Audit 51053

FY End
2022-06-30
Total Expended
$22.49M
Findings
16
Programs
11
Year: 2022 Accepted: 2023-01-25

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
50252 2022-001 Material Weakness - C
50253 2022-002 Significant Deficiency - L
50254 2022-003 Significant Deficiency - B
50255 2022-001 Material Weakness - C
50256 2022-001 Material Weakness - C
50257 2022-001 Material Weakness - C
50258 2022-002 Significant Deficiency - L
50259 2022-003 Significant Deficiency - B
626694 2022-001 Material Weakness - C
626695 2022-002 Significant Deficiency - L
626696 2022-003 Significant Deficiency - B
626697 2022-001 Material Weakness - C
626698 2022-001 Material Weakness - C
626699 2022-001 Material Weakness - C
626700 2022-002 Significant Deficiency - L
626701 2022-003 Significant Deficiency - B

Contacts

Name Title Type
FQADB5DEWZB3 Michael Graff Auditee
4405257060 Robb Rose Auditor
No contacts on file

Notes to SEFA

Title: Loan Balances Accounting Policies: The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal grant activity of Lake County Community College District d/b/a Lakeland Community College (College) under programs of the federal government for the year ended June 30, 2022. The information in the 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 (the Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the College, it is not intended to and does not present the financial position, changes in net position, or cash flows of the College. Expenditures reported in the Schedule are reported on the accrual basis of accounting, the same basis of accounting as the basic financial statements. Such expenditures are recognized following the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. The pass-through entity identifying numbers are presented where available. The College has elected not to use the 10 percent de minimis indirect cost rate to recover indirect costs as allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. Federal Direct Loan ProgramThe College participates in the Federal Direct Student Loan Program (84.268). The College originates but does not provide funding for federal direct loans (FDL). The amount presented on the schedule of expenditures of federal awards represents the value of new FDL processed by the College for the year ended June 30, 2022.

Finding Details

Assistance Listing Number, Federal Agency, and Program Name - 84.425, U.S. Department of Education, Education Stabilization Fund Federal Award Identification Number and Year - P425E203325, P425F202751 - 2021 Pass-through Entity - N/A Finding Type: Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - The College must minimize the time elapsing between the transfer of funds from the United States Treasury to the University and the disbursement of those funds, as outlined in 2 CFR Section 200.305(b). Condition - The College drew down an estimated amount for student and institutional portion prior to the funds being disbursed to students or used for allowable expenditures. Questioned Costs - There were no questioned costs identified. Identification of How Questioned Costs Were Computed - N/A Context - In November 2021, the College drew down $5,882,052 for the Student Aid portion and $5,622,717 for the Institutional Aid portion, but it did not spend the funds within the required time following cash management rules under 2 CFR Section 200.305(b). Cause and Effect - The College was not aware that cash management requirements under Uniform Guidance applied to these programs, which resulted in an excess of funds drawn down. Recommendation - We recommend the College implement a process to ensure that minimizes the time elapsed between the transfer of funds from the United States Treasury to the College and the disbursement of those funds. Views of Responsible Officials and Corrective Action Plan - The College reviewed its cash management policies and corrected accounting procedures are in effect December 22, 2022. Please note that the College was unaware of this requirement; in that regard, it should be recognized that College financial executives consistently and frequently met with their Ohio community college peers, including Ohio Attorney General Office staff, to understand and interpret the evolution of federal rules and guidelines for these federally designated institutional and student awards.
