2022 ? 003: Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Name: Rural Business Development Grant Assistance Listing Number: 10.351 Federal Award Identification Number and Year: Borrower ID: 32-087-295542779 - Year Ended June 30, 2022 Award Period: 7/1/2021 ? 6/30/2022 ____________________________________________________ Federal Agency: U.S. Department of Interior Federal Program Name: Assistance to Tribally Controlled Community Colleges and Universities Assistance Listing Number: 15.027 Federal Award Identification Number and Year: A19AP00124 ? Year Ended June 30, 2022 Award Period: 7/1/2019 ? 6/30/2024 ____________________________________________________ Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425K Federal Award Identification Number and Year: P425K200020-20B -Year Ended June 30, 2022 Award Period: 05/28/2020 ? 06/30/2024 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: The College had not established a policy or an effective internal control system related to the grant agreements and the Procurement, Suspension, and Debarment compliance requirement. The College?s current procurement policy does not include a documented process to ensure vendors meet suspension and debarment requirements. In addition, there was no documentation that the Authority had searched all applicable vendors on the System for Award Management (SAM) to ensure that the College?s vendors were not suspended or debarred. Questioned costs: None Context: Procurement policies were followed, but no documented process to ensure suspension and debarment noted. Cause: The current policy and internal control structure does not include a process for ensuring suspension and debarment requirements are met for all required vendors. Effect: The College may contract with or make subawards under covered transactions to parties that are suspended or debarred. Repeat Finding: No Recommendation: The College should consider updating their current procurement policy to include suspension and debarment processes and implement appropriate internal controls to ensure the processes are followed. Views of responsible officials: The College agrees with the auditor?s comments and has taken corrective action to ensure suspension and debarment consideration is added to policies and procedures.
2022 ? 002: Allowable Indirect Costs Federal Agency: U.S. Department of Interior Federal Program Name: Assistance to Tribally Controlled Community Colleges and Universities Assistance Listing Number: 15.027 Federal Award Identification Number and Year: A19AP00124 ? Year Ended June 30, 2022 Award Period: 7/1/2019 ? 6/30/2024 ____________________________________________________ Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425K Federal Award Identification Number and Year: P425K200020-20B ? Year Ended June 30, 2022 Award Period: 05/28/2020 ? 06/30/2024 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Material Noncompliance (Modified Opinion) Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Indirect costs should be calculated based on modified total direct costs excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs and the portion of each subaward in excess of $25,000, as stipulated by the College?s approved indirect cost rate agreement. Condition: The College applied their indirect cost rate to all direct costs of the Programs including tuition remission, scholarships, and payments to students. Questioned costs: The questioned costs have been calculated based on the recalculation of modified total direct costs multiplied by the College?s negotiated indirect cost rate. The known questioned costs for 15.027 totals $148,287. The known questioned costs for 84.425K totals $263,299. Context: As a part of the audit of allowable costs and activities, it was noted that the College was not appropriately calculating the indirect costs to be charged to the federal program in accordance with the stated criteria. Cause: The College did not appropriately calculate the modified total direct costs in accordance with the stated criteria. Effect: The College claimed indirect costs in excess of what would be allowed by the stated criteria. Repeat Finding: No Recommendation: We recommend that the College develop a process and internal controls that will mitigate the risk of incorrectly calculating the indirect costs to be charged to federal programs. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 003: Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Name: Rural Business Development Grant Assistance Listing Number: 10.351 Federal Award Identification Number and Year: Borrower ID: 32-087-295542779 - Year Ended June 30, 2022 Award Period: 7/1/2021 ? 6/30/2022 ____________________________________________________ Federal Agency: U.S. Department of Interior Federal Program Name: Assistance to Tribally Controlled Community Colleges and Universities Assistance Listing Number: 15.027 Federal Award Identification Number and Year: A19AP00124 ? Year Ended June 30, 2022 Award Period: 7/1/2019 ? 6/30/2024 ____________________________________________________ Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425K Federal Award Identification Number and Year: P425K200020-20B -Year Ended June 30, 2022 Award Period: 05/28/2020 ? 06/30/2024 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: The College had not established a policy or an effective internal control system related to the grant agreements and the Procurement, Suspension, and Debarment compliance requirement. The College?s current procurement policy does not include a documented process to ensure vendors meet suspension and debarment requirements. In addition, there was no documentation that the Authority had searched all applicable vendors on the System for Award Management (SAM) to ensure that the College?s vendors were not suspended or debarred. Questioned costs: None Context: Procurement policies were followed, but no documented process to ensure suspension and debarment noted. Cause: The current policy and internal control structure does not include a process for ensuring suspension and debarment requirements are met for all required vendors. Effect: The College may contract with or make subawards under covered transactions to parties that are suspended or debarred. Repeat Finding: No Recommendation: The College should consider updating their current procurement policy to include suspension and debarment processes and implement appropriate internal controls to ensure the processes are followed. Views of responsible officials: The College agrees with the auditor?s comments and has taken corrective action to ensure suspension and debarment consideration is added to policies and procedures.
