.318(i), non-federal entities must retain documentation sufficient to detail the history of procurement decisions. Cause The College did not provide their own independent sole source determination. Effect The College may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the grantor agency.
2024-015 (2023-013) DATA COLLECTION FORM SUBMISSION (REPEATED AND MODIFIED) Federal Agency: U.S. Department of Education, U.S. Department of Energy Federal Program Title and Assistance Listing Number: Student Financial Assistance Cluster of Programs; Federal Pell Grant Program 84.063, Federal Direct Student Loans 84.268, Higher Education Institutional Aid 84.031, Adult Education - Basic Grants to States, Environmental Remediation and Waste Processing and Disposal 81.104, Type of Finding: Significant Deficiency in Internal Controls over Non-compliance Compliance Area: Reporting Federal Award Year: 2024 Questioned Costs: None Condition The College’s June 30, 2024 Data Collection Form was not submitted to the Federal Audit clearinghouse database timely, and was due by March 31, 2025. Criteria Per 2 CFR 200.512(a)(1), Report Submission, The audit must be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. Cause The College did not file the data collection form as required due to the delay in completing the audit. Effect Not submitting the data collection form denies access to the public and grantor agencies which could lead in loss of funding needed