Assistance Listing Number, Federal Agency, and Program Name - 84.425, U.S. Department of Education, Education Stabalization Fund Federal Award Identification Number and Year - P425E203325 - Various Pass-through Entity - N/A Finding Type: Significant Deficiency Repeat Finding - No Criteria - 2 CFR 200.302(a) indicates that a non-federal entity's financial management system includes records documenting compliance with Federal statutes, regulations must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. 2 CFR 200.303(a) requires non-federal entities to 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. And 2 CFR 200.334 requires that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Condition - The College did not retain underlying support related to the student emergency grants information reported by the College on the annual and quarterly reporting. Questioned Costs - There were no questioned costs identified. Identification of How Questioned Costs Were Computed - N/A Context: The quarterly student reports were posted to the College's website for each quarter in fiscal year 2022 and the annual report covering the period from January 1, 2021 through December 31, 2021 was submitted to the Department of Education. However, the College did not maintain the supporting documents for the information reported. Cause and Effect - The College's processes and controls were not designed effectively in order to ensure appropriate record retention related to reporting completed throughout the year. The failure to establish an effective internal control led to the inabiltiy to provide supporting documentation for key information reported during the year. Recommendation - We recommend the College retains underlying supporting records used to substantiate reporting for the timeframe required by the regulations, as stated above. Views of Responsible Officials and Corrective Action Plan - Support used for reporting will be retained for all future reports moving forward including the fourth quarter 2022 report and the 2022 annual report.
Assistance Listing Number, Federal Agency, and Program Name - 84.425, U.S. Department of Education, Education Stabalization Fund Federal Award Identification Number and Year - P425E203325, Various Pass-through Entity - N/A Finding Type: Significant Deficiency Repeat Finding - No Criteria - Expenditures are required to be reported on the Schedule of Expenditures of Federal Awards (SEFA) according to the basis of accounting followed by the nonfederal entity, per 2 CFR 200.502(a) and in accordance with the cost principles that the program is subject to (2 CFR 200, Subpart E). Condition - The College reported $593,703 of expenditures on the SEFA for disbursements to students that occurred prior to July 1, 2021. This treatment is not in accordance with the accrual basis of accounting following generally accepted accounting principles (GAAP), which is the basis of accounting for the College's SEFA. Questioned Costs - There were no questioned costs identified. Identification of How Questioned Costs Were Computed - Although the expenditures identified were not reported in the appropriate period for the purposes of the SEFA, based on audit procedures performed, they were still within the period of performance for the award. Context - Amounts that were disbursed to students in June 2021 as emergency grants under the Student Portion of the award for summer term were incorrectly not captured on the June 30, 2021 SEFA. These amounts were reported on the June 30, 2022 SEFA. Because they were not captured in the appropriate period, the College concluded to report them on the 2022 SEFA in order to ensure that the expenditures were subject to audit. Cause and Effect - Instead of the College accumulating the total expenditures by disbursement date, management accumulated the total expenditures by academic term. This resulted in a certain expenditures being reported on the SEFA in the incorrect period. Recommendation - We recommend that the College establish controls to ensure appropriate cutoff for SEFA reporting purposes. Views of Responsible Officials and Corrective Action Plan - The College will review its practices for SEFA reporting and in the future follow U.S. GAAP and the uniform guidance.
Assistance Listing Number, Federal Agency, and Program Name - 84.425, U.S. Department of Education, Education Stabilization Fund Federal Award Identification Number and Year - P425E203325, P425F202751 - 2021 Pass-through Entity - N/A Finding Type: Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - The College must minimize the time elapsing between the transfer of funds from the United States Treasury to the University and the disbursement of those funds, as outlined in 2 CFR Section 200.305(b). Condition - The College drew down an estimated amount for student and institutional portion prior to the funds being disbursed to students or used for allowable expenditures. Questioned Costs - There were no questioned costs identified. Identification of How Questioned Costs Were Computed - N/A Context - In November 2021, the College drew down $5,882,052 for the Student Aid portion and $5,622,717 for the Institutional Aid portion, but it did not spend the funds within the required time following cash management rules under 2 CFR Section 200.305(b). Cause and Effect - The College was not aware that cash management requirements under Uniform Guidance applied to these programs, which resulted in an excess of funds drawn down. Recommendation - We recommend the College implement a process to ensure that minimizes the time elapsed between the transfer of funds from the United States Treasury to the College and the disbursement of those funds. Views of Responsible Officials and Corrective Action Plan - The College reviewed its cash management policies and corrected accounting procedures are in effect December 22, 2022. Please note that the College was unaware of this requirement; in that regard, it should be recognized that College financial executives consistently and frequently met with their Ohio community college peers, including Ohio Attorney General Office staff, to understand and interpret the evolution of federal rules and guidelines for these federally designated institutional and student awards.
