Finding Number: 2022-002 Program: COVID-19 Higher Education Emergency Relief Fund (HEERF) Federal Agency Name: U.S. Department of Education Federal Award Year: July 1, 2021 ? June 30, 2022 Federal Assistance Listing Number: 84.425F Criteria There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the CRRSAA 314(e) require an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Annual Reporting (all HEERF grantees) ED required an annual report from HEERF grantees in April 2022 that included reporting uses of HEERF I CARES Act funds, HEERF II CRRSAA funds, and HEERF III ARP funds for the 2021 calendar year. Quarterly Public Reporting for (a)(1) Institutional Portion, (a)(2), and (a)(3) funds The CARES, CRRSAA, and ARP institutional quarterly portion reporting requirements involve publicly posting completed forms on the institution?s website. The forms must be conspicuously posted on the institution?s primary website on the same page the reports of the IHE?s activities as to the emergency financial aid grants to students (Student Aid Portion) are posted. IHEs must post this quarterly report form no later than 10 days after the end of each calendar quarter apart from the first report, which was due October 30, 2020, and the report covering the first quarter of 2021, which was due by July 10, 2021. Quarterly Public Reporting for (a)(1) Student Aid Portion ED requires institutions that received Student Aid Portion awards under CARES Act, CRRSAA and ARP to publicly post certain information on their website. Under the requirements to post student aid public reporting for CRRSAA and ARP, there is a requirement to include certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated not later than 10 days after the end of each calendar quarter. Further, in accordance with 2 CFR 200.303(a), non-federal entities 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. Condition During the year ended June 30, 2022, although all required reporting was found to be accurate and provided on a timely basis, in compliance with the reporting requirements, the College had not implemented a control that specifically addresses the accuracy and timeliness of the required reporting under HEERF. Cause The College?s HEERF reporting process did not include a control designed to monitor the timeliness and accuracy of the required reporting. Although identified as a finding in the prior year, the timing of the identification of this issue did not allow for the management of the College to implement a control that was responsive to the finding. Effect If appropriate controls are not designed and operating effectively over the HEERF reporting process, HEERF expenditures reported on the College?s website and to ED may be incomplete, inaccurate, or not posted within the timeframe required. Questioned Costs None noted. Prior Year Finding Yes ? 2021-001 Recommendation We recommend that the College implement a more thorough and detailed process and related internal controls to ensure timely and accurate reporting required under its Federal programs. Management?s Views Subsequent to June 30, 2022, management has reviewed its reporting requirements under its Federal programs and implemented controls to ensure accuracy and timeliness of required reporting. These include reconciliation of reporting to the College?s accounting records and a review of requirements to ensure timeliness. Anticipated Completion Date Completed ? October 31, 2022 Responsible Persons Gillian King, Chief of Staff
Finding Number: 2022-002 Program: COVID-19 Higher Education Emergency Relief Fund (HEERF) Federal Agency Name: U.S. Department of Education Federal Award Year: July 1, 2021 ? June 30, 2022 Federal Assistance Listing Number: 84.425F Criteria There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the CRRSAA 314(e) require an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Annual Reporting (all HEERF grantees) ED required an annual report from HEERF grantees in April 2022 that included reporting uses of HEERF I CARES Act funds, HEERF II CRRSAA funds, and HEERF III ARP funds for the 2021 calendar year. Quarterly Public Reporting for (a)(1) Institutional Portion, (a)(2), and (a)(3) funds The CARES, CRRSAA, and ARP institutional quarterly portion reporting requirements involve publicly posting completed forms on the institution?s website. The forms must be conspicuously posted on the institution?s primary website on the same page the reports of the IHE?s activities as to the emergency financial aid grants to students (Student Aid Portion) are posted. IHEs must post this quarterly report form no later than 10 days after the end of each calendar quarter apart from the first report, which was due October 30, 2020, and the report covering the first quarter of 2021, which was due by July 10, 2021. Quarterly Public Reporting for (a)(1) Student Aid Portion ED requires institutions that received Student Aid Portion awards under CARES Act, CRRSAA and ARP to publicly post certain information on their website. Under the requirements to post student aid public reporting for CRRSAA and ARP, there is a requirement to include certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated not later than 10 days after the end of each calendar quarter. Further, in accordance with 2 CFR 200.303(a), non-federal entities 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. Condition During the year ended June 30, 2022, although all required reporting was found to be accurate and provided on a timely basis, in compliance with the reporting requirements, the College had not implemented a control that specifically addresses the accuracy and timeliness of the required reporting under HEERF. Cause The College?s HEERF reporting process did not include a control designed to monitor the timeliness and accuracy of the required reporting. Although identified as a finding in the prior year, the timing of the identification of this issue did not allow for the management of the College to implement a control that was responsive to the finding. Effect If appropriate controls are not designed and operating effectively over the HEERF reporting process, HEERF expenditures reported on the College?s website and to ED may be incomplete, inaccurate, or not posted within the timeframe required. Questioned Costs None noted. Prior Year Finding Yes ? 2021-001 Recommendation We recommend that the College implement a more thorough and detailed process and related internal controls to ensure timely and accurate reporting required under its Federal programs. Management?s Views Subsequent to June 30, 2022, management has reviewed its reporting requirements under its Federal programs and implemented controls to ensure accuracy and timeliness of required reporting. These include reconciliation of reporting to the College?s accounting records and a review of requirements to ensure timeliness. Anticipated Completion Date Completed ? October 31, 2022 Responsible Persons Gillian King, Chief of Staff