See Schedule of Findings and Questioned Costs for chart/table 2022-003: Reporting Criteria: 2 CFR 200.327, Financial Reporting, and the laws, regulations, and provisions of contracts or grant agreements pertaining to the specific programs require that reports be complete, accurate, and supported by accounting records (if applicable), and submitted in compliance with the appropriate deadlines. Per various guidance published by ED, the Higher Education Emergency Relief Fund (HEERF) portion of the ESF requires the following with respect to reporting: Quarterly Public Reporting (Student Portion): Institutes of Higher Education (IHE) were required to publicly post certain information on their websites no later than 30 days after award and update that information every 45 days thereafter. However, on August 31, 2020, ED revised the requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. IHEs 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. IHEs may have until the end of the second calendar quarter, June 30, 2021, to post these retroactive reports if they have not already done so. Quarterly Public Reporting (Institutional Portion): A new, separate form was to be posted covering aggregate amounts spent for all HEERF funds each quarterly reporting period. IHEs must post this quarterly report form no later than 10 days after the end of each calendar quarter, apart from the first report, which was due on October 30, 2020, and the report covering the first quarter of 2021, which was due on July 10, 2021. The forms are required to be conspicuously posted on each institution?s primary website on the same page the reports of the IHE?s activities as to the emergency financial aid grants to students (Student Portion) are posted. Condition/context: A total of five reports were selected for testing, including one annual report, two quarterly reports related to the Student Portion and two quarterly reports related to the Institutional Portion. Of these five reports: 1. All reports lacked evidence of proper review and approval by authorized individuals before submission of the report to the ED. 2. The Quarterly Student report for the period ended March 31, 2022 was not submitted in a timely manner. 3. The Quarterly Institutional report for the period ended September 30, 2021 was not submitted in a timely manner. 4. The Quarterly Institutional report for the period ended March 31, 2022 was not submitted in a timely manner. Questioned costs: $0 Cause: The College?s internal control system did not have a sufficient control process in place to ensure all reports were reviewed and approved by proper authorized individuals or that the reports were completed and submitted timely. Effect: If a non-Federal entity fails to comply with Federal statutes, regulations, or the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, which include requiring payments as reimbursements rather than advance payments; withholding authority to proceed to the next phase until receiving evidence of acceptable performance within a given period of performance; requiring additional, more detailed financial reports; requiring additional project monitoring; requiring the non-Federal entity to obtain technical or management assistance; and establishing additional prior approvals. If the Federal awarding agency determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding agency may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR Part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Identification as a repeat finding: Yes; see prior-year finding 2021-002. Recommendation: We recommend that the College revise its procedures to include an independent review of reports for accuracy before they are submitted and posted. Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I.
See Schedule of Findings and Questioned Costs for chart/table 2022-003: Reporting Criteria: 2 CFR 200.327, Financial Reporting, and the laws, regulations, and provisions of contracts or grant agreements pertaining to the specific programs require that reports be complete, accurate, and supported by accounting records (if applicable), and submitted in compliance with the appropriate deadlines. Per various guidance published by ED, the Higher Education Emergency Relief Fund (HEERF) portion of the ESF requires the following with respect to reporting: Quarterly Public Reporting (Student Portion): Institutes of Higher Education (IHE) were required to publicly post certain information on their websites no later than 30 days after award and update that information every 45 days thereafter. However, on August 31, 2020, ED revised the requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. IHEs 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. IHEs may have until the end of the second calendar quarter, June 30, 2021, to post these retroactive reports if they have not already done so. Quarterly Public Reporting (Institutional Portion): A new, separate form was to be posted covering aggregate amounts spent for all HEERF funds each quarterly reporting period. IHEs must post this quarterly report form no later than 10 days after the end of each calendar quarter, apart from the first report, which was due on October 30, 2020, and the report covering the first quarter of 2021, which was due on July 10, 2021. The forms are required to be conspicuously posted on each institution?s primary website on the same page the reports of the IHE?s activities as to the emergency financial aid grants to students (Student Portion) are posted. Condition/context: A total of five reports were selected for testing, including one annual report, two quarterly reports related to the Student Portion and two quarterly reports related to the Institutional Portion. Of these five reports: 1. All reports lacked evidence of proper review and approval by authorized individuals before submission of the report to the ED. 2. The Quarterly Student report for the period ended March 31, 2022 was not submitted in a timely manner. 3. The Quarterly Institutional report for the period ended September 30, 2021 was not submitted in a timely manner. 4. The Quarterly Institutional report for the period ended March 31, 2022 was not submitted in a timely manner. Questioned costs: $0 Cause: The College?s internal control system did not have a sufficient control process in place to ensure all reports were reviewed and approved by proper authorized individuals or that the reports were completed and submitted timely. Effect: If a non-Federal entity fails to comply with Federal statutes, regulations, or the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, which include requiring payments as reimbursements rather than advance payments; withholding authority to proceed to the next phase until receiving evidence of acceptable performance within a given period of performance; requiring additional, more detailed financial reports; requiring additional project monitoring; requiring the non-Federal entity to obtain technical or management assistance; and establishing additional prior approvals. If the Federal awarding agency determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding agency may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR Part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Identification as a repeat finding: Yes; see prior-year finding 2021-002. Recommendation: We recommend that the College revise its procedures to include an independent review of reports for accuracy before they are submitted and posted. Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I.