Assistance Listing Number, Federal Agency, and Program Name - 84.425, U.S. Department of Education, Education Stabilization Fund Federal Award Identification Number and Year - P425E203325, P425F202751 - 2021 Pass-through Entity - N/A Finding Type: Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - The College must minimize the time elapsing between the transfer of funds from the United States Treasury to the University and the disbursement of those funds, as outlined in 2 CFR Section 200.305(b). Condition - The College drew down an estimated amount for student and institutional portion prior to the funds being disbursed to students or used for allowable expenditures. Questioned Costs - There were no questioned costs identified. Identification of How Questioned Costs Were Computed - N/A Context - In November 2021, the College drew down $5,882,052 for the Student Aid portion and $5,622,717 for the Institutional Aid portion, but it did not spend the funds within the required time following cash management rules under 2 CFR Section 200.305(b). Cause and Effect - The College was not aware that cash management requirements under Uniform Guidance applied to these programs, which resulted in an excess of funds drawn down. Recommendation - We recommend the College implement a process to ensure that minimizes the time elapsed between the transfer of funds from the United States Treasury to the College and the disbursement of those funds. Views of Responsible Officials and Corrective Action Plan - The College reviewed its cash management policies and corrected accounting procedures are in effect December 22, 2022. Please note that the College was unaware of this requirement; in that regard, it should be recognized that College financial executives consistently and frequently met with their Ohio community college peers, including Ohio Attorney General Office staff, to understand and interpret the evolution of federal rules and guidelines for these federally designated institutional and student awards.
Assistance Listing Number, Federal Agency, and Program Name - 84.425, U.S. Department of Education, Education Stabilization Fund Federal Award Identification Number and Year - P425E203325, P425F202751 - 2021 Pass-through Entity - N/A Finding Type: Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - The College must minimize the time elapsing between the transfer of funds from the United States Treasury to the University and the disbursement of those funds, as outlined in 2 CFR Section 200.305(b). Condition - The College drew down an estimated amount for student and institutional portion prior to the funds being disbursed to students or used for allowable expenditures. Questioned Costs - There were no questioned costs identified. Identification of How Questioned Costs Were Computed - N/A Context - In November 2021, the College drew down $5,882,052 for the Student Aid portion and $5,622,717 for the Institutional Aid portion, but it did not spend the funds within the required time following cash management rules under 2 CFR Section 200.305(b). Cause and Effect - The College was not aware that cash management requirements under Uniform Guidance applied to these programs, which resulted in an excess of funds drawn down. Recommendation - We recommend the College implement a process to ensure that minimizes the time elapsed between the transfer of funds from the United States Treasury to the College and the disbursement of those funds. Views of Responsible Officials and Corrective Action Plan - The College reviewed its cash management policies and corrected accounting procedures are in effect December 22, 2022. Please note that the College was unaware of this requirement; in that regard, it should be recognized that College financial executives consistently and frequently met with their Ohio community college peers, including Ohio Attorney General Office staff, to understand and interpret the evolution of federal rules and guidelines for these federally designated institutional and student awards.
