2022 ? 003 ? COD Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.268 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing of COD disbursements, CLA noted that 1 out of the 40 selections had a 'COD Applied Date' that was not within 15 days of the 'COD Disbursement Date' Questioned costs: None Context: There was a lack of internal control processes in place for correct reporting to COD. Cause: The College does not have a process in place to accurate report Pell disbursements to COD within the required 15 days. Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting Pell disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 003 ? COD Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.268 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing of COD disbursements, CLA noted that 1 out of the 40 selections had a 'COD Applied Date' that was not within 15 days of the 'COD Disbursement Date' Questioned costs: None Context: There was a lack of internal control processes in place for correct reporting to COD. Cause: The College does not have a process in place to accurate report Pell disbursements to COD within the required 15 days. Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting Pell disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 003 ? COD Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.268 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing of COD disbursements, CLA noted that 1 out of the 40 selections had a 'COD Applied Date' that was not within 15 days of the 'COD Disbursement Date' Questioned costs: None Context: There was a lack of internal control processes in place for correct reporting to COD. Cause: The College does not have a process in place to accurate report Pell disbursements to COD within the required 15 days. Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting Pell disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 003 ? COD Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.268 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing of COD disbursements, CLA noted that 1 out of the 40 selections had a 'COD Applied Date' that was not within 15 days of the 'COD Disbursement Date' Questioned costs: None Context: There was a lack of internal control processes in place for correct reporting to COD. Cause: The College does not have a process in place to accurate report Pell disbursements to COD within the required 15 days. Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting Pell disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 003 ? COD Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.268 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing of COD disbursements, CLA noted that 1 out of the 40 selections had a 'COD Applied Date' that was not within 15 days of the 'COD Disbursement Date' Questioned costs: None Context: There was a lack of internal control processes in place for correct reporting to COD. Cause: The College does not have a process in place to accurate report Pell disbursements to COD within the required 15 days. Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting Pell disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 003 ? COD Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.268 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing of COD disbursements, CLA noted that 1 out of the 40 selections had a 'COD Applied Date' that was not within 15 days of the 'COD Disbursement Date' Questioned costs: None Context: There was a lack of internal control processes in place for correct reporting to COD. Cause: The College does not have a process in place to accurate report Pell disbursements to COD within the required 15 days. Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting Pell disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 004 ? Higher Education Emergency Relief Funds (HEERF) Reporting Federal Agency: Department of Education Federal Program Title: Higher Education Emergency Relief Funds ALN Numbers: 84.425E, 84.425F Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Code of Federal Regulations (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. Condition: During our testing of reporting, we noted the College did not revise its reporting of the HEERF expenditures that were originally reported in fiscal year 2020 and subsequently corrected on the financial statements of the College. We noted the required quarterly student-portion reporting was not uploaded to the College?s website in fiscal year 2022. We noted the required quarterly institutional-portion reporting for quarter-ending 12/31/21 and 3/31/22 were not uploaded to the College?s website in fiscal year 2022. Lastly, we noted several discrepancies in the numbers reported in the annual report submitted for 2021. There was also no documentation of review of this report. Questioned costs: None Context: There was a lack of internal control processes in place for submission of the necessary required reporting. Cause: The College did not have an internal control structure that included correcting errors in reporting or timely submission of reporting. Effect: Mistakes and/or errors could result if internal control procedures are not properly in place and implemented. Repeat Finding: Yes, 2021-002 Recommendation: We recommend that the College review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 006 ? Higher Education Emergency Relief Fund (HEERF) ? Cash Management Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Fund ALN: 84.425E, 84.425F, 84.425M Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Certification and Agreements and/or Supplemental Agreements for CRRSAA HEERF II and ARP HEERF III require that Student Aid Portion (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from