Audit 44238

FY End
2022-06-30
Total Expended
$9.92M
Findings
2
Programs
24
Organization: Pomona College (CA)
Year: 2022 Accepted: 2023-03-29
Auditor: Kpmg LLP

Organization Exclusion Status:

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Findings

ID Ref Severity Repeat Requirement
44821 2022-001 Significant Deficiency - AB
621263 2022-001 Significant Deficiency - AB

Contacts

Name Title Type
Q9VBQSV2CBY5 Vickie Roberts Auditee
9096218276 Spencer Endicott Auditor
No contacts on file

Notes to SEFA

Title: Loan/loan guarantee outstanding balances Accounting Policies: General and Basis of Presentation: The accompanying schedule of expenditures of federal awards (the Schedule) presents the activity of all federal award programs of Pomona College (the College). Because the Schedule presents only a selected portion of the operations of the College, it is not intended to, and does not, present the financial position, changes in net assets, or cash flows for the College.For purposes of the Schedule, federal awards include all grants and contracts entered into directly between the College and agencies and departments of the federal government and pass-through agencies. The awards are classified into major program categories in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), for Audits of States, Local Governments, and Non-Profit Organizations. The information in the Schedule is prepared based on the accrual basis of accounting and is also presented in accordance with the requirements of the Uniform Guidance. Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the financial statements. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The College has elected not to use the 10-percent de minimis direct cost rate allowed under the Uniform Guidance. Facilities and administrative costs allocated to awards for the year ended June 30, 2022, were based on predetermined fixed rates up to 62% negotiated with the Colleges cognizant federal agency, the National Science Foundation, and are included as a component of the expenditures in the Schedule. FEDERAL PERKINS LOAN PROGRAM (84.038) - Balances outstanding at the end of the audit period were 851022.
Title: Relationship to Federal Financial Reports Accounting Policies: General and Basis of Presentation: The accompanying schedule of expenditures of federal awards (the Schedule) presents the activity of all federal award programs of Pomona College (the College). Because the Schedule presents only a selected portion of the operations of the College, it is not intended to, and does not, present the financial position, changes in net assets, or cash flows for the College.For purposes of the Schedule, federal awards include all grants and contracts entered into directly between the College and agencies and departments of the federal government and pass-through agencies. The awards are classified into major program categories in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), for Audits of States, Local Governments, and Non-Profit Organizations. The information in the Schedule is prepared based on the accrual basis of accounting and is also presented in accordance with the requirements of the Uniform Guidance. Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the financial statements. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The College has elected not to use the 10-percent de minimis direct cost rate allowed under the Uniform Guidance. Facilities and administrative costs allocated to awards for the year ended June 30, 2022, were based on predetermined fixed rates up to 62% negotiated with the Colleges cognizant federal agency, the National Science Foundation, and are included as a component of the expenditures in the Schedule. Amounts reported in the Schedule agree in all material respects with the amounts reported in the related federal financial reports.

Finding Details

Federal Program: Research and Development Cluster Federal Assistance Listing Number: Various Federal Agency: Various Award Year: Various Criteria: The OMB Compliance Supplement notes the excerpt below as one of the Allowable Cost criteria: c. Costs did not consist of improper payments, including (1) payments that should not have been made or that were made in incorrect amounts (including overpayments and underpayments) under statutory, contractual, administrative, or other legally applicable requirements; (2) payments that do not account for credit for applicable discounts; (3) duplicate payments; (4) payments that were made to an ineligible party or for an ineligible good or service; and (5) payments for goods or services not received (except for such payments where authorized by law). Condition and Context: During of testwork of 76 expenditures during the current year, we identified four expenditures that were not an allowable expenditure to the federal grant. Management charged nonpayroll expenses that had not been incurred as of year-end to a federal grant. Stipends for an 8-week summer program relating to Grant 6117 (Pomona Research in Mathematics Experience), ALN: 47.049, that ran from June 9, 2022 to August 6, 2022 were partially incurred by year-end (June 30, 2022), but charged entirely to the grant in FY22. Per the contract with the hired Research Assistants, stipends were to be made in two installments, whereby the second installment relates to the portion of the expenditure incurred after year-end. The second installment was charged to the grant in FY22, before the Research Assistants completed their grant-related work. This questioned cost represents the entire amount of the stipends paid in FY22 that relate to grant-related work performed after June 30, 2022. Isolated or Systemic: Isolated. Cause and Effect: The College?s control failed in detecting timely that unallowable costs were charged to the Research and Development Cluster. Questioned Costs: $16,588. Whether the sampling was a statistically valid sample: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No. Recommendation: We recommend that the College enhance its internal controls to ensure all expenditures charged to the Research and Development Cluster are for allowable costs. View of Responsible Officials: Finance staff are working with the Director of Sponsored Research to better align stipend payment schedules with our fiscal year-end. Appropriate schedules for the variety of grant-funded summer research will be communicated to the Primary Investigators and academic department staff. Accounts Payable staff will be instructed to reject any participant payment requests that are not in accordance with the approved schedules. Additionally, reviews of each grant payment will be performed at the time of the payment request and in July, as part of our year-end close process, to identify any grant expenses that may have been charged to the incorrect fiscal year and reclassify them accordingly.
Federal Program: Research and Development Cluster Federal Assistance Listing Number: Various Federal Agency: Various Award Year: Various Criteria: The OMB Compliance Supplement notes the excerpt below as one of the Allowable Cost criteria: c. Costs did not consist of improper payments, including (1) payments that should not have been made or that were made in incorrect amounts (including overpayments and underpayments) under statutory, contractual, administrative, or other legally applicable requirements; (2) payments that do not account for credit for applicable discounts; (3) duplicate payments; (4) payments that were made to an ineligible party or for an ineligible good or service; and (5) payments for goods or services not received (except for such payments where authorized by law). Condition and Context: During of testwork of 76 expenditures during the current year, we identified four expenditures that were not an allowable expenditure to the federal grant. Management charged nonpayroll expenses that had not been incurred as of year-end to a federal grant. Stipends for an 8-week summer program relating to Grant 6117 (Pomona Research in Mathematics Experience), ALN: 47.049, that ran from June 9, 2022 to August 6, 2022 were partially incurred by year-end (June 30, 2022), but charged entirely to the grant in FY22. Per the contract with the hired Research Assistants, stipends were to be made in two installments, whereby the second installment relates to the portion of the expenditure incurred after year-end. The second installment was charged to the grant in FY22, before the Research Assistants completed their grant-related work. This questioned cost represents the entire amount of the stipends paid in FY22 that relate to grant-related work performed after June 30, 2022. Isolated or Systemic: Isolated. Cause and Effect: The College?s control failed in detecting timely that unallowable costs were charged to the Research and Development Cluster. Questioned Costs: $16,588. Whether the sampling was a statistically valid sample: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No. Recommendation: We recommend that the College enhance its internal controls to ensure all expenditures charged to the Research and Development Cluster are for allowable costs. View of Responsible Officials: Finance staff are working with the Director of Sponsored Research to better align stipend payment schedules with our fiscal year-end. Appropriate schedules for the variety of grant-funded summer research will be communicated to the Primary Investigators and academic department staff. Accounts Payable staff will be instructed to reject any participant payment requests that are not in accordance with the approved schedules. Additionally, reviews of each grant payment will be performed at the time of the payment request and in July, as part of our year-end close process, to identify any grant expenses that may have been charged to the incorrect fiscal year and reclassify them accordingly.