Assistance Listing Number, Federal Agency, and Program Name - 84.425, U.S. Department of Education, Education Stabalization Fund Federal Award Identification Number and Year - P425E203325 - Various Pass-through Entity - N/A Finding Type: Significant Deficiency Repeat Finding - No Criteria - 2 CFR 200.302(a) indicates that a non-federal entity's financial management system includes records documenting compliance with Federal statutes, regulations must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. 2 CFR 200.303(a) requires non-federal entities to 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. And 2 CFR 200.334 requires that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Condition - The College did not retain underlying support related to the student emergency grants information reported by the College on the annual and quarterly reporting. Questioned Costs - There were no questioned costs identified. Identification of How Questioned Costs Were Computed - N/A Context: The quarterly student reports were posted to the College's website for each quarter in fiscal year 2022 and the annual report covering the period from January 1, 2021 through December 31, 2021 was submitted to the Department of Education. However, the College did not maintain the supporting documents for the information reported. Cause and Effect - The College's processes and controls were not designed effectively in order to ensure appropriate record retention related to reporting completed throughout the year. The failure to establish an effective internal control led to the inabiltiy to provide supporting documentation for key information reported during the year. Recommendation - We recommend the College retains underlying supporting records used to substantiate reporting for the timeframe required by the regulations, as stated above. Views of Responsible Officials and Corrective Action Plan - Support used for reporting will be retained for all future reports moving forward including the fourth quarter 2022 report and the 2022 annual report.
Assistance Listing Number, Federal Agency, and Program Name - 84.425, U.S. Department of Education, Education Stabalization Fund Federal Award Identification Number and Year - P425E203325, Various Pass-through Entity - N/A Finding Type: Significant Deficiency Repeat Finding - No Criteria - Expenditures are required to be reported on the Schedule of Expenditures of Federal Awards (SEFA) according to the basis of accounting followed by the nonfederal entity, per 2 CFR 200.502(a) and in accordance with the cost principles that the program is subject to (2 CFR 200, Subpart E). Condition - The College reported $593,703 of expenditures on the SEFA for disbursements to students that occurred prior to July 1, 2021. This treatment is not in accordance with the accrual basis of accounting following generally accepted accounting principles (GAAP), which is the basis of accounting for the College's SEFA. Questioned Costs - There were no questioned costs identified. Identification of How Questioned Costs Were Computed - Although the expenditures identified were not reported in the appropriate period for the purposes of the SEFA, based on audit procedures performed, they were still within the period of performance for the award. Context - Amounts that were disbursed to students in June 2021 as emergency grants under the Student Portion of the award for summer term were incorrectly not captured on the June 30, 2021 SEFA. These amounts were reported on the June 30, 2022 SEFA. Because they were not captured in the appropriate period, the College concluded to report them on the 2022 SEFA in order to ensure that the expenditures were subject to audit. Cause and Effect - Instead of the College accumulating the total expenditures by disbursement date, management accumulated the total expenditures by academic term. This resulted in a certain expenditures being reported on the SEFA in the incorrect period. Recommendation - We recommend that the College establish controls to ensure appropriate cutoff for SEFA reporting purposes. Views of Responsible Officials and Corrective Action Plan - The College will review its practices for SEFA reporting and in the future follow U.S. GAAP and the uniform guidance.
Assistance Listing Number, Federal Agency, and Program Name - 84.425, U.S. Department of Education, Education Stabilization Fund Federal Award Identification Number and Year - P425E203325, P425F202751 - 2021 Pass-through Entity - N/A Finding Type: Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - The College must minimize the time elapsing between the transfer of funds from the United States Treasury to the University and the disbursement of those funds, as outlined in 2 CFR Section 200.305(b). Condition - The College drew down an estimated amount for student and institutional portion prior to the funds being disbursed to students or used for allowable expenditures. Questioned Costs - There were no questioned costs identified. Identification of How Questioned Costs Were Computed - N/A Context - In November 2021, the College drew down $5,882,052 for the Student Aid portion and $5,622,717 for the Institutional Aid portion, but it did not spend the funds within the required time following cash management rules under 2 CFR Section 200.305(b). Cause and Effect - The College was not aware that cash management requirements under Uniform Guidance applied to these programs, which resulted in an excess of funds drawn down. Recommendation - We recommend the College implement a process to ensure that minimizes the time elapsed between the transfer of funds from the United States Treasury to the College and the disbursement of those funds. Views of Responsible Officials and Corrective Action Plan - The College reviewed its cash management policies and corrected accounting procedures are in effect December 22, 2022. Please note that the College was unaware of this requirement; in that regard, it should be recognized that College financial executives consistently and frequently met with their Ohio community college peers, including Ohio Attorney General Office staff, to understand and interpret the evolution of federal rules and guidelines for these federally designated institutional and student awards.
