FAC Explorer

Audit 49051

FY End
2022-06-30
Total Expended
$4.24M
Findings
4
Programs
5
Organization: College of Biblical Studies (TX)
Year: 2022 Accepted: 2022-11-20
Auditor: Carr Riggs & Ingram LLC

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
51361 2022-001 Significant Deficiency - C
51362 2022-002 Significant Deficiency - I
627803 2022-001 Significant Deficiency - C
627804 2022-002 Significant Deficiency - I

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $1.25M - 0
84.425 Covid-19 Education Stabilization Fund $1.14M Yes 1
84.063 Federal Pell Grant Program $753,851 - 0
84.007 Federal Supplemental Educational Opportunity Grants $117,856 - 0
84.033 Federal Work-Study Program $26,188 - 0

Contacts

Name Title Type
W9K7XKME1855 Benjamin Chelladurai Auditee
8322524616 Alyssa Hill Auditor
No contacts on file

Notes to SEFA

Title: Note 3: Relationship to College's Financial Statements Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (the Schedule) presents the Federal award program expenditures of the College for the year ended June 30, 2022. The information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in this schedule may differ from amounts presented in or used in the preparation of the Colleges financial statements. The Colleges COVID19: Education StabilizationFund: Higher Education Emergency Relief Fund (HEERF) revenue of $1,576,954 as reported in the statement of activities for the year ended June 30, 2022 differs from the reported schedule of expenditures of federal awards of $2,097,552 for 2022 by $520,598 which represents discharging of student receivable balances from HEERF funding.Expenditures presented on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles as found in the Uniform Guidance. The College has elected not to use the 10 percent de minimus indirect cost rate as allowed under the Uniform Guidance. The College did not receive any federal noncash assistance for the year ended June 30, 2022. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. Federal Pell Grant, Federal Direct Student Loans, Federal WorkStudy Program and Federal Supplemental Educational Opportunity Grant award expenditures, as reported in the Schedule of Expenditures of Federal Awards, reimburse all or part of tuition and fees due from students. Excess award amounts are refunded to the students. Federal awards, except HEERF are not recognized in the Colleges financial statements for the year ended June 30, 2022.

Finding Details

Finding 2022-001
2022-001 Compliance and Internal Controls over Cash Management (Significant Deficiency) U.S. Department of Education COVID -19: Education Stabilization Fund: Higher Education Emergency Relief Fund 84.425E ? COVID-19 Student Portion 2021-2022 Funding Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under HEERF award, grantees are under an obligation to minimize the time between drawing down funds from G5 and paying obligations incurred by the grantee (liquidation). If a HEERF grantee is using HEERF grant funds to make financial aid grants to students, the Department may evaluate for compliance with the rule grantees who have not drawn down the funds from G5 and not paid the obligations (the financial aid grants to students) to the students within fifteen calendar days. Condition: We noted that for all 25 of the disbursements reviewed, the payments to students were processed after the fifteen calendar day timeframe. Effect: While HEERF funding has been exhausted as of June 30, 2022, not issuing refunds within due dates may impact future federal funding levels for the College. Cause: Issues with communications between the business office and student financial aid department and system issue with the student software caused delays in processing payment to students. Questioned Costs: None. Perspective: Systemic problem noted for all disbursements made to students arising from communication issues between the College?s departments and student software issues. Repeat Finding: No Auditors? Recommendation: While not applicable for HEERF funding since this has been fully utilized, for all related federal awards to students, we recommend that in order to minimize the time between funds drawn and eventual disbursement to students, the Business Office should only make draws after communication from the Student Financial Aid department that all student reviews have been completed and these are ready to be paid. Evidence of this communication should also be maintained to allow for proper audit trail. Views of Responsible Officials: See corrective action plan
Finding 2022-002
2022-002 Internal Controls over Suspension and Debarment (Significant Deficiency) U.S. Department of Education COVID -19: Education Stabilization Fund: Higher Education Emergency Relief Fund 84.425F ? COVID-19 Institutional Portion 2021-2022 Funding Criteria: Under 2 CFR Section 200.303(a) and 2 CFR Section 180, Subpart C, non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Condition: The College does not have documented controls to prevent purchases using federal funds from suspended or debarred vendors. Effect: Payments from federal funds made to suspended or debarred vendors may need to returned and / or impact future funding. Cause: While the College has policies and procedures for procurement, these do not encompass verifying that the potential vendor is suspended or debarred from receiving federal funding as required under 2 CFR Section 180, Subpart C. Questioned Costs: None. Perspective: Because a formal policy is not established, none of the vendors meeting the threshold were subjected to suspension and debarment testing by the College. Repeat Finding: No Auditors? Recommendation: The College should establish procedures to ensure that controls related to suspension and debarment are devised, are consistently implemented and that all written records are maintained to support that the compliance requirement is met. Views of Responsible Officials: See corrective action plan
Finding 2022-001
2022-001 Compliance and Internal Controls over Cash Management (Significant Deficiency) U.S. Department of Education COVID -19: Education Stabilization Fund: Higher Education Emergency Relief Fund 84.425E ? COVID-19 Student Portion 2021-2022 Funding Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under HEERF award, grantees are under an obligation to minimize the time between drawing down funds from G5 and paying obligations incurred by the grantee (liquidation). If a HEERF grantee is using HEERF grant funds to make financial aid grants to students, the Department may evaluate for compliance with the rule grantees who have not drawn down the funds from G5 and not paid the obligations (the financial aid grants to students) to the students within fifteen calendar days. Condition: We noted that for all 25 of the disbursements reviewed, the payments to students were processed after the fifteen calendar day timeframe. Effect: While HEERF funding has been exhausted as of June 30, 2022, not issuing refunds within due dates may impact future federal funding levels for the College. Cause: Issues with communications between the business office and student financial aid department and system issue with the student software caused delays in processing payment to students. Questioned Costs: None. Perspective: Systemic problem noted for all disbursements made to students arising from communication issues between the College?s departments and student software issues. Repeat Finding: No Auditors? Recommendation: While not applicable for HEERF funding since this has been fully utilized, for all related federal awards to students, we recommend that in order to minimize the time between funds drawn and eventual disbursement to students, the Business Office should only make draws after communication from the Student Financial Aid department that all student reviews have been completed and these are ready to be paid. Evidence of this communication should also be maintained to allow for proper audit trail. Views of Responsible Officials: See corrective action plan
Finding 2022-002
2022-002 Internal Controls over Suspension and Debarment (Significant Deficiency) U.S. Department of Education COVID -19: Education Stabilization Fund: Higher Education Emergency Relief Fund 84.425F ? COVID-19 Institutional Portion 2021-2022 Funding Criteria: Under 2 CFR Section 200.303(a) and 2 CFR Section 180, Subpart C, non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Condition: The College does not have documented controls to prevent purchases using federal funds from suspended or debarred vendors. Effect: Payments from federal funds made to suspended or debarred vendors may need to returned and / or impact future funding. Cause: While the College has policies and procedures for procurement, these do not encompass verifying that the potential vendor is suspended or debarred from receiving federal funding as required under 2 CFR Section 180, Subpart C. Questioned Costs: None. Perspective: Because a formal policy is not established, none of the vendors meeting the threshold were subjected to suspension and debarment testing by the College. Repeat Finding: No Auditors? Recommendation: The College should establish procedures to ensure that controls related to suspension and debarment are devised, are consistently implemented and that all written records are maintained to support that the compliance requirement is met. Views of Responsible Officials: See corrective action plan