Item 2022-001 ? Suspension and Debarment Education Stabilization Fund: Higher Education Emergency Relief Fund (HEERF) ? ALN # 84.425E, 84.425F, & 84.425M U.S. Department of Education Federal Award #P425E201496, P425F202110, P425M200661 Federal Award Year - 2020 Criteria ? 2 CFR 200.303 requires the non-Federal entity to ?(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.? Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All nonprocurement transactions entered into by a recipient (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Condition ? Adequate controls were not in place to provide for proper review of covered transactions for suspension and debarment. Covered transactions, over $25,000 paid with grant funding were not reviewed for suspension and debarment. Cause ? The College lacked sufficient controls to ensure evidence of compliance with suspension and debarment. Questioned Costs ? Not determinable Effect ? Failure to properly verify that a potential vendor has not been suspended or debarred could result in unallowable expenditures and disallowed costs. Recommendation ? We recommend that controls should be put into place to better monitor and document the compliance of vendors for suspension and debarment. Management?s Response ? The College will implement additional controls to ensure there is evidence of review of covered transactions over $25,000 for suspension and debarment prior to payment. Dean of Administrative Services will be responsible for the corrective action and anticipates completion of corrective action will be taken before September 30, 2023.
Item 2022-001 ? Suspension and Debarment Education Stabilization Fund: Higher Education Emergency Relief Fund (HEERF) ? ALN # 84.425E, 84.425F, & 84.425M U.S. Department of Education Federal Award #P425E201496, P425F202110, P425M200661 Federal Award Year - 2020 Criteria ? 2 CFR 200.303 requires the non-Federal entity to ?(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.? Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All nonprocurement transactions entered into by a recipient (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Condition ? Adequate controls were not in place to provide for proper review of covered transactions for suspension and debarment. Covered transactions, over $25,000 paid with grant funding were not reviewed for suspension and debarment. Cause ? The College lacked sufficient controls to ensure evidence of compliance with suspension and debarment. Questioned Costs ? Not determinable Effect ? Failure to properly verify that a potential vendor has not been suspended or debarred could result in unallowable expenditures and disallowed costs. Recommendation ? We recommend that controls should be put into place to better monitor and document the compliance of vendors for suspension and debarment. Management?s Response ? The College will implement additional controls to ensure there is evidence of review of covered transactions over $25,000 for suspension and debarment prior to payment. Dean of Administrative Services will be responsible for the corrective action and anticipates completion of corrective action will be taken before September 30, 2023.
Item 2022-001 ? Suspension and Debarment Education Stabilization Fund: Higher Education Emergency Relief Fund (HEERF) ? ALN # 84.425E, 84.425F, & 84.425M U.S. Department of Education Federal Award #P425E201496, P425F202110, P425M200661 Federal Award Year - 2020 Criteria ? 2 CFR 200.303 requires the non-Federal entity to ?(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.? Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All nonprocurement transactions entered into by a recipient (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Condition ? Adequate controls were not in place to provide for proper review of covered transactions for suspension and debarment. Covered transactions, over $25,000 paid with grant funding were not reviewed for suspension and debarment. Cause ? The College lacked sufficient controls to ensure evidence of compliance with suspension and debarment. Questioned Costs ? Not determinable Effect ? Failure to properly verify that a potential vendor has not been suspended or debarred could result in unallowable expenditures and disallowed costs. Recommendation ? We recommend that controls should be put into place to better monitor and document the compliance of vendors for suspension and debarment. Management?s Response ? The College will implement additional controls to ensure there is evidence of review of covered transactions over $25,000 for suspension and debarment prior to payment. Dean of Administrative Services will be responsible for the corrective action and anticipates completion of corrective action will be taken before September 30, 2023.
Item 2022-002 ? Eligibility TRIO Cluster ? ALN # 84.042A, 84.044A, & 84.066A U.S. Department of Education Federal Award #P042A200340-21, P044A210348, P066A210037 Federal Award Year - 2022 Criteria ? As specified in 2 CFR section 200.303 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. The College lacked sufficient review of participant applications to verify compliance with eligibility requirements as referenced in 34 CFR section 644.3. Condition ? During a dual purpose tests of controls and compliance there were 3 participants selected for testing that did not certify to the fact that they were a citizen, national, or permanent resident of the United States, a requirement for eligibility of the TRIO program. Cause ? The College lacked sufficient review of participant application to verify compliance with eligibility. Questioned Costs ? Not determinable Effect ? Failure to properly verify eligibility could result in services being provided to participants that do not meet requirements of program. Recommendation ? We recommend that review should be performed of participants application before services are rendered. Management?s Response ? The College will implement additional controls to ensure there is evidence of review of certifying statement from participant prior to services being rendered. TRIO Services Director will be responsible for the corrective action and anticipates completion of corrective action will be taken before September 30, 2023.