Assistance Listing Number, Federal Agency, and Program Name - 84.425, U.S. Department of Education, Education Stabalization Fund Federal Award Identification Number and Year - P425E203325 - Various Pass-through Entity - N/A Finding Type: Significant Deficiency Repeat Finding - No Criteria - 2 CFR 200.302(a) indicates that a non-federal entity's financial management system includes records documenting compliance with Federal statutes, regulations must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. 2 CFR 200.303(a) requires non-federal entities to 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. And 2 CFR 200.334 requires that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Condition - The College did not retain underlying support related to the student emergency grants information reported by the College on the annual and quarterly reporting. Questioned Costs - There were no questioned costs identified. Identification of How Questioned Costs Were Computed - N/A Context: The quarterly student reports were posted to the College's website for each quarter in fiscal year 2022 and the annual report covering the period from January 1, 2021 through December 31, 2021 was submitted to the Department of Education. However, the College did not maintain the supporting documents for the information reported. Cause and Effect - The College's processes and controls were not designed effectively in order to ensure appropriate record retention related to reporting completed throughout the year. The failure to establish an effective internal control led to the inabiltiy to provide supporting documentation for key information reported during the year. Recommendation - We recommend the College retains underlying supporting records used to substantiate reporting for the timeframe required by the regulations, as stated above. Views of Responsible Officials and Corrective Action Plan - Support used for reporting will be retained for all future reports moving forward including the fourth quarter 2022 report and the 2022 annual report.
Assistance Listing Number, Federal Agency, and Program Name - 84.425, U.S. Department of Education, Education Stabalization Fund Federal Award Identification Number and Year - P425E203325, Various Pass-through Entity - N/A Finding Type: Significant Deficiency Repeat Finding - No Criteria - Expenditures are required to be reported on the Schedule of Expenditures of Federal Awards (SEFA) according to the basis of accounting followed by the nonfederal entity, per 2 CFR 200.502(a) and in accordance with the cost principles that the program is subject to (2 CFR 200, Subpart E). Condition - The College reported $593,703 of expenditures on the SEFA for disbursements to students that occurred prior to July 1, 2021. This treatment is not in accordance with the accrual basis of accounting following generally accepted accounting principles (GAAP), which is the basis of accounting for the College's SEFA. Questioned Costs - There were no questioned costs identified. Identification of How Questioned Costs Were Computed - Although the expenditures identified were not reported in the appropriate period for the purposes of the SEFA, based on audit procedures performed, they were still within the period of performance for the award. Context - Amounts that were disbursed to students in June 2021 as emergency grants under the Student Portion of the award for summer term were incorrectly not captured on the June 30, 2021 SEFA. These amounts were reported on the June 30, 2022 SEFA. Because they were not captured in the appropriate period, the College concluded to report them on the 2022 SEFA in order to ensure that the expenditures were subject to audit. Cause and Effect - Instead of the College accumulating the total expenditures by disbursement date, management accumulated the total expenditures by academic term. This resulted in a certain expenditures being reported on the SEFA in the incorrect period. Recommendation - We recommend that the College establish controls to ensure appropriate cutoff for SEFA reporting purposes. Views of Responsible Officials and Corrective Action Plan - The College will review its practices for SEFA reporting and in the future follow U.S. GAAP and the uniform guidance.