See Schedule of Findings and Questioned Costs for chart/table 2022-004: Special Tests - Number of Students Served Criteria: Per the Sub-Award Agreement between the University of Wyoming and the College (the Contractor), ?Subrecipient shall provide services designed to assist in achieving the following objectives for its selected GEAR UP students: ? GEAR UP Wyoming (GUWY) will serve a minimum of 2,000 participants each year. (Contractor is required to serve at least 350 of the 2,000 students).? Condition/context: The number of students served by the College during the year was recorded at 298, an underserving of 52. Questioned costs: $0 Cause: Historically, the College has been able to meet the minimum required students served via internal tracking as well as subrecipient monitoring provided by the University of Wyoming. However, during the year, the GEAR UP program experienced turnover in the director position and other matters impacted the ability of the former outreach coordinator/database technician to perform her normal duties. As such, the College did not follow its internal procedures to track students served and maintain continuous contact with the University of Wyoming to ensure that the minimum number of students were being served. Effect: The University of Wyoming could opt to not renew the College?s program funding if the minimum number of students served requirement is not met. Identification as a repeat finding: No Recommendation: We recommend that the program have a process in place to ensure all necessary procedures/controls are adhered to, even in times of positional turnover or when the individuals who usually perform those procedures/controls are on leave. Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I.
See Schedule of Findings and Questioned Costs for chart/table 2022-003: Reporting Criteria: 2 CFR 200.327, Financial Reporting, and the laws, regulations, and provisions of contracts or grant agreements pertaining to the specific programs require that reports be complete, accurate, and supported by accounting records (if applicable), and submitted in compliance with the appropriate deadlines. Per various guidance published by ED, the Higher Education Emergency Relief Fund (HEERF) portion of the ESF requires the following with respect to reporting: Quarterly Public Reporting (Student Portion): Institutes of Higher Education (IHE) were required to publicly post certain information on their websites no later than 30 days after award and update that information every 45 days thereafter. However, on August 31, 2020, ED revised the requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. IHEs 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. IHEs may have until the end of the second calendar quarter, June 30, 2021, to post these retroactive reports if they have not already done so. Quarterly Public Reporting (Institutional Portion): A new, separate form was to be posted covering aggregate amounts spent for all HEERF funds each quarterly reporting period. IHEs must post this quarterly report form no later than 10 days after the end of each calendar quarter, apart from the first report, which was due on October 30, 2020, and the report covering the first quarter of 2021, which was due on July 10, 2021. The forms are required to be conspicuously posted on each institution?s primary website on the same page the reports of the IHE?s activities as to the emergency financial aid grants to students (Student Portion) are posted. Condition/context: A total of five reports were selected for testing, including one annual report, two quarterly reports related to the Student Portion and two quarterly reports related to the Institutional Portion. Of these five reports: 1. All reports lacked evidence of proper review and approval by authorized individuals before submission of the report to the ED. 2. The Quarterly Student report for the period ended March 31, 2022 was not submitted in a timely manner. 3. The Quarterly Institutional report for the period ended September 30, 2021 was not submitted in a timely manner. 4. The Quarterly Institutional report for the period ended March 31, 2022 was not submitted in a timely manner. Questioned costs: $0 Cause: The College?s internal control system did not have a sufficient control process in place to ensure all reports were reviewed and approved by proper authorized individuals or that the reports were completed and submitted timely. Effect: If a non-Federal entity fails to comply with Federal statutes, regulations, or the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, which include requiring payments as reimbursements rather than advance payments; withholding authority to proceed to the next phase until receiving evidence of acceptable performance within a given period of performance; requiring additional, more detailed financial reports; requiring additional project monitoring; requiring the non-Federal entity to obtain technical or management assistance; and establishing additional prior approvals. If the Federal awarding agency determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding agency may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR Part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Identification as a repeat finding: Yes; see prior-year finding 2021-002. Recommendation: We recommend that the College revise its procedures to include an independent review of reports for accuracy before they are submitted and posted. Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I.