the Department of Education?s G5 grants system and Institutional Aid Portion, (a)(2), and (a)(3) funds (all other ALNs) should be disbursed within three calendar days of the drawdown from G5. Condition: During our testing, we noted 15 student grant payments out of 17 tested which were disbursed outside of the 15-calendar day window. In addition, three institutional expenses out of four tested were disbursed outside of the three-calendar day window. Questioned costs: None Context: The College drew down funds from the Department of Education?s G5 grants system and did not disburse the funds within the necessary timeframe. Cause: The College did not have an internal control structure in place that included reconciling the timing of its expenditures and its G5 drawdowns. Effect: The College is out of compliance with this requirement. Repeat finding: No Recommendation: We recommend that the College review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 004 ? Higher Education Emergency Relief Funds (HEERF) Reporting Federal Agency: Department of Education Federal Program Title: Higher Education Emergency Relief Funds ALN Numbers: 84.425E, 84.425F Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Code of Federal Regulations (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. Condition: During our testing of reporting, we noted the College did not revise its reporting of the HEERF expenditures that were originally reported in fiscal year 2020 and subsequently corrected on the financial statements of the College. We noted the required quarterly student-portion reporting was not uploaded to the College?s website in fiscal year 2022. We noted the required quarterly institutional-portion reporting for quarter-ending 12/31/21 and 3/31/22 were not uploaded to the College?s website in fiscal year 2022. Lastly, we noted several discrepancies in the numbers reported in the annual report submitted for 2021. There was also no documentation of review of this report. Questioned costs: None Context: There was a lack of internal control processes in place for submission of the necessary required reporting. Cause: The College did not have an internal control structure that included correcting errors in reporting or timely submission of reporting. Effect: Mistakes and/or errors could result if internal control procedures are not properly in place and implemented. Repeat Finding: Yes, 2021-002 Recommendation: We recommend that the College review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 005 ? Higher Education Emergency Relief Fund (HEERF) ? Procurement, Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Fund ALN: 84.425F, 84.425M Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations requires Colleges to have a written procurement policy that includes certain requirements as it relates to procuring good and services using federal dollars. Additionally, 2 CFR 180.995 requires that the College has a written policy where Colleges should perform a check to ensure vendors are not debarred. Condition: During our testing, it was noted that the College did not have a procurement policy that contained certain required elements. Also, it was noted during testing that there is no written policy that requires the College to verify that vendors are suspended or debarred. Questioned costs: None Context: The College did have appropriate documentation that met the procurement, and suspension and debarment federal requirements. However, the written policies were not in place at time of procurement or entering into contracts with vendors. Cause: The College was unaware of this federal requirement since it is their first federal grant that was non-student financial aid. Effect: All requirements were met, but it is also required that the policies be documented in a written form. Without written policies it is likely that required steps in the process may be missed. Repeat finding: Yes, 2021-003 Recommendation: We recommend that the College review their Procurement and Suspension and debarment policies and ensure that any missing federal requirements are included in their written policies. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 006 ? Higher Education Emergency Relief Fund (HEERF) ? Cash Management Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Fund ALN: 84.425E, 84.425F, 84.425M Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Certification and Agreements and/or Supplemental Agreements for CRRSAA HEERF II and ARP HEERF III require that Student Aid Portion (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from the Department of Education?s G5 grants system and Institutional Aid Portion, (a)(2), and (a)(3) funds (all other ALNs) should be disbursed within three calendar days of the drawdown from G5. Condition: During our testing, we noted 15 student grant payments out of 17 tested which were disbursed outside of the 15-calendar day window. In addition, three institutional expenses out of four tested were disbursed outside of the three-calendar day window. Questioned costs: None Context: The College drew down funds from the Department of Education?s G5 grants system and did not disburse the funds within the necessary timeframe. Cause: The College did not have an internal control structure in place that included reconciling the timing of its expenditures and its G5 drawdowns. Effect: The College is out of compliance with this requirement. Repeat finding: No Recommendation: We recommend that the College review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 005 ? Higher Education Emergency Relief Fund (HEERF) ? Procurement, Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Fund ALN: 84.425F, 84.425M Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations requires Colleges to have a written procurement policy that includes certain requirements as it relates to procuring good and services using federal dollars. Additionally, 2 CFR 180.995 requires that the College has a written policy where Colleges should perform a check to ensure vendors are not debarred. Condition: During our testing, it was noted that the College did not have a procurement policy that contained certain required elements. Also, it was noted during testing that there is no written policy that requires the College to verify that vendors are suspended or debarred. Questioned costs: None Context: The College did have appropriate documentation that met the procurement, and suspension and debarment federal requirements. However, the written policies were not in place at time of procurement or entering into contracts with vendors. Cause: The College was unaware of this federal requirement since it is their first federal grant that was non-student financial aid. Effect: All requirements were met, but it is also required that the policies be documented in a written form. Without written policies it is likely that required steps in the process may be missed. Repeat finding: Yes, 2021-003 Recommendation: We recommend that the College review their Procurement and Suspension and debarment policies and ensure that any missing federal requirements are included in their written policies. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 006 ? Higher Education Emergency Relief Fund (HEERF) ? Cash Management Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Fund ALN: 84.425E, 84.425F, 84.425M Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Certification and Agreements and/or Supplemental Agreements for CRRSAA HEERF II and ARP HEERF III require that Student Aid Portion (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from the Department of Education?s G5 grants system and Institutional Aid Portion, (a)(2), and (a)(3) funds (all other ALNs) should be disbursed within three calendar days of the drawdown from G5. Condition: During our testing, we noted 15 student grant payments out of 17 tested which were disbursed outside of the 15-calendar day window. In addition, three institutional expenses out of four tested were disbursed outside of the three-calendar day window. Questioned costs: None Context: The College drew down funds from the Department of Education?s G5 grants system and did not disburse the funds within the necessary timeframe. Cause: The College did not have an internal control structure in place that included reconciling the timing of its expenditures and its G5 drawdowns. Effect: The College is out of compliance with this requirement. Repeat finding: No Recommendation: We recommend that the College review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 003 ? COD Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.268 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing of COD disbursements, CLA noted that 1 out of the 40 selections had a 'COD Applied Date' that was not within 15 days of the 'COD Disbursement Date' Questioned costs: None Context: There was a lack of internal control processes in place for correct reporting to COD. Cause: The College does not have a process in place to accurate report Pell disbursements to COD within the required 15 days. Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting Pell disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 003 ? COD Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.268 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing of COD disbursements, CLA noted that 1 out of the 40 selections had a 'COD Applied Date' that was not within 15 days of the 'COD Disbursement Date' Questioned costs: None Context: There was a lack of internal control processes in place for correct reporting to COD. Cause: The College does not have a process in place to accurate report Pell disbursements to COD within the required 15 days. Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting Pell disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 003 ? COD Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.268 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing of COD disbursements, CLA noted that 1 out of the 40 selections had a 'COD Applied Date' that was not within 15 days of the 'COD Disbursement Date' Questioned costs: None Context: There was a lack of internal control processes in place for correct reporting to COD. Cause: The College does not have a process in place to accurate report Pell disbursements to COD within the required 15 days. Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting Pell disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 003 ? COD Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.268 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing of COD disbursements, CLA noted that 1 out of the 40 selections had a 'COD Applied Date' that was not within 15 days of the 'COD Disbursement Date' Questioned costs: None Context: There was a lack of internal control processes in place for correct reporting to COD. Cause: The College does not have a process in place to accurate report Pell disbursements to COD within the required 15 days. Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting Pell disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 003 ? COD Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.268 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing of COD disbursements, CLA noted that 1 out of the 40 selections had a 'COD Applied Date' that was not within 15 days of the 'COD Disbursement Date' Questioned costs: None Context: There was a lack of internal control processes in place for correct reporting to COD. Cause: The College does not have a process in place to accurate report Pell disbursements to COD within the required 15 days. Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting Pell disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 003 ? COD Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.268 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing of COD disbursements, CLA noted that 1 out of the 40 selections had a 'COD Applied Date' that was not within 15 days of the 'COD Disbursement Date' Questioned costs: None Context: There was a lack of internal control processes in place for correct reporting to COD. Cause: The College does not have a process in place to accurate report Pell disbursements to COD within the required 15 days. Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting Pell disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 004 ? Higher Education Emergency Relief Funds (HEERF) Reporting Federal Agency: Department of Education Federal Program Title: Higher Education Emergency Relief Funds ALN Numbers: 84.425E, 84.425F Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Code of Federal Regulations (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. Condition: During our testing of reporting, we noted the College did not revise its reporting of the HEERF expenditures that were originally reported in fiscal year 2020 and subsequently corrected on the financial statements of the College. We noted the required quarterly student-portion reporting was not uploaded to the College?s website in fiscal year 2022. We noted the required quarterly institutional-portion reporting for quarter-ending 12/31/21 and 3/31/22 were not uploaded to the College?s website in fiscal year 2022. Lastly, we noted several discrepancies in the numbers reported in the annual report submitted for 2021. There was also no documentation of review of this report. Questioned costs: None Context: There was a lack of internal control processes in place for submission of the necessary required reporting. Cause: The College did not have an internal control structure that included correcting errors in reporting or timely submission of reporting. Effect: Mistakes and/or errors could result if internal control procedures are not properly in place and implemented. Repeat Finding: Yes, 2021-002 Recommendation: We recommend that the College review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 006 ? Higher Education Emergency Relief Fund (HEERF) ? Cash Management Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Fund ALN: 84.425E, 84.425F, 84.425M Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Certification and Agreements and/or Supplemental Agreements for CRRSAA HEERF II and ARP HEERF III require that Student Aid Portion (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from the Department of Education?s G5 grants system and Institutional Aid Portion, (a)(2), and (a)(3) funds (all other ALNs) should be disbursed within three calendar days of the drawdown from G5. Condition: During our testing, we noted 15 student grant payments out of 17 tested which were disbursed outside of the 15-calendar day window. In addition, three institutional expenses out of four tested were disbursed outside of the three-calendar day window. Questioned costs: None Context: The College drew down funds from the Department of Education?s G5 grants system and did not disburse the funds within the necessary timeframe. Cause: The College did not have an internal control structure in place that included reconciling the timing of its expenditures and its G5 drawdowns. Effect: The College is out of compliance with this requirement. Repeat finding: No Recommendation: We recommend that the College review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 004 ? Higher Education Emergency Relief Funds (HEERF) Reporting Federal Agency: Department of Education Federal Program Title: Higher Education Emergency Relief Funds ALN Numbers: 84.425E, 84.425F Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Code of Federal Regulations (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. Condition: During our testing of reporting, we noted the College did not revise its reporting of the HEERF expenditures that were originally reported in fiscal year 2020 and subsequently corrected on the financial statements of the College. We noted the required quarterly student-portion reporting was not uploaded to the College?s website in fiscal year 2022. We noted the required quarterly institutional-portion reporting for quarter-ending 12/31/21 and 3/31/22 were not uploaded to the College?s website in fiscal year 2022. Lastly, we noted several discrepancies in the numbers reported in the annual report submitted for 2021. There was also no documentation of review of this report. Questioned costs: None Context: There was a lack of internal control processes in place for submission of the necessary required reporting. Cause: The College did not have an internal control structure that included correcting errors in reporting or timely submission of reporting. Effect: Mistakes and/or errors could result if internal control procedures are not properly in place and implemented. Repeat Finding: Yes, 2021-002 Recommendation: We recommend that the College review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 005 ? Higher Education Emergency Relief Fund (HEERF) ? Procurement, Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Fund ALN: 84.425F, 84.425M Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations requires Colleges to have a written procurement policy that includes certain requirements as it relates to procuring good and services using federal dollars. Additionally, 2 CFR 