Assistance Listing Number, Federal Agency, and Program Name - 84.425, U.S. Department of Education, Education Stabilization Fund Federal Award Identification Number and Year - P425E203325, P425F202751 - 2021 Pass-through Entity - N/A Finding Type: Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - The College must minimize the time elapsing between the transfer of funds from the United States Treasury to the University and the disbursement of those funds, as outlined in 2 CFR Section 200.305(b). Condition - The College drew down an estimated amount for student and institutional portion prior to the funds being disbursed to students or used for allowable expenditures. Questioned Costs - There were no questioned costs identified. Identification of How Questioned Costs Were Computed - N/A Context - In November 2021, the College drew down $5,882,052 for the Student Aid portion and $5,622,717 for the Institutional Aid portion, but it did not spend the funds within the required time following cash management rules under 2 CFR Section 200.305(b). Cause and Effect - The College was not aware that cash management requirements under Uniform Guidance applied to these programs, which resulted in an excess of funds drawn down. Recommendation - We recommend the College implement a process to ensure that minimizes the time elapsed between the transfer of funds from the United States Treasury to the College and the disbursement of those funds. Views of Responsible Officials and Corrective Action Plan - The College reviewed its cash management policies and corrected accounting procedures are in effect December 22, 2022. Please note that the College was unaware of this requirement; in that regard, it should be recognized that College financial executives consistently and frequently met with their Ohio community college peers, including Ohio Attorney General Office staff, to understand and interpret the evolution of federal rules and guidelines for these federally designated institutional and student awards.
Assistance Listing Number, Federal Agency, and Program Name - 84.425, U.S. Department of Education, Education Stabilization Fund Federal Award Identification Number and Year - P425E203325, P425F202751 - 2021 Pass-through Entity - N/A Finding Type: Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - The College must minimize the time elapsing between the transfer of funds from the United States Treasury to the University and the disbursement of those funds, as outlined in 2 CFR Section 200.305(b). Condition - The College drew down an estimated amount for student and institutional portion prior to the funds being disbursed to students or used for allowable expenditures. Questioned Costs - There were no questioned costs identified. Identification of How Questioned Costs Were Computed - N/A Context - In November 2021, the College drew down $5,882,052 for the Student Aid portion and $5,622,717 for the Institutional Aid portion, but it did not spend the funds within the required time following cash management rules under 2 CFR Section 200.305(b). Cause and Effect - The College was not aware that cash management requirements under Uniform Guidance applied to these programs, which resulted in an excess of funds drawn down. Recommendation - We recommend the College implement a process to ensure that minimizes the time elapsed between the transfer of funds from the United States Treasury to the College and the disbursement of those funds. Views of Responsible Officials and Corrective Action Plan - The College reviewed its cash management policies and corrected accounting procedures are in effect December 22, 2022. Please note that the College was unaware of this requirement; in that regard, it should be recognized that College financial executives consistently and frequently met with their Ohio community college peers, including Ohio Attorney General Office staff, to understand and interpret the evolution of federal rules and guidelines for these federally designated institutional and student awards.
Assistance Listing Number, Federal Agency, and Program Name - 84.425, U.S. Department of Education, Education Stabilization Fund Federal Award Identification Number and Year - P425E203325, P425F202751 - 2021 Pass-through Entity - N/A Finding Type: Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - The College must minimize the time elapsing between the transfer of funds from the United States Treasury to the University and the disbursement of those funds, as outlined in 2 CFR Section 200.305(b). Condition - The College drew down an estimated amount for student and institutional portion prior to the funds being disbursed to students or used for allowable expenditures. Questioned Costs - There were no questioned costs identified. Identification of How Questioned Costs Were Computed - N/A Context - In November 2021, the College drew down $5,882,052 for the Student Aid portion and $5,622,717 for the Institutional Aid portion, but it did not spend the funds within the required time following cash management rules under 2 CFR Section 200.305(b). Cause and Effect - The College was not aware that cash management requirements under Uniform Guidance applied to these programs, which resulted in an excess of funds drawn down. Recommendation - We recommend the College implement a process to ensure that minimizes the time elapsed between the transfer of funds from the United States Treasury to the College and the disbursement of those funds. Views of Responsible Officials and Corrective Action Plan - The College reviewed its cash management policies and corrected accounting procedures are in effect December 22, 2022. Please note that the College was unaware of this requirement; in that regard, it should be recognized that College financial executives consistently and frequently met with their Ohio community college peers, including Ohio Attorney General Office staff, to understand and interpret the evolution of federal rules and guidelines for these federally designated institutional and student awards.