2022 ? 004: Program Income - Federal Agency: U.S. Department of Interior Federal Program Name: Assistance to Tribally Controlled Community Colleges and Universities Assistance Listing Number: 15.027 Federal Award Identification Number and Year: A19AP00124 ? Year Ended June 30, 2022 Award Period: 7/1/2019 ? 6/30/2024 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). If interest in excess of $500 per year is earned on federal cash draws, the College is required to consider annual remittance to the granting agency in absence of other direction from the granting agency. Condition: The College has taken advance draws from the granting agency without incurring qualifying expenditures. These advance draws are reported as unearned revenues in the College?s financial statements in the amount originally drawn. Interest being earned on these funds have not been remitted to the granting agency. Questioned costs: None Context: As part of the audit of the College?s cash management process, it was noted that the College was not appropriately tracking and remitting program income being earned on advance draws in accordance with compliance requirements. Cause: The College did not appropriately track and remit program income earned on advance draws. Effect: The College earned interest income that was not appropriately tracked or remitted back to the granting agency. Repeat Finding: No Recommendation: We recommend that the College develop a process and internal controls to draw federal funds when qualifying expenditures have been incurred or scheduled to be incurred. We recommend that the College develop a process and internal controls to track program income earned when funds are drawn in advance of qualifying expenditures being incurred or scheduled to be incurred. Views of responsible officials: The College agrees with the auditor?s comments and has taken corrective action to ensure program income and cash management consideration is added to policies and procedures.
2022 ? 002: Allowable Indirect Costs Federal Agency: U.S. Department of Interior Federal Program Name: Assistance to Tribally Controlled Community Colleges and Universities Assistance Listing Number: 15.027 Federal Award Identification Number and Year: A19AP00124 ? Year Ended June 30, 2022 Award Period: 7/1/2019 ? 6/30/2024 ____________________________________________________ Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425K Federal Award Identification Number and Year: P425K200020-20B ? Year Ended June 30, 2022 Award Period: 05/28/2020 ? 06/30/2024 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Material Noncompliance (Modified Opinion) Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Indirect costs should be calculated based on modified total direct costs excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs and the portion of each subaward in excess of $25,000, as stipulated by the College?s approved indirect cost rate agreement. Condition: The College applied their indirect cost rate to all direct costs of the Programs including tuition remission, scholarships, and payments to students. Questioned costs: The questioned costs have been calculated based on the recalculation of modified total direct costs multiplied by the College?s negotiated indirect cost rate. The known questioned costs for 15.027 totals $148,287. The known questioned costs for 84.425K totals $263,299. Context: As a part of the audit of allowable costs and activities, it was noted that the College was not appropriately calculating the indirect costs to be charged to the federal program in accordance with the stated criteria. Cause: The College did not appropriately calculate the modified total direct costs in accordance with the stated criteria. Effect: The College claimed indirect costs in excess of what would be allowed by the stated criteria. Repeat Finding: No Recommendation: We recommend that the College develop a process and internal controls that will mitigate the risk of incorrectly calculating the indirect costs to be charged to federal programs. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 003: Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Name: Rural Business Development Grant Assistance Listing Number: 10.351 Federal Award Identification Number and Year: Borrower ID: 32-087-295542779 - Year Ended June 30, 2022 Award Period: 7/1/2021 ? 6/30/2022 ____________________________________________________ Federal Agency: U.S. Department of Interior Federal Program Name: Assistance to Tribally Controlled Community Colleges and Universities Assistance Listing Number: 15.027 Federal Award Identification Number and Year: A19AP00124 ? Year Ended June 30, 2022 Award Period: 7/1/2019 ? 6/30/2024 ____________________________________________________ Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425K Federal Award Identification Number and Year: P425K200020-20B -Year Ended June 30, 2022 Award Period: 05/28/2020 ? 06/30/2024 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: The College had not established a policy or an effective internal control system related to the grant agreements and the Procurement, Suspension, and Debarment compliance requirement. The College?s current procurement policy does not include a documented process to ensure vendors meet suspension and debarment requirements. In addition, there was no documentation that the Authority had searched all applicable vendors on the System for Award Management (SAM) to ensure that the College?s vendors were not suspended or debarred. Questioned costs: None Context: Procurement policies were followed, but no documented process to ensure suspension and debarment noted. Cause: The current policy and internal control structure does not include a process for ensuring suspension and debarment requirements are met for all required vendors. Effect: The College may contract with or make subawards under covered transactions to parties that are suspended or debarred. Repeat Finding: No Recommendation: The College should consider updating their current procurement policy to include suspension and debarment processes and implement appropriate internal controls to ensure the processes are followed. Views of responsible officials: The College agrees with the auditor?s comments and has taken corrective action to ensure suspension and debarment consideration is added to policies and procedures.