180.995 requires that the College has a written policy where Colleges should perform a check to ensure vendors are not debarred. Condition: During our testing, it was noted that the College did not have a procurement policy that contained certain required elements. Also, it was noted during testing that there is no written policy that requires the College to verify that vendors are suspended or debarred. Questioned costs: None Context: The College did have appropriate documentation that met the procurement, and suspension and debarment federal requirements. However, the written policies were not in place at time of procurement or entering into contracts with vendors. Cause: The College was unaware of this federal requirement since it is their first federal grant that was non-student financial aid. Effect: All requirements were met, but it is also required that the policies be documented in a written form. Without written policies it is likely that required steps in the process may be missed. Repeat finding: Yes, 2021-003 Recommendation: We recommend that the College review their Procurement and Suspension and debarment policies and ensure that any missing federal requirements are included in their written policies. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 006 ? Higher Education Emergency Relief Fund (HEERF) ? Cash Management Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Fund ALN: 84.425E, 84.425F, 84.425M Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Certification and Agreements and/or Supplemental Agreements for CRRSAA HEERF II and ARP HEERF III require that Student Aid Portion (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from the Department of Education?s G5 grants system and Institutional Aid Portion, (a)(2), and (a)(3) funds (all other ALNs) should be disbursed within three calendar days of the drawdown from G5. Condition: During our testing, we noted 15 student grant payments out of 17 tested which were disbursed outside of the 15-calendar day window. In addition, three institutional expenses out of four tested were disbursed outside of the three-calendar day window. Questioned costs: None Context: The College drew down funds from the Department of Education?s G5 grants system and did not disburse the funds within the necessary timeframe. Cause: The College did not have an internal control structure in place that included reconciling the timing of its expenditures and its G5 drawdowns. Effect: The College is out of compliance with this requirement. Repeat finding: No Recommendation: We recommend that the College review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 005 ? Higher Education Emergency Relief Fund (HEERF) ? Procurement, Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Fund ALN: 84.425F, 84.425M Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations requires Colleges to have a written procurement policy that includes certain requirements as it relates to procuring good and services using federal dollars. Additionally, 2 CFR 180.995 requires that the College has a written policy where Colleges should perform a check to ensure vendors are not debarred. Condition: During our testing, it was noted that the College did not have a procurement policy that contained certain required elements. Also, it was noted during testing that there is no written policy that requires the College to verify that vendors are suspended or debarred. Questioned costs: None Context: The College did have appropriate documentation that met the procurement, and suspension and debarment federal requirements. However, the written policies were not in place at time of procurement or entering into contracts with vendors. Cause: The College was unaware of this federal requirement since it is their first federal grant that was non-student financial aid. Effect: All requirements were met, but it is also required that the policies be documented in a written form. Without written policies it is likely that required steps in the process may be missed. Repeat finding: Yes, 2021-003 Recommendation: We recommend that the College review their Procurement and Suspension and debarment policies and ensure that any missing federal requirements are included in their written policies. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 006 ? Higher Education Emergency Relief Fund (HEERF) ? Cash Management Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Fund ALN: 84.425E, 84.425F, 84.425M Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Certification and Agreements and/or Supplemental Agreements for CRRSAA HEERF II and ARP HEERF III require that Student Aid Portion (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from the Department of Education?s G5 grants system and Institutional Aid Portion, (a)(2), and (a)(3) funds (all other ALNs) should be disbursed within three calendar days of the drawdown from G5. Condition: During our testing, we noted 15 student grant payments out of 17 tested which were disbursed outside of the 15-calendar day window. In addition, three institutional expenses out of four tested were disbursed outside of the three-calendar day window. Questioned costs: None Context: The College drew down funds from the Department of Education?s G5 grants system and did not disburse the funds within the necessary timeframe. Cause: The College did not have an internal control structure in place that included reconciling the timing of its expenditures and its G5 drawdowns. Effect: The College is out of compliance with this requirement. Repeat finding: No Recommendation: We recommend that the College review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of responsible officials: There is no disagreement with the audit finding.