Assistance Listing Number, Federal Agency, and Program Name - 84.425, U.S. Department of Education, Education Stabalization Fund Federal Award Identification Number and Year - P425E203325 - Various Pass-through Entity - N/A Finding Type: Significant Deficiency Repeat Finding - No Criteria - 2 CFR 200.302(a) indicates that a non-federal entity's financial management system includes records documenting compliance with Federal statutes, regulations must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. 2 CFR 200.303(a) requires non-federal entities to 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. And 2 CFR 200.334 requires that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Condition - The College did not retain underlying support related to the student emergency grants information reported by the College on the annual and quarterly reporting. Questioned Costs - There were no questioned costs identified. Identification of How Questioned Costs Were Computed - N/A Context: The quarterly student reports were posted to the College's website for each quarter in fiscal year 2022 and the annual report covering the period from January 1, 2021 through December 31, 2021 was submitted to the Department of Education. However, the College did not maintain the supporting documents for the information reported. Cause and Effect - The College's processes and controls were not designed effectively in order to ensure appropriate record retention related to reporting completed throughout the year. The failure to establish an effective internal control led to the inabiltiy to provide supporting documentation for key information reported during the year. Recommendation - We recommend the College retains underlying supporting records used to substantiate reporting for the timeframe required by the regulations, as stated above. Views of Responsible Officials and Corrective Action Plan - Support used for reporting will be retained for all future reports moving forward including the fourth quarter 2022 report and the 2022 annual report.
Assistance Listing Number, Federal Agency, and Program Name - 84.425, U.S. Department of Education, Education Stabalization Fund Federal Award Identification Number and Year - P425E203325, Various Pass-through Entity - N/A Finding Type: Significant Deficiency Repeat Finding - No Criteria - Expenditures are required to be reported on the Schedule of Expenditures of Federal Awards (SEFA) according to the basis of accounting followed by the nonfederal entity, per 2 CFR 200.502(a) and in accordance with the cost principles that the program is subject to (2 CFR 200, Subpart E). Condition - The College reported $593,703 of expenditures on the SEFA for disbursements to students that occurred prior to July 1, 2021. This treatment is not in accordance with the accrual basis of accounting following generally accepted accounting principles (GAAP), which is the basis of accounting for the College's SEFA. Questioned Costs - There were no questioned costs identified. Identification of How Questioned Costs Were Computed - Although the expenditures identified were not reported in the appropriate period for the purposes of the SEFA, based on audit procedures performed, they were still within the period of performance for the award. Context - Amounts that were disbursed to students in June 2021 as emergency grants under the Student Portion of the award for summer term were incorrectly not captured on the June 30, 2021 SEFA. These amounts were reported on the June 30, 2022 SEFA. Because they were not captured in the appropriate period, the College concluded to report them on the 2022 SEFA in order to ensure that the expenditures were subject to audit. Cause and Effect - Instead of the College accumulating the total expenditures by disbursement date, management accumulated the total expenditures by academic term. This resulted in a certain expenditures being reported on the SEFA in the incorrect period. Recommendation - We recommend that the College establish controls to ensure appropriate cutoff for SEFA reporting purposes. Views of Responsible Officials and Corrective Action Plan - The College will review its practices for SEFA reporting and in the future follow U.S. GAAP and the uniform guidance.