See Schedule of Findings and Questioned Costs for chart/table 2022-003: Reporting Criteria: 2 CFR 200.327, Financial Reporting, and the laws, regulations, and provisions of contracts or grant agreements pertaining to the specific programs require that reports be complete, accurate, and supported by accounting records (if applicable), and submitted in compliance with the appropriate deadlines. Per various guidance published by ED, the Higher Education Emergency Relief Fund (HEERF) portion of the ESF requires the following with respect to reporting: Quarterly Public Reporting (Student Portion): Institutes of Higher Education (IHE) were required to publicly post certain information on their websites no later than 30 days after award and update that information every 45 days thereafter. However, on August 31, 2020, ED revised the requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. IHEs 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. IHEs may have until the end of the second calendar quarter, June 30, 2021, to post these retroactive reports if they have not already done so. Quarterly Public Reporting (Institutional Portion): A new, separate form was to be posted covering aggregate amounts spent for all HEERF funds each quarterly reporting period. IHEs must post this quarterly report form no later than 10 days after the end of each calendar quarter, apart from the first report, which was due on October 30, 2020, and the report covering the first quarter of 2021, which was due on July 10, 2021. The forms are required to be conspicuously posted on each institution?s primary website on the same page the reports of the IHE?s activities as to the emergency financial aid grants to students (Student Portion) are posted. Condition/context: A total of five reports were selected for testing, including one annual report, two quarterly reports related to the Student Portion and two quarterly reports related to the Institutional Portion. Of these five reports: 1. All reports lacked evidence of proper review and approval by authorized individuals before submission of the report to the ED. 2. The Quarterly Student report for the period ended March 31, 2022 was not submitted in a timely manner. 3. The Quarterly Institutional report for the period ended September 30, 2021 was not submitted in a timely manner. 4. The Quarterly Institutional report for the period ended March 31, 2022 was not submitted in a timely manner. Questioned costs: $0 Cause: The College?s internal control system did not have a sufficient control process in place to ensure all reports were reviewed and approved by proper authorized individuals or that the reports were completed and submitted timely. Effect: If a non-Federal entity fails to comply with Federal statutes, regulations, or the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, which include requiring payments as reimbursements rather than advance payments; withholding authority to proceed to the next phase until receiving evidence of acceptable performance within a given period of performance; requiring additional, more detailed financial reports; requiring additional project monitoring; requiring the non-Federal entity to obtain technical or management assistance; and establishing additional prior approvals. If the Federal awarding agency determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding agency may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR Part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Identification as a repeat finding: Yes; see prior-year finding 2021-002. Recommendation: We recommend that the College revise its procedures to include an independent review of reports for accuracy before they are submitted and posted. Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I.
See Schedule of Findings and Questioned Costs for chart/table 2022-004: Special Tests - Number of Students Served Criteria: Per the Sub-Award Agreement between the University of Wyoming and the College (the Contractor), ?Subrecipient shall provide services designed to assist in achieving the following objectives for its selected GEAR UP students: ? GEAR UP Wyoming (GUWY) will serve a minimum of 2,000 participants each year. (Contractor is required to serve at least 350 of the 2,000 students).? Condition/context: The number of students served by the College during the year was recorded at 298, an underserving of 52. Questioned costs: $0 Cause: Historically, the College has been able to meet the minimum required students served via internal tracking as well as subrecipient monitoring provided by the University of Wyoming. However, during the year, the GEAR UP program experienced turnover in the director position and other matters impacted the ability of the former outreach coordinator/database technician to perform her normal duties. As such, the College did not follow its internal procedures to track students served and maintain continuous contact with the University of Wyoming to ensure that the minimum number of students were being served. Effect: The University of Wyoming could opt to not renew the College?s program funding if the minimum number of students served requirement is not met. Identification as a repeat finding: No Recommendation: We recommend that the program have a process in place to ensure all necessary procedures/controls are adhered to, even in times of positional turnover or when the individuals who usually perform those procedures/controls are on leave. Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I.