2022 ? 004: Program Income - Federal Agency: U.S. Department of Interior Federal Program Name: Assistance to Tribally Controlled Community Colleges and Universities Assistance Listing Number: 15.027 Federal Award Identification Number and Year: A19AP00124 ? Year Ended June 30, 2022 Award Period: 7/1/2019 ? 6/30/2024 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). If interest in excess of $500 per year is earned on federal cash draws, the College is required to consider annual remittance to the granting agency in absence of other direction from the granting agency. Condition: The College has taken advance draws from the granting agency without incurring qualifying expenditures. These advance draws are reported as unearned revenues in the College?s financial statements in the amount originally drawn. Interest being earned on these funds have not been remitted to the granting agency. Questioned costs: None Context: As part of the audit of the College?s cash management process, it was noted that the College was not appropriately tracking and remitting program income being earned on advance draws in accordance with compliance requirements. Cause: The College did not appropriately track and remit program income earned on advance draws. Effect: The College earned interest income that was not appropriately tracked or remitted back to the granting agency. Repeat Finding: No Recommendation: We recommend that the College develop a process and internal controls to draw federal funds when qualifying expenditures have been incurred or scheduled to be incurred. We recommend that the College develop a process and internal controls to track program income earned when funds are drawn in advance of qualifying expenditures being incurred or scheduled to be incurred. Views of responsible officials: The College agrees with the auditor?s comments and has taken corrective action to ensure program income and cash management consideration is added to policies and procedures.
2022 ? 003: Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Name: Rural Business Development Grant Assistance Listing Number: 10.351 Federal Award Identification Number and Year: Borrower ID: 32-087-295542779 - Year Ended June 30, 2022 Award Period: 7/1/2021 ? 6/30/2022 ____________________________________________________ Federal Agency: U.S. Department of Interior Federal Program Name: Assistance to Tribally Controlled Community Colleges and Universities Assistance Listing Number: 15.027 Federal Award Identification Number and Year: A19AP00124 ? Year Ended June 30, 2022 Award Period: 7/1/2019 ? 6/30/2024 ____________________________________________________ Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425K Federal Award Identification Number and Year: P425K200020-20B -Year Ended June 30, 2022 Award Period: 05/28/2020 ? 06/30/2024 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: The College had not established a policy or an effective internal control system related to the grant agreements and the Procurement, Suspension, and Debarment compliance requirement. The College?s current procurement policy does not include a documented process to ensure vendors meet suspension and debarment requirements. In addition, there was no documentation that the Authority had searched all applicable vendors on the System for Award Management (SAM) to ensure that the College?s vendors were not suspended or debarred. Questioned costs: None Context: Procurement policies were followed, but no documented process to ensure suspension and debarment noted. Cause: The current policy and internal control structure does not include a process for ensuring suspension and debarment requirements are met for all required vendors. Effect: The College may contract with or make subawards under covered transactions to parties that are suspended or debarred. Repeat Finding: No Recommendation: The College should consider updating their current procurement policy to include suspension and debarment processes and implement appropriate internal controls to ensure the processes are followed. Views of responsible officials: The College agrees with the auditor?s comments and has taken corrective action to ensure suspension and debarment consideration is added to policies and procedures.
2022 ? 002: Allowable Indirect Costs Federal Agency: U.S. Department of Interior Federal Program Name: Assistance to Tribally Controlled Community Colleges and Universities Assistance Listing Number: 15.027 Federal Award Identification Number and Year: A19AP00124 ? Year Ended June 30, 2022 Award Period: 7/1/2019 ? 6/30/2024 ____________________________________________________ Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425K Federal Award Identification Number and Year: P425K200020-20B ? Year Ended June 30, 2022 Award Period: 05/28/2020 ? 06/30/2024 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Material Noncompliance (Modified Opinion) Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Indirect costs should be calculated based on modified total direct costs excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs and the portion of each subaward in excess of $25,000, as stipulated by the College?s approved indirect cost rate agreement. Condition: The College applied their indirect cost rate to all direct costs of the Programs including tuition remission, scholarships, and payments to students. Questioned costs: The questioned costs have been calculated based on the recalculation of modified total direct costs multiplied by the College?s negotiated indirect cost rate. The known questioned costs for 15.027 totals $148,287. The known questioned costs for 84.425K totals $263,299. Context: As a part of the audit of allowable costs and activities, it was noted that the College was not appropriately calculating the indirect costs to be charged to the federal program in accordance with the stated criteria. Cause: The College did not appropriately calculate the modified total direct costs in accordance with the stated criteria. Effect: The College claimed indirect costs in excess of what would be allowed by the stated criteria. Repeat Finding: No Recommendation: We recommend that the College develop a process and internal controls that will mitigate the risk of incorrectly calculating the indirect costs to be charged to federal programs. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 005: Reporting - Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425E & F Federal Award Identification Number and Year: P425K200020-20B -Year Ended June 30, 2022 Award Period: 05/28/2020 ? 06/30/2024 ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). An institution is required to publicly post its Quarterly Reporting Form for the Student (84.425E) and Institutional (84.425F) funding within ten (10) days of the end of the quarter. Annual reporting for all fund expended January 1, 2021 through December 31, 2021 was due May 6, 2022 Condition: The College did not maintain supporting documentation to illustrate timely posting of its quarterly reports. The annual report was submitted on May 9, 2022. Questioned costs: None Context: During our audit of the reporting requirements, submission of quarterly and annual reports was completed in accordance with the required deadlines. Cause: The College did not submit its quarterly and annual reports prior to the reporting deadlines. Effect: The College published quarterly reports after ten (10) days after the end of the quarter. The annual report was completed after the May 6, 2022 deadline. Repeat Finding: No Recommendation: We recommend that the College develop a process and internal controls to ensure timely publication and submission of required reports and maintain supporting documentation to verify compliance. Views of responsible officials: The College agrees with the auditor?s comments and has taken corrective action to ensure reporting consideration is added to policies and procedures.
