Program: COVID-19 Education Stabilization Fund ALN 84.425E, F and L Higher Education Emergency Relief Fund-Student Aid, Institutional Portion and Minority Serving Institutions Compliance Requirement: Reporting Condition: Quarterly reports are reflecting life to date totals versus quarterly details as well as combining the student aid and minority serving institutions amounts. The Institutional Portion reports reflect debt forgiveness and need to be amended to reflect the approved plan to replace expenditures. See Finding 2022-003. Criteria: Pursuant to 2022 Compliance Supplement ESF Section 2 III E, F, L, an institution must submit a report covering quarterly expenditures for each program for each calendar quarter by purpose. Cause: The College did not properly review the reporting requirements for the grant. Effect: The College could be required to return funding if information is not publicly available or correct to the extent funds were spent. Context: The four quarterly reports did not tie to general ledger accounts used to support the grant for quarterly expenditures. The errors were not detected or amended by year end. Questioned Cost: None Repeat Finding: No Recommendation: We recommend that the College implement procedures to obtain guidance on the high-risk grants and ensure all compliance requirements are followed. Views of Responsible Officials: The reporting standards changed during the year and the reports issued prior to the standard change were not amended. The reports prepared after the change in standards were done quarterly as required. In the future, staff will verify standards prior to preparing the report and contact the Department of Education should anything be in question. The College will amend the effected reports to have only quarterly expenditures and to properly reflect the change in expenditures approved by the Department.
Program: COVID-19 Education Stabilization Fund ALN 84.425E, F and L Higher Education Emergency Relief Fund-Student Aid, Institutional Portion and Minority Serving Institutions Compliance Requirement: Reporting Condition: Quarterly reports are reflecting life to date totals versus quarterly details as well as combining the student aid and minority serving institutions amounts. The Institutional Portion reports reflect debt forgiveness and need to be amended to reflect the approved plan to replace expenditures. See Finding 2022-003. Criteria: Pursuant to 2022 Compliance Supplement ESF Section 2 III E, F, L, an institution must submit a report covering quarterly expenditures for each program for each calendar quarter by purpose. Cause: The College did not properly review the reporting requirements for the grant. Effect: The College could be required to return funding if information is not publicly available or correct to the extent funds were spent. Context: The four quarterly reports did not tie to general ledger accounts used to support the grant for quarterly expenditures. The errors were not detected or amended by year end. Questioned Cost: None Repeat Finding: No Recommendation: We recommend that the College implement procedures to obtain guidance on the high-risk grants and ensure all compliance requirements are followed. Views of Responsible Officials: The reporting standards changed during the year and the reports issued prior to the standard change were not amended. The reports prepared after the change in standards were done quarterly as required. In the future, staff will verify standards prior to preparing the report and contact the Department of Education should anything be in question. The College will amend the effected reports to have only quarterly expenditures and to properly reflect the change in expenditures approved by the Department.
Program: COVID-19 Education Stabilization Fund ALN 84.425F Higher Education Emergency Relief Fund - Institutional Portion Compliance Requirement: Reporting Condition: The quarterly reports for the Institutional Portion were not posted to the college?s website. Criteria: Pursuant to 2022 Compliance Supplement ESF Section 2 III F, requires the College to publish on the institution?s website, quarterly reports for the grants above no later than 10 days after the end of each calendar quarter. Cause: The College is working on a webpage for the Institutional Portion reports but has not completed the page. Effect: The College could lose funding if information is not publicly available or correct to the extent funds were spent. Context: The four quarterly reports for the Institutional portion were only available per request. The College website did not contain reports for the Institutional Portion. Questioned Cost: None Repeat Finding: No Recommendation: The College needs to ensure the reports are posted timely to a webpage dedicated to this grant. Views of Responsible Officials: The one instance cited was for the last quarterly report. All other quarterly reports were on the College website. The staff were working on moving the reports to a more accessible place on the College?s site, but they were on the website. This has since been corrected and all quarterly reports are on an easily accessible page on the College webpage.