Item 2022-002 ? Eligibility TRIO Cluster ? ALN # 84.042A, 84.044A, & 84.066A U.S. Department of Education Federal Award #P042A200340-21, P044A210348, P066A210037 Federal Award Year - 2022 Criteria ? As specified in 2 CFR section 200.303 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. The College lacked sufficient review of participant applications to verify compliance with eligibility requirements as referenced in 34 CFR section 644.3. Condition ? During a dual purpose tests of controls and compliance there were 3 participants selected for testing that did not certify to the fact that they were a citizen, national, or permanent resident of the United States, a requirement for eligibility of the TRIO program. Cause ? The College lacked sufficient review of participant application to verify compliance with eligibility. Questioned Costs ? Not determinable Effect ? Failure to properly verify eligibility could result in services being provided to participants that do not meet requirements of program. Recommendation ? We recommend that review should be performed of participants application before services are rendered. Management?s Response ? The College will implement additional controls to ensure there is evidence of review of certifying statement from participant prior to services being rendered. TRIO Services Director will be responsible for the corrective action and anticipates completion of corrective action will be taken before September 30, 2023.
Item 2022-002 ? Eligibility TRIO Cluster ? ALN # 84.042A, 84.044A, & 84.066A U.S. Department of Education Federal Award #P042A200340-21, P044A210348, P066A210037 Federal Award Year - 2022 Criteria ? As specified in 2 CFR section 200.303 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. The College lacked sufficient review of participant applications to verify compliance with eligibility requirements as referenced in 34 CFR section 644.3. Condition ? During a dual purpose tests of controls and compliance there were 3 participants selected for testing that did not certify to the fact that they were a citizen, national, or permanent resident of the United States, a requirement for eligibility of the TRIO program. Cause ? The College lacked sufficient review of participant application to verify compliance with eligibility. Questioned Costs ? Not determinable Effect ? Failure to properly verify eligibility could result in services being provided to participants that do not meet requirements of program. Recommendation ? We recommend that review should be performed of participants application before services are rendered. Management?s Response ? The College will implement additional controls to ensure there is evidence of review of certifying statement from participant prior to services being rendered. TRIO Services Director will be responsible for the corrective action and anticipates completion of corrective action will be taken before September 30, 2023.
Item 2022-001 ? Suspension and Debarment Education Stabilization Fund: Higher Education Emergency Relief Fund (HEERF) ? ALN # 84.425E, 84.425F, & 84.425M U.S. Department of Education Federal Award #P425E201496, P425F202110, P425M200661 Federal Award Year - 2020 Criteria ? 2 CFR 200.303 requires the non-Federal entity to ?(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.? Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All nonprocurement transactions entered into by a recipient (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Condition ? Adequate controls were not in place to provide for proper review of covered transactions for suspension and debarment. Covered transactions, over $25,000 paid with grant funding were not reviewed for suspension and debarment. Cause ? The College lacked sufficient controls to ensure evidence of compliance with suspension and debarment. Questioned Costs ? Not determinable Effect ? Failure to properly verify that a potential vendor has not been suspended or debarred could result in unallowable expenditures and disallowed costs. Recommendation ? We recommend that controls should be put into place to better monitor and document the compliance of vendors for suspension and debarment. Management?s Response ? The College will implement additional controls to ensure there is evidence of review of covered transactions over $25,000 for suspension and debarment prior to payment. Dean of Administrative Services will be responsible for the corrective action and anticipates completion of corrective action will be taken before September 30, 2023.
Item 2022-001 ? Suspension and Debarment Education Stabilization Fund: Higher Education Emergency Relief Fund (HEERF) ? ALN # 84.425E, 84.425F, & 84.425M U.S. Department of Education Federal Award #P425E201496, P425F202110, P425M200661 Federal Award Year - 2020 Criteria ? 2 CFR 200.303 requires the non-Federal entity to ?(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.? Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All nonprocurement transactions entered into by a recipient (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Condition ? Adequate controls were not in place to provide for proper review of covered transactions for suspension and debarment. Covered transactions, over $25,000 paid with grant funding were not reviewed for suspension and debarment. Cause ? The College lacked sufficient controls to ensure evidence of compliance with suspension and debarment. Questioned Costs ? Not determinable Effect ? Failure to properly verify that a potential vendor has not been suspended or debarred could result in unallowable expenditures and disallowed costs. Recommendation ? We recommend that controls should be put into place to better monitor and document the compliance of vendors for suspension and debarment. Management?s Response ? The College will implement additional controls to ensure there is evidence of review of covered transactions over $25,000 for suspension and debarment prior to payment. Dean of Administrative Services will be responsible for the corrective action and anticipates completion of corrective action will be taken before September 30, 2023.
