Finding 2022-002: Information on the Federal Program: 84.425F ? Higher Education Emergency Relief Fund ? institutional Portion Compliance Requirement: Reporting Type of Finding: Significant Deficiency Criteria: The objective of the Higher Education Emergency Relief Fund (HEERF) program is to use HEERF grant funds to ?prevent, prepare for, and respond to coronavirus? through grants to eligible institutions. 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) programs, as applicable; and (3) the annual report. Beginning on May 6, 2020, U.S. Department of Education (ED) required institutions that received a HEERF 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after award, and update that information every 45 days thereafter (by posting a new report). This was announced through an electronic announcement (EA). On August 31, 2020, ED revised the EA by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020, should instead post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. Sections 18004(a)(1) Institutional Portion, (a)(2), and (a)(3) Quarterly Public Reporting must be conspicuously posted on the institution?s primary website on the same page the reports of the Institution of Higher Education (IHE)?s activities as to the emergency financial aid grants to students made with funds from the IHE?s allocation under Section 18004(a)(1) of the CARES Act (Student Aid Portion) are posted. A new, separate form must be posted covering each quarterly reporting period (September 30, December 31, March 31, June 30), concluding after either (1) posting the quarterly report ending September 30, 2022, or (2) when an institution has expended and liquidated all (a)(1) Institutional Portion, (a)(2), and (a)(3) funds and checks the ?final report? box. IHEs must post this quarterly report form no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, July 10) apart from the first report, which is due October 30, 2020. In addition, reporting requirements to ED state that the institutional portion of HEERF is reported by Quarter and should not be cumulative. Condition: Jacksonville College did not post the quarterly report for Quarter 1 ending on March 31, 2022 for the institutional portions that were expended. The institutional quarterly reports for the quarters ending June 30, 2022, September 30, 2022, and December 31, 2022 contained amounts that were inconsistent with the amount of funds expended. Context: Management's review control over its reporting requirements for HEERF was not operating at a level of precision to ensure accurate reporting. As such, certain data reported on HEERF was not accurate or timely. Questioned Costs: $0 Cause: The College did not properly review the reporting requirements or grant expenditures in a timely manner. 37 Effect or Potential Effect: Jacksonville College did not report correct amounts to the Department of Education. Repeat Finding: Not a repeat finding. Recommendation: The College should develop written procedures for posting the quarterly reports to the College webpage in a timely manner. In addition, the College should implement procedures to periodically review expenditures for grant requirements and reconciling the grant expenditures to the quarterly reports. Views of Responsible Official: The College has taken the necessary steps to get these reports corrected and filed. See the details attached within the Corrective Action Plan at the end of this report.
Finding 2022-003: Information on the Federal Program: 84.425F ? Higher Education Emergency Relief Fund ? institutional Portion, 84.425E ? Higher Education Emergency Relief Fund ? Student Portion Compliance Requirement: Cash Management Type of Finding: Material Weakness Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statutes, regulations, and the terms and conditions of the award. Additionally, under HEERF award, grantees are under an obligation to minimize the time between drawing down funds from G5 and paying obligations incurred by the grantee (liquidation). If a HEERF grantee is using HEERF grant funds to make financial aid grants to students, the Department may evaluate for compliance with the rule grantees who have not drawn down the funds from G5 and not paid the obligations (the financial aid grants to students) to the students within fifteen calendar days. The Supplemental Agreement published by the U.S. Department of Education pertaining to Supplemental Grant Funds identifies that funds not disbursed within 3 days of being drawn down may be subject to heightened scrutiny by the U.S. Department of Education, the institution?s auditors, and/or the Department?s Office of the Inspector General. Internal controls over compliance with direct and material compliance requirements should be sufficient to prevent or detect and correct material noncompliance in a timely manner. Condition: During testing of cash management compliance requirements, it was noted that Jacksonville College had drawn down the entirety of the HEERF awards in 2021 and recorded $1,302,078 in grant revenues. A portion of the funds drawn in 2021 were used to pay off a loan with SBTC. In 2022, the College had expended the majority of the funds but continues to report a deferred liability of $42,887 related to prematurely drawn-down HEERF funds. Context: Jacksonville College did not review compliance requirements related to drawing down of grant funds and over-drew funds related to the HEERF grant. Questioned Costs: $42,887 remaining in Deferred Income. Cause: A material weakness in internal control over compliance exists relating to cash management. Personnel responsible for maintaining compliance with cash management did not have sufficient education on the cash management requirements. In addition, there was no review over compliance with cash management requirements to monitor compliance. 38 Effect or Potential Effect: The College was not in compliance with Federal requirements of the COVID-19 Education Stabilization Fund. Repeat Finding: Not a repeat finding. Recommendation: We recommend that the College put into place controls that require review of grant requirements prior to drawing down funds. Views of Responsible Official: The College?s current Administration, put in place during the end of 2021, is committed to improving processes by identifying and amending them in the future to improve internal controls of the College. This includes formulation of policies and procedures based on best practices of the industry. We have taken the necessary steps to ensure that this is corrected moving forward and more detail can be found in the Corrective Action Plan at the end of this report.