2022 ? 002: Allowable Indirect Costs Federal Agency: U.S. Department of Interior Federal Program Name: Assistance to Tribally Controlled Community Colleges and Universities Assistance Listing Number: 15.027 Federal Award Identification Number and Year: A19AP00124 ? Year Ended June 30, 2022 Award Period: 7/1/2019 ? 6/30/2024 ____________________________________________________ Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425K Federal Award Identification Number and Year: P425K200020-20B ? Year Ended June 30, 2022 Award Period: 05/28/2020 ? 06/30/2024 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Material Noncompliance (Modified Opinion) Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Indirect costs should be calculated based on modified total direct costs excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs and the portion of each subaward in excess of $25,000, as stipulated by the College?s approved indirect cost rate agreement. Condition: The College applied their indirect cost rate to all direct costs of the Programs including tuition remission, scholarships, and payments to students. Questioned costs: The questioned costs have been calculated based on the recalculation of modified total direct costs multiplied by the College?s negotiated indirect cost rate. The known questioned costs for 15.027 totals $148,287. The known questioned costs for 84.425K totals $263,299. Context: As a part of the audit of allowable costs and activities, it was noted that the College was not appropriately calculating the indirect costs to be charged to the federal program in accordance with the stated criteria. Cause: The College did not appropriately calculate the modified total direct costs in accordance with the stated criteria. Effect: The College claimed indirect costs in excess of what would be allowed by the stated criteria. Repeat Finding: No Recommendation: We recommend that the College develop a process and internal controls that will mitigate the risk of incorrectly calculating the indirect costs to be charged to federal programs. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 003: Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Name: Rural Business Development Grant Assistance Listing Number: 10.351 Federal Award Identification Number and Year: Borrower ID: 32-087-295542779 - Year Ended June 30, 2022 Award Period: 7/1/2021 ? 6/30/2022 ____________________________________________________ Federal Agency: U.S. Department of Interior Federal Program Name: Assistance to Tribally Controlled Community Colleges and Universities Assistance Listing Number: 15.027 Federal Award Identification Number and Year: A19AP00124 ? Year Ended June 30, 2022 Award Period: 7/1/2019 ? 6/30/2024 ____________________________________________________ Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425K Federal Award Identification Number and Year: P425K200020-20B -Year Ended June 30, 2022 Award Period: 05/28/2020 ? 06/30/2024 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: The College had not established a policy or an effective internal control system related to the grant agreements and the Procurement, Suspension, and Debarment compliance requirement. The College?s current procurement policy does not include a documented process to ensure vendors meet suspension and debarment requirements. In addition, there was no documentation that the Authority had searched all applicable vendors on the System for Award Management (SAM) to ensure that the College?s vendors were not suspended or debarred. Questioned costs: None Context: Procurement policies were followed, but no documented process to ensure suspension and debarment noted. Cause: The current policy and internal control structure does not include a process for ensuring suspension and debarment requirements are met for all required vendors. Effect: The College may contract with or make subawards under covered transactions to parties that are suspended or debarred. Repeat Finding: No Recommendation: The College should consider updating their current procurement policy to include suspension and debarment processes and implement appropriate internal controls to ensure the processes are followed. Views of responsible officials: The College agrees with the auditor?s comments and has taken corrective action to ensure suspension and debarment consideration is added to policies and procedures.