Program: COVID-19 Education Stabilization Fund ALN 84.425F Higher Education Emergency Relief Fund ? Institutional Portion Compliance Requirement: Period of Performance Condition: The quarterly reports reflect $4.6 million in expenditures for debt forgiveness that was for institutional debt before March 13, 2020. These expenditures were not in compliance with the period of performance. Criteria: Pursuant to 2022 Compliance Supplement ESF Section 2 III Reporting, the College is to file quarterly reports to reflect expenditures of that quarter by purpose for expenditure within the period of performance. Cause: The College was not aware of the grant?s period of performance. On September 23, 2022, the College was asked to contact the Department of Education for guidance and clarification on debt forgiveness being outside the period of performance for $4.6 million of $6.5 million in debt forgiveness expenditures or obtain a waiver allowing expenditures prior to March 13, 2020. The College?s request for a waiver was denied on November 29, 2022. However, the Department of Education gave written approval to the College to apply invoices for expenditures that are within the grant guidelines and period of performance to replace the disallowed portion of the debt forgiveness that was before March 13, 2020. As the approval was obtained prior to presentation to the Board of Regents for approval, the reclassified expenditures were considered in the compliance testwork and were within the grant guidelines. Amended reports reflecting expenditures by the updated purpose need to be filed with the Department of Education. Effect: The College could be asked to return funding if expenditures are viewed as out of compliance with the period of performance. Context: The College originally applied funds to debt forgiveness in which $1.9 million was within the period of performance and $4.6 million that was outside the period of performance. The debt forgiveness waiver was not approved by the Department of Education for items before March 13, 2020, due to the Department of Education viewing these as recruiting expenditures. The Department of Education gave written approval to the College to amend reports with expenditures that were applicable under the grant guidelines. The quarterly reports reflected only debt forgiveness and have not been amended to reflect accurate expenditures for the period of performance. Questioned Cost: None due to the Department of Education?s approval to file amended reports and exchange disallowed costs with allowable expenditures. Repeat Finding: No Recommendation: The College needs to ensure they understand high-risk grant requirements by reviewing the compliance supplement, the Department of Education?s website and making contact with the Department on questions of concern in a timely fashion. Views of Responsible Officials: The College requested an exchange of expenditures in order to ensure only allowable costs were utilized. The Department of Education granted this exchange and approved filing amended reports. The College will amend the quarterly reports to properly reflect the approved allowed expenditures as per the email from the Department of Education. Staff will contact the Department on any questions they have going forward on questioned expenditures or allowed costs.
Program: COVID-19 Education Stabilization Fund ALN 84.425F Higher Education Emergency Relief Fund ? Institutional Portion Compliance Requirement: Cash Management Criteria: Pursuant to 2022 Compliance Supplement ESF Section 2 III Cash Management, the College is required to disburse funds within three days of draw from G5. Condition: The College had approval from the Department of Education to transfer allowable activities to other expenditures that were applicable under the grant guidelines and replace debt forgiveness outside the period of performance. This caused cash management to become out of compliance with the three days to apply expenditures from the date of drawdown. Context: The College originally applied funds to debt forgiveness in which the parameters of the three days to apply funds did apply. The debt forgiveness was not approved by the Department of Education for items before March 13, 2020. The Department of Education gave written approval to the College to reclass invoices that were applicable under the grant guidelines. This produced the draws being over three days from drawdown for majority of the items. Cause: On September 23, 2022, the College was asked to contact the Department of Education for guidance on debt forgiveness or obtain a waiver. The College?s request for a waiver was denied on November 29, 2022. The Department of Education gave written approval to the College to apply invoices that are within the guidelines of the grant as grant expenditures instead of the original debt forgiveness. Transferring allowable activities resulted in noncompliance with the criteria of expending funds within three days of draw. Effect: The College could be asked to return funding if draws are viewed as out of compliance after the reclassification. Questioned Cost: None Repeat Finding: No Recommendation: The College needs to ensure they understand high-risk grant requirements by reviewing the compliance supplement, the Department of Education?s website and making contact with the Department on questions of concern. Views of Responsible Officials: The College requested a reclassification of expenditures for the grant year. The request was approved by the Department of Education. The College will request any clarification on items from the Department when in question to ensure they understand the requirements of the grant. No further action is required.