Finding 2022-002: Information on the Federal Program: 84.425F ? Higher Education Emergency Relief Fund ? institutional Portion Compliance Requirement: Reporting Type of Finding: Significant Deficiency Criteria: The objective of the Higher Education Emergency Relief Fund (HEERF) program is to use HEERF grant funds to ?prevent, prepare for, and respond to coronavirus? through grants to eligible institutions. 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) programs, as applicable; and (3) the annual report. Beginning on May 6, 2020, U.S. Department of Education (ED) required institutions that received a HEERF 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after award, and update that information every 45 days thereafter (by posting a new report). This was announced through an electronic announcement (EA). On August 31, 2020, ED revised the EA by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020, should instead post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. Sections 18004(a)(1) Institutional Portion, (a)(2), and (a)(3) Quarterly Public Reporting must be conspicuously posted on the institution?s primary website on the same page the reports of the Institution of Higher Education (IHE)?s activities as to the emergency financial aid grants to students made with funds from the IHE?s allocation under Section 18004(a)(1) of the CARES Act (Student Aid Portion) are posted. A new, separate form must be posted covering each quarterly reporting period (September 30, December 31, March 31, June 30), concluding after either (1) posting the quarterly report ending September 30, 2022, or (2) when an institution has expended and liquidated all (a)(1) Institutional Portion, (a)(2), and (a)(3) funds and checks the ?final report? box. IHEs must post this quarterly report form no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, July 10) apart from the first report, which is due October 30, 2020. In addition, reporting requirements to ED state that the institutional portion of HEERF is reported by Quarter and should not be cumulative. Condition: Jacksonville College did not post the quarterly report for Quarter 1 ending on March 31, 2022 for the institutional portions that were expended. The institutional quarterly reports for the quarters ending June 30, 2022, September 30, 2022, and December 31, 2022 contained amounts that were inconsistent with the amount of funds expended. Context: Management's review control over its reporting requirements for HEERF was not operating at a level of precision to ensure accurate reporting. As such, certain data reported on HEERF was not accurate or timely. Questioned Costs: $0 Cause: The College did not properly review the reporting requirements or grant expenditures in a timely manner. 37 Effect or Potential Effect: Jacksonville College did not report correct amounts to the Department of Education. Repeat Finding: Not a repeat finding. Recommendation: The College should develop written procedures for posting the quarterly reports to the College webpage in a timely manner. In addition, the College should implement procedures to periodically review expenditures for grant requirements and reconciling the grant expenditures to the quarterly reports. Views of Responsible Official: The College has taken the necessary steps to get these reports corrected and filed. See the details attached within the Corrective Action Plan at the end of this report.
Finding 2022-003: Information on the Federal Program: 84.425F ? Higher Education Emergency Relief Fund ? institutional Portion, 84.425E ? Higher Education Emergency Relief Fund ? Student Portion Compliance Requirement: Cash Management Type of Finding: Material Weakness Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statutes, regulations, and the terms and conditions of the award. Additionally, under HEERF award, grantees are under an obligation to minimize the time between drawing down funds from G5 and paying obligations incurred by the grantee (liquidation). If a HEERF grantee is using HEERF grant funds to make financial aid grants to students, the Department may evaluate for compliance with the rule grantees who have not drawn down the funds from G5 and not paid the obligations (the financial aid grants to students) to the students within fifteen calendar days. The Supplemental Agreement published by the U.S. Department of Education pertaining to Supplemental Grant Funds identifies that funds not disbursed within 3 days of being drawn down may be subject to heightened scrutiny by the U.S. Department of Education, the institution?s auditors, and/or the Department?s Office of the Inspector General. Internal controls over compliance with direct and material compliance requirements should be sufficient to prevent or detect and correct material noncompliance in a timely manner. Condition: During testing of cash management compliance requirements, it was noted that Jacksonville College had drawn down the entirety of the HEERF awards in 2021 and recorded $1,302,078 in grant revenues. A portion of the funds drawn in 2021 were used to pay off a loan with SBTC. In 2022, the College had expended the majority of the funds but continues to report a deferred liability of $42,887 related to prematurely drawn-down HEERF funds. Context: Jacksonville College did not review compliance requirements related to drawing down of grant funds and over-drew funds related to the HEERF grant. Questioned Costs: $42,887 remaining in Deferred Income. Cause: A material weakness in internal control over compliance exists relating to cash management. Personnel responsible for maintaining compliance with cash management did not have sufficient education on the cash management requirements. In addition, there was no review over compliance with cash management requirements to monitor compliance. 38 Effect or Potential Effect: The College was not in compliance with Federal requirements of the COVID-19 Education Stabilization Fund. Repeat Finding: Not a repeat finding. Recommendation: We recommend that the College put into place controls that require review of grant requirements prior to drawing down funds. Views of Responsible Official: The College?s current Administration, put in place during the end of 2021, is committed to improving processes by identifying and amending them in the future to improve internal controls of the College. This includes formulation of policies and procedures based on best practices of the industry. We have taken the necessary steps to ensure that this is corrected moving forward and more detail can be found in the Corrective Action Plan at the end of this report.