2022 ? 005: Reporting - Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425E & F Federal Award Identification Number and Year: P425K200020-20B -Year Ended June 30, 2022 Award Period: 05/28/2020 ? 06/30/2024 ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). An institution is required to publicly post its Quarterly Reporting Form for the Student (84.425E) and Institutional (84.425F) funding within ten (10) days of the end of the quarter. Annual reporting for all fund expended January 1, 2021 through December 31, 2021 was due May 6, 2022 Condition: The College did not maintain supporting documentation to illustrate timely posting of its quarterly reports. The annual report was submitted on May 9, 2022. Questioned costs: None Context: During our audit of the reporting requirements, submission of quarterly and annual reports was completed in accordance with the required deadlines. Cause: The College did not submit its quarterly and annual reports prior to the reporting deadlines. Effect: The College published quarterly reports after ten (10) days after the end of the quarter. The annual report was completed after the May 6, 2022 deadline. Repeat Finding: No Recommendation: We recommend that the College develop a process and internal controls to ensure timely publication and submission of required reports and maintain supporting documentation to verify compliance. Views of responsible officials: The College agrees with the auditor?s comments and has taken corrective action to ensure reporting consideration is added to policies and procedures.
2022 ? 002: Allowable Indirect Costs Federal Agency: U.S. Department of Interior Federal Program Name: Assistance to Tribally Controlled Community Colleges and Universities Assistance Listing Number: 15.027 Federal Award Identification Number and Year: A19AP00124 ? Year Ended June 30, 2022 Award Period: 7/1/2019 ? 6/30/2024 ____________________________________________________ Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425K Federal Award Identification Number and Year: P425K200020-20B ? Year Ended June 30, 2022 Award Period: 05/28/2020 ? 06/30/2024 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Material Noncompliance (Modified Opinion) Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Indirect costs should be calculated based on modified total direct costs excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs and the portion of each subaward in excess of $25,000, as stipulated by the College?s approved indirect cost rate agreement. Condition: The College applied their indirect cost rate to all direct costs of the Programs including tuition remission, scholarships, and payments to students. Questioned costs: The questioned costs have been calculated based on the recalculation of modified total direct costs multiplied by the College?s negotiated indirect cost rate. The known questioned costs for 15.027 totals $148,287. The known questioned costs for 84.425K totals $263,299. Context: As a part of the audit of allowable costs and activities, it was noted that the College was not appropriately calculating the indirect costs to be charged to the federal program in accordance with the stated criteria. Cause: The College did not appropriately calculate the modified total direct costs in accordance with the stated criteria. Effect: The College claimed indirect costs in excess of what would be allowed by the stated criteria. Repeat Finding: No Recommendation: We recommend that the College develop a process and internal controls that will mitigate the risk of incorrectly calculating the indirect costs to be charged to federal programs. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 003: Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Name: Rural Business Development Grant Assistance Listing Number: 10.351 Federal Award Identification Number and Year: Borrower ID: 32-087-295542779 - Year Ended June 30, 2022 Award Period: 7/1/2021 ? 6/30/2022 ____________________________________________________ Federal Agency: U.S. Department of Interior Federal Program Name: Assistance to Tribally Controlled Community Colleges and Universities Assistance Listing Number: 15.027 Federal Award Identification Number and Year: A19AP00124 ? Year Ended June 30, 2022 Award Period: 7/1/2019 ? 6/30/2024 ____________________________________________________ Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425K Federal Award Identification Number and Year: P425K200020-20B -Year Ended June 30, 2022 Award Period: 05/28/2020 ? 06/30/2024 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: The College had not established a policy or an effective internal control system related to the grant agreements and the Procurement, Suspension, and Debarment compliance requirement. The College?s current procurement policy does not include a documented process to ensure vendors meet suspension and debarment requirements. In addition, there was no documentation that the Authority had searched all applicable vendors on the System for Award Management (SAM) to ensure that the College?s vendors were not suspended or debarred. Questioned costs: None Context: Procurement policies were followed, but no documented process to ensure suspension and debarment noted. Cause: The current policy and internal control structure does not include a process for ensuring suspension and debarment requirements are met for all required vendors. Effect: The College may contract with or make subawards under covered transactions to parties that are suspended or debarred. Repeat Finding: No Recommendation: The College should consider updating their current procurement policy to include suspension and debarment processes and implement appropriate internal controls to ensure the processes are followed. Views of responsible officials: The College agrees with the auditor?s comments and has taken corrective action to ensure suspension and debarment consideration is added to policies and procedures.
2022 ? 005: Reporting - Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425E & F Federal Award Identification Number and Year: P425K200020-20B -Year Ended June 30, 2022 Award Period: 05/28/2020 ? 06/30/2024 ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). An institution is required to publicly post its Quarterly Reporting Form for the Student (84.425E) and Institutional (84.425F) funding within ten (10) days of the end of the quarter. Annual reporting for all fund expended January 1, 2021 through December 31, 2021 was due May 6, 2022 Condition: The College did not maintain supporting documentation to illustrate timely posting of its quarterly reports. The annual report was submitted on May 9, 2022. Questioned costs: None Context: During our audit of the reporting requirements, submission of quarterly and annual reports was completed in accordance with the required deadlines. Cause: The College did not submit its quarterly and annual reports prior to the reporting deadlines. Effect: The College published quarterly reports after ten (10) days after the end of the quarter. The annual report was completed after the May 6, 2022 deadline. Repeat Finding: No Recommendation: We recommend that the College develop a process and internal controls to ensure timely publication and submission of required reports and maintain supporting documentation to verify compliance. Views of responsible officials: The College agrees with the auditor?s comments and has taken corrective action to ensure reporting consideration is added to policies and procedures.