Item 2022-001 ? Suspension and Debarment Education Stabilization Fund: Higher Education Emergency Relief Fund (HEERF) ? ALN # 84.425E, 84.425F, & 84.425M U.S. Department of Education Federal Award #P425E201496, P425F202110, P425M200661 Federal Award Year - 2020 Criteria ? 2 CFR 200.303 requires the non-Federal entity to ?(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.? Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All nonprocurement transactions entered into by a recipient (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Condition ? Adequate controls were not in place to provide for proper review of covered transactions for suspension and debarment. Covered transactions, over $25,000 paid with grant funding were not reviewed for suspension and debarment. Cause ? The College lacked sufficient controls to ensure evidence of compliance with suspension and debarment. Questioned Costs ? Not determinable Effect ? Failure to properly verify that a potential vendor has not been suspended or debarred could result in unallowable expenditures and disallowed costs. Recommendation ? We recommend that controls should be put into place to better monitor and document the compliance of vendors for suspension and debarment. Management?s Response ? The College will implement additional controls to ensure there is evidence of review of covered transactions over $25,000 for suspension and debarment prior to payment. Dean of Administrative Services will be responsible for the corrective action and anticipates completion of corrective action will be taken before September 30, 2023.
Item 2022-002 ? Eligibility TRIO Cluster ? ALN # 84.042A, 84.044A, & 84.066A U.S. Department of Education Federal Award #P042A200340-21, P044A210348, P066A210037 Federal Award Year - 2022 Criteria ? As specified in 2 CFR section 200.303 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. The College lacked sufficient review of participant applications to verify compliance with eligibility requirements as referenced in 34 CFR section 644.3. Condition ? During a dual purpose tests of controls and compliance there were 3 participants selected for testing that did not certify to the fact that they were a citizen, national, or permanent resident of the United States, a requirement for eligibility of the TRIO program. Cause ? The College lacked sufficient review of participant application to verify compliance with eligibility. Questioned Costs ? Not determinable Effect ? Failure to properly verify eligibility could result in services being provided to participants that do not meet requirements of program. Recommendation ? We recommend that review should be performed of participants application before services are rendered. Management?s Response ? The College will implement additional controls to ensure there is evidence of review of certifying statement from participant prior to services being rendered. TRIO Services Director will be responsible for the corrective action and anticipates completion of corrective action will be taken before September 30, 2023.
Item 2022-002 ? Eligibility TRIO Cluster ? ALN # 84.042A, 84.044A, & 84.066A U.S. Department of Education Federal Award #P042A200340-21, P044A210348, P066A210037 Federal Award Year - 2022 Criteria ? As specified in 2 CFR section 200.303 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. The College lacked sufficient review of participant applications to verify compliance with eligibility requirements as referenced in 34 CFR section 644.3. Condition ? During a dual purpose tests of controls and compliance there were 3 participants selected for testing that did not certify to the fact that they were a citizen, national, or permanent resident of the United States, a requirement for eligibility of the TRIO program. Cause ? The College lacked sufficient review of participant application to verify compliance with eligibility. Questioned Costs ? Not determinable Effect ? Failure to properly verify eligibility could result in services being provided to participants that do not meet requirements of program. Recommendation ? We recommend that review should be performed of participants application before services are rendered. Management?s Response ? The College will implement additional controls to ensure there is evidence of review of certifying statement from participant prior to services being rendered. TRIO Services Director will be responsible for the corrective action and anticipates completion of corrective action will be taken before September 30, 2023.
Item 2022-002 ? Eligibility TRIO Cluster ? ALN # 84.042A, 84.044A, & 84.066A U.S. Department of Education Federal Award #P042A200340-21, P044A210348, P066A210037 Federal Award Year - 2022 Criteria ? As specified in 2 CFR section 200.303 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. The College lacked sufficient review of participant applications to verify compliance with eligibility requirements as referenced in 34 CFR section 644.3. Condition ? During a dual purpose tests of controls and compliance there were 3 participants selected for testing that did not certify to the fact that they were a citizen, national, or permanent resident of the United States, a requirement for eligibility of the TRIO program. Cause ? The College lacked sufficient review of participant application to verify compliance with eligibility. Questioned Costs ? Not determinable Effect ? Failure to properly verify eligibility could result in services being provided to participants that do not meet requirements of program. Recommendation ? We recommend that review should be performed of participants application before services are rendered. Management?s Response ? The College will implement additional controls to ensure there is evidence of review of certifying statement from participant prior to services being rendered. TRIO Services Director will be responsible for the corrective action and anticipates completion of corrective action will be taken before September 30, 2023.