Program: COVID-19 Education Stabilization Fund ALN 84.425E, F and L Higher Education Emergency Relief Fund-Student Aid, Institutional Portion and Minority Serving Institutions Compliance Requirement: Reporting Condition: Quarterly reports are reflecting life to date totals versus quarterly details as well as combining the student aid and minority serving institutions amounts. The Institutional Portion reports reflect debt forgiveness and need to be amended to reflect the approved plan to replace expenditures. See Finding 2022-003. Criteria: Pursuant to 2022 Compliance Supplement ESF Section 2 III E, F, L, an institution must submit a report covering quarterly expenditures for each program for each calendar quarter by purpose. Cause: The College did not properly review the reporting requirements for the grant. Effect: The College could be required to return funding if information is not publicly available or correct to the extent funds were spent. Context: The four quarterly reports did not tie to general ledger accounts used to support the grant for quarterly expenditures. The errors were not detected or amended by year end. Questioned Cost: None Repeat Finding: No Recommendation: We recommend that the College implement procedures to obtain guidance on the high-risk grants and ensure all compliance requirements are followed. Views of Responsible Officials: The reporting standards changed during the year and the reports issued prior to the standard change were not amended. The reports prepared after the change in standards were done quarterly as required. In the future, staff will verify standards prior to preparing the report and contact the Department of Education should anything be in question. The College will amend the effected reports to have only quarterly expenditures and to properly reflect the change in expenditures approved by the Department.
Program: COVID-19 Education Stabilization Fund ALN 84.425E, F and L Higher Education Emergency Relief Fund-Student Aid, Institutional Portion and Minority Serving Institutions Compliance Requirement: Reporting Condition: Quarterly reports are reflecting life to date totals versus quarterly details as well as combining the student aid and minority serving institutions amounts. The Institutional Portion reports reflect debt forgiveness and need to be amended to reflect the approved plan to replace expenditures. See Finding 2022-003. Criteria: Pursuant to 2022 Compliance Supplement ESF Section 2 III E, F, L, an institution must submit a report covering quarterly expenditures for each program for each calendar quarter by purpose. Cause: The College did not properly review the reporting requirements for the grant. Effect: The College could be required to return funding if information is not publicly available or correct to the extent funds were spent. Context: The four quarterly reports did not tie to general ledger accounts used to support the grant for quarterly expenditures. The errors were not detected or amended by year end. Questioned Cost: None Repeat Finding: No Recommendation: We recommend that the College implement procedures to obtain guidance on the high-risk grants and ensure all compliance requirements are followed. Views of Responsible Officials: The reporting standards changed during the year and the reports issued prior to the standard change were not amended. The reports prepared after the change in standards were done quarterly as required. In the future, staff will verify standards prior to preparing the report and contact the Department of Education should anything be in question. The College will amend the effected reports to have only quarterly expenditures and to properly reflect the change in expenditures approved by the Department.
Program: COVID-19 Education Stabilization Fund ALN 84.425E, F and L Higher Education Emergency Relief Fund-Student Aid, Institutional Portion and Minority Serving Institutions Compliance Requirement: Reporting Condition: Quarterly reports are reflecting life to date totals versus quarterly details as well as combining the student aid and minority serving institutions amounts. The Institutional Portion reports reflect debt forgiveness and need to be amended to reflect the approved plan to replace expenditures. See Finding 2022-003. Criteria: Pursuant to 2022 Compliance Supplement ESF Section 2 III E, F, L, an institution must submit a report covering quarterly expenditures for each program for each calendar quarter by purpose. Cause: The College did not properly review the reporting requirements for the grant. Effect: The College could be required to return funding if information is not publicly available or correct to the extent funds were spent. Context: The four quarterly reports did not tie to general ledger accounts used to support the grant for quarterly expenditures. The errors were not detected or amended by year end. Questioned Cost: None Repeat Finding: No Recommendation: We recommend that the College implement procedures to obtain guidance on the high-risk grants and ensure all compliance requirements are followed. Views of Responsible Officials: The reporting standards changed during the year and the reports issued prior to the standard change were not amended. The reports prepared after the change in standards were done quarterly as required. In the future, staff will verify standards prior to preparing the report and contact the Department of Education should anything be in question. The College will amend the effected reports to have only quarterly expenditures and to properly reflect the change in expenditures approved by the Department.
Program: COVID-19 Education Stabilization Fund ALN 84.425F Higher Education Emergency Relief Fund - Institutional Portion Compliance Requirement: Reporting Condition: The quarterly reports for the Institutional Portion were not posted to the college?s website. Criteria: Pursuant to 2022 Compliance Supplement ESF Section 2 III F, requires the College to publish on the institution?s website, quarterly reports for the grants above no later than 10 days after the end of each calendar quarter. Cause: The College is working on a webpage for the Institutional Portion reports but has not completed the page. Effect: The College could lose funding if information is not publicly available or correct to the extent funds were spent. Context: The four quarterly reports for the Institutional portion were only available per request. The College website did not contain reports for the Institutional Portion. Questioned Cost: None Repeat Finding: No Recommendation: The College needs to ensure the reports are posted timely to a webpage dedicated to this grant. Views of Responsible Officials: The one instance cited was for the last quarterly report. All other quarterly reports were on the College website. The staff were working on moving the reports to a more accessible place on the College?s site, but they were on the website. This has since been corrected and all quarterly reports are on an easily accessible page on the College webpage.
Program: COVID-19 Education Stabilization Fund ALN 84.425F Higher Education Emergency Relief Fund ? Institutional Portion Compliance Requirement: Period of Performance Condition: The quarterly reports reflect $4.6 million in expenditures for debt forgiveness that was for institutional debt before March 13, 2020. These expenditures were not in compliance with the period of performance. Criteria: Pursuant to 2022 Compliance Supplement ESF Section 2 III Reporting, the College is to file quarterly reports to reflect expenditures of that quarter by purpose for expenditure within the period of performance. Cause: The College was not aware of the grant?s period of performance. On September 23, 2022, the College was asked to contact the Department of Education for guidance and clarification on debt forgiveness being outside the period of performance for $4.6 million of $6.5 million in debt forgiveness expenditures or obtain a waiver allowing expenditures prior to March 13, 2020. The College?s request for a waiver was denied on November 29, 2022. However, the Department of Education gave written approval to the College to apply invoices for expenditures that are within the grant guidelines and period of performance to replace the disallowed portion of the debt forgiveness that was before March 13, 2020. As the approval was obtained prior to presentation to the Board of Regents for approval, the reclassified expenditures were considered in the compliance testwork and were within the grant guidelines. Amended reports reflecting expenditures by the updated purpose need to be filed with the Department of Education. Effect: The College could be asked to return funding if expenditures are viewed as out of compliance with the period of performance. Context: The College originally applied funds to debt forgiveness in which $1.9 million was within the period of performance and $4.6 million that was outside the period of performance. The debt forgiveness waiver was not approved by the Department of Education for items before March 13, 2020, due to the Department of Education viewing these as recruiting expenditures. The Department of Education gave written approval to the College to amend reports with expenditures that were applicable under the grant guidelines. The quarterly reports reflected only debt forgiveness and have not been amended to reflect accurate expenditures for the period of performance. Questioned Cost: None due to the Department of Education?s approval to file amended reports and exchange disallowed costs with allowable expenditures. Repeat Finding: No Recommendation: The College needs to ensure they understand high-risk grant requirements by reviewing the compliance supplement, the Department of Education?s website and making contact with the Department on questions of concern in a timely fashion. Views of Responsible Officials: The College requested an exchange of expenditures in order to ensure only allowable costs were utilized. The Department of Education granted this exchange and approved filing amended reports. The College will amend the quarterly reports to properly reflect the approved allowed expenditures as per the email from the Department of Education. Staff will contact the Department on any questions they have going forward on questioned expenditures or allowed costs.
Program: COVID-19 Education Stabilization Fund ALN 84.425F Higher Education Emergency Relief Fund ? Institutional Portion Compliance Requirement: Cash Management Criteria: Pursuant to 2022 Compliance Supplement ESF Section 2 III Cash Management, the College is required to disburse funds within three days of draw from G5. Condition: The College had approval from the Department of Education to transfer allowable activities to other expenditures that were applicable under the grant guidelines and replace debt forgiveness outside the period of performance. This caused cash management to become out of compliance with the three days to apply expenditures from the date of drawdown. Context: The College originally applied funds to debt forgiveness in which the parameters of the three days to apply funds did apply. The debt forgiveness was not approved by the Department of Education for items before March 13, 2020. The Department of Education gave written approval to the College to reclass invoices that were applicable under the grant guidelines. This produced the draws being over three days from drawdown for majority of the items. Cause: On September 23, 2022, the College was asked to contact the Department of Education for guidance on debt forgiveness or obtain a waiver. The College?s request for a waiver was denied on November 29, 2022. The Department of Education gave written approval to the College to apply invoices that are within the guidelines of the grant as grant expenditures instead of the original debt forgiveness. Transferring allowable activities resulted in noncompliance with the criteria of expending funds within three days of draw. Effect: The College could be asked to return funding if draws are viewed as out of compliance after the reclassification. Questioned Cost: None Repeat Finding: No Recommendation: The College needs to ensure they understand high-risk grant requirements by reviewing the compliance supplement, the Department of Education?s website and making contact with the Department on questions of concern. Views of Responsible Officials: The College requested a reclassification of expenditures for the grant year. The request was approved by the Department of Education. The College will request any clarification on items from the Department when in question to ensure they understand the requirements of the grant. No further action is required.
Program: COVID-19 Education Stabilization Fund ALN 84.425E, F and L Higher Education Emergency Relief Fund-Student Aid, Institutional Portion and Minority Serving Institutions Compliance Requirement: Reporting Condition: Quarterly reports are reflecting life to date totals versus quarterly details as well as combining the student aid and minority serving institutions amounts. The Institutional Portion reports reflect debt forgiveness and need to be amended to reflect the approved plan to replace expenditures. See Finding 2022-003. Criteria: Pursuant to 2022 Compliance Supplement ESF Section 2 III E, F, L, an institution must submit a report covering quarterly expenditures for each program for each calendar quarter by purpose. Cause: The College did not properly review the reporting requirements for the grant. Effect: The College could be required to return funding if information is not publicly available or correct to the extent funds were spent. Context: The four quarterly reports did not tie to general ledger accounts used to support the grant for quarterly expenditures. The errors were not detected or amended by year end. Questioned Cost: None Repeat Finding: No Recommendation: We recommend that the College implement procedures to obtain guidance on the high-risk grants and ensure all compliance requirements are followed. Views of Responsible Officials: The reporting standards changed during the year and the reports issued prior to the standard change were not amended. The reports prepared after the change in standards were done quarterly as required. In the future, staff will verify standards prior to preparing the report and contact the Department of Education should anything be in question. The College will amend the effected reports to have only quarterly expenditures and to properly reflect the change in expenditures approved by the Department.