2022 ? 003: Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Name: Rural Business Development Grant Assistance Listing Number: 10.351 Federal Award Identification Number and Year: Borrower ID: 32-087-295542779 - Year Ended June 30, 2022 Award Period: 7/1/2021 ? 6/30/2022 ____________________________________________________ Federal Agency: U.S. Department of Interior Federal Program Name: Assistance to Tribally Controlled Community Colleges and Universities Assistance Listing Number: 15.027 Federal Award Identification Number and Year: A19AP00124 ? Year Ended June 30, 2022 Award Period: 7/1/2019 ? 6/30/2024 ____________________________________________________ Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425K Federal Award Identification Number and Year: P425K200020-20B -Year Ended June 30, 2022 Award Period: 05/28/2020 ? 06/30/2024 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: The College had not established a policy or an effective internal control system related to the grant agreements and the Procurement, Suspension, and Debarment compliance requirement. The College?s current procurement policy does not include a documented process to ensure vendors meet suspension and debarment requirements. In addition, there was no documentation that the Authority had searched all applicable vendors on the System for Award Management (SAM) to ensure that the College?s vendors were not suspended or debarred. Questioned costs: None Context: Procurement policies were followed, but no documented process to ensure suspension and debarment noted. Cause: The current policy and internal control structure does not include a process for ensuring suspension and debarment requirements are met for all required vendors. Effect: The College may contract with or make subawards under covered transactions to parties that are suspended or debarred. Repeat Finding: No Recommendation: The College should consider updating their current procurement policy to include suspension and debarment processes and implement appropriate internal controls to ensure the processes are followed. Views of responsible officials: The College agrees with the auditor?s comments and has taken corrective action to ensure suspension and debarment consideration is added to policies and procedures.
2022 ? 002: Allowable Indirect Costs Federal Agency: U.S. Department of Interior Federal Program Name: Assistance to Tribally Controlled Community Colleges and Universities Assistance Listing Number: 15.027 Federal Award Identification Number and Year: A19AP00124 ? Year Ended June 30, 2022 Award Period: 7/1/2019 ? 6/30/2024 ____________________________________________________ Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425K Federal Award Identification Number and Year: P425K200020-20B ? Year Ended June 30, 2022 Award Period: 05/28/2020 ? 06/30/2024 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Material Noncompliance (Modified Opinion) Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Indirect costs should be calculated based on modified total direct costs excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs and the portion of each subaward in excess of $25,000, as stipulated by the College?s approved indirect cost rate agreement. Condition: The College applied their indirect cost rate to all direct costs of the Programs including tuition remission, scholarships, and payments to students. Questioned costs: The questioned costs have been calculated based on the recalculation of modified total direct costs multiplied by the College?s negotiated indirect cost rate. The known questioned costs for 15.027 totals $148,287. The known questioned costs for 84.425K totals $263,299. Context: As a part of the audit of allowable costs and activities, it was noted that the College was not appropriately calculating the indirect costs to be charged to the federal program in accordance with the stated criteria. Cause: The College did not appropriately calculate the modified total direct costs in accordance with the stated criteria. Effect: The College claimed indirect costs in excess of what would be allowed by the stated criteria. Repeat Finding: No Recommendation: We recommend that the College develop a process and internal controls that will mitigate the risk of incorrectly calculating the indirect costs to be charged to federal programs. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 003: Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Name: Rural Business Development Grant Assistance Listing Number: 10.351 Federal Award Identification Number and Year: Borrower ID: 32-087-295542779 - Year Ended June 30, 2022 Award Period: 7/1/2021 ? 6/30/2022 ____________________________________________________ Federal Agency: U.S. Department of Interior Federal Program Name: Assistance to Tribally Controlled Community Colleges and Universities Assistance Listing Number: 15.027 Federal Award Identification Number and Year: A19AP00124 ? Year Ended June 30, 2022 Award Period: 7/1/2019 ? 6/30/2024 ____________________________________________________ Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425K Federal Award Identification Number and Year: P425K200020-20B -Year Ended June 30, 2022 Award Period: 05/28/2020 ? 06/30/2024 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: The College had not established a policy or an effective internal control system related to the grant agreements and the Procurement, Suspension, and Debarment compliance requirement. The College?s current procurement policy does not include a documented process to ensure vendors meet suspension and debarment requirements. In addition, there was no documentation that the Authority had searched all applicable vendors on the System for Award Management (SAM) to ensure that the College?s vendors were not suspended or debarred. Questioned costs: None Context: Procurement policies were followed, but no documented process to ensure suspension and debarment noted. Cause: The current policy and internal control structure does not include a process for ensuring suspension and debarment requirements are met for all required vendors. Effect: The College may contract with or make subawards under covered transactions to parties that are suspended or debarred. Repeat Finding: No Recommendation: The College should consider updating their current procurement policy to include suspension and debarment processes and implement appropriate internal controls to ensure the processes are followed. Views of responsible officials: The College agrees with the auditor?s comments and has taken corrective action to ensure suspension and debarment consideration is added to policies and procedures.
2022 ? 004: Program Income - Federal Agency: U.S. Department of Interior Federal Program Name: Assistance to Tribally Controlled Community Colleges and Universities Assistance Listing Number: 15.027 Federal Award Identification Number and Year: A19AP00124 ? Year Ended June 30, 2022 Award Period: 7/1/2019 ? 6/30/2024 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). If interest in excess of $500 per year is earned on federal cash draws, the College is required to consider annual remittance to the granting agency in absence of other direction from the granting agency. Condition: The College has taken advance draws from the granting agency without incurring qualifying expenditures. These advance draws are reported as unearned revenues in the College?s financial statements in the amount originally drawn. Interest being earned on these funds have not been remitted to the granting agency. Questioned costs: None Context: As part of the audit of the College?s cash management process, it was noted that the College was not appropriately tracking and remitting program income being earned on advance draws in accordance with compliance requirements. Cause: The College did not appropriately track and remit program income earned on advance draws. Effect: The College earned interest income that was not appropriately tracked or remitted back to the granting agency. Repeat Finding: No Recommendation: We recommend that the College develop a process and internal controls to draw federal funds when qualifying expenditures have been incurred or scheduled to be incurred. We recommend that the College develop a process and internal controls to track program income earned when funds are drawn in advance of qualifying expenditures being incurred or scheduled to be incurred. Views of responsible officials: The College agrees with the auditor?s comments and has taken corrective action to ensure program income and cash management consideration is added to policies and procedures.
2022 ? 002: Allowable Indirect Costs Federal Agency: U.S. Department of Interior Federal Program Name: Assistance to Tribally Controlled Community Colleges and Universities Assistance Listing Number: 15.027 Federal Award Identification Number and Year: A19AP00124 ? Year Ended June 30, 2022 Award Period: 7/1/2019 ? 6/30/2024 ____________________________________________________ Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425K Federal Award Identification Number and Year: P425K200020-20B ? Year Ended June 30, 2022 Award Period: 05/28/2020 ? 06/30/2024 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Material Noncompliance (Modified Opinion) Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Indirect costs should be calculated based on modified total direct costs excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs and the portion of each subaward in excess of $25,000, as stipulated by the College?s approved indirect cost rate agreement. Condition: The College applied their indirect cost rate to all direct costs of the Programs including tuition remission, scholarships, and payments to students. Questioned costs: The questioned costs have been calculated based on the recalculation of modified total direct costs multiplied by the College?s negotiated indirect cost rate. The known questioned costs for 15.027 totals $148,287. The known questioned costs for 84.425K totals $263,299. Context: As a part of the audit of allowable costs and activities, it was noted that the College was not appropriately calculating the indirect costs to be charged to the federal program in accordance with the stated criteria. Cause: The College did not appropriately calculate the modified total direct costs in accordance with the stated criteria. Effect: The College claimed indirect costs in excess of what would be allowed by the stated criteria. Repeat Finding: No Recommendation: We recommend that the College develop a process and internal controls that will mitigate the risk of incorrectly calculating the indirect costs to be charged to federal programs. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 003: Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Name: Rural Business Development Grant Assistance Listing Number: 10.351 Federal Award Identification Number and Year: Borrower ID: 32-087-295542779 - Year Ended June 30, 2022 Award Period: 7/1/2021 ? 6/30/2022 ____________________________________________________ Federal Agency: U.S. Department of Interior Federal Program Name: Assistance to Tribally Controlled Community Colleges and Universities Assistance Listing Number: 15.027 Federal Award Identification Number and Year: A19AP00124 ? Year Ended June 30, 2022 Award Period: 7/1/2019 ? 6/30/2024 ____________________________________________________ Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425K Federal Award Identification Number and Year: P425K200020-20B -Year Ended June 30, 2022 Award Period: 05/28/2020 ? 06/30/2024 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: The College had not established a policy or an effective internal control system related to the grant agreements and the Procurement, Suspension, and Debarment compliance requirement. The College?s current procurement policy does not include a documented process to ensure vendors meet suspension and debarment requirements. In addition, there was no documentation that the Authority had searched all applicable vendors on the System for Award Management (SAM) to ensure that the College?s vendors were not suspended or debarred. Questioned costs: None Context: Procurement policies were followed, but no documented process to ensure suspension and debarment noted. Cause: The current policy and internal control structure does not include a process for ensuring suspension and debarment requirements are met for all required vendors. Effect: The College may contract with or make subawards under covered transactions to parties that are suspended or debarred. Repeat Finding: No Recommendation: The College should consider updating their current procurement policy to include suspension and debarment processes and implement appropriate internal controls to ensure the processes are followed. Views of responsible officials: The College agrees with the auditor?s comments and has taken corrective action to ensure suspension and debarment consideration is added to policies and procedures.
2022 ? 004: Program Income - Federal Agency: U.S. Department of Interior Federal Program Name: Assistance to Tribally Controlled Community Colleges and Universities Assistance Listing Number: 15.027 Federal Award Identification Number and Year: A19AP00124 ? Year Ended June 30, 2022 Award Period: 7/1/2019 ? 6/30/2024 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). If interest in excess of $500 per year is earned on federal cash draws, the College is required to consider annual remittance to the granting agency in absence of other direction from the granting agency. Condition: The College has taken advance draws from the granting agency without incurring qualifying expenditures. These advance draws are reported as unearned revenues in the College?s financial statements in the amount originally drawn. Interest being earned on these funds have not been remitted to the granting agency. Questioned costs: None Context: As part of the audit of the College?s cash management process, it was noted that the College was not appropriately tracking and remitting program income being earned on advance draws in accordance with compliance requirements. Cause: The College did not appropriately track and remit program income earned on advance draws. Effect: The College earned interest income that was not appropriately tracked or remitted back to the granting agency. Repeat Finding: No Recommendation: We recommend that the College develop a process and internal controls to draw federal funds when qualifying expenditures have been incurred or scheduled to be incurred. We recommend that the College develop a process and internal controls to track program income earned when funds are drawn in advance of qualifying expenditures being incurred or scheduled to be incurred. Views of responsible officials: The College agrees with the auditor?s comments and has taken corrective action to ensure program income and cash management consideration is added to policies and procedures.
2022 ? 003: Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Name: Rural Business Development Grant Assistance Listing Number: 10.351 Federal Award Identification Number and Year: Borrower ID: 32-087-295542779 - Year Ended June 30, 2022 Award Period: 7/1/2021 ? 6/30/2022 ____________________________________________________ Federal Agency: U.S. Department of Interior Federal Program Name: Assistance to Tribally Controlled Community Colleges and Universities Assistance Listing Number: 15.027 Federal Award Identification Number and Year: A19AP00124 ? Year Ended June 30, 2022 Award Period: 7/1/2019 ? 6/30/2024 ____________________________________________________ Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425K Federal Award Identification Number and Year: P425K200020-20B -Year Ended June 30, 2022 Award Period: 05/28/2020 ? 06/30/2024 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: The College had not established a policy or an effective internal control system related to the grant agreements and the Procurement, Suspension, and Debarment compliance requirement. The College?s current procurement policy does not include a documented process to ensure vendors meet suspension and debarment requirements. In addition, there was no documentation that the Authority had searched all applicable vendors on the System for Award Management (SAM) to ensure that the College?s vendors were not suspended or debarred. Questioned costs: None Context: Procurement policies were followed, but no documented process to ensure suspension and debarment noted. Cause: The current policy and internal control structure does not include a process for ensuring suspension and debarment requirements are met for all required vendors. Effect: The College may contract with or make subawards under covered transactions to parties that are suspended or debarred. Repeat Finding: No Recommendation: The College should consider updating their current procurement policy to include suspension and debarment processes and implement appropriate internal controls to ensure the processes are followed. Views of responsible officials: The College agrees with the auditor?s comments and has taken corrective action to ensure suspension and debarment consideration is added to policies and procedures.
2022 ? 002: Allowable Indirect Costs Federal Agency: U.S. Department of Interior Federal Program Name: Assistance to Tribally Controlled Community Colleges and Universities Assistance Listing Number: 15.027 Federal Award Identification Number and Year: A19AP00124 ? Year Ended June 30, 2022 Award Period: 7/1/2019 ? 6/30/2024 ____________________________________________________ Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425K Federal Award Identification Number and Year: P425K200020-20B ? Year Ended June 30, 2022 Award Period: 05/28/2020 ? 06/30/2024 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Material Noncompliance (Modified Opinion) Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Indirect costs should be calculated based on modified total direct costs excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs and the portion of each subaward in excess of $25,000, as stipulated by the College?s approved indirect cost rate agreement. Condition: The College applied their indirect cost rate to all direct costs of the Programs including tuition remission, scholarships, and payments to students. Questioned costs: The questioned costs have been calculated based on the recalculation of modified total direct costs multiplied by the College?s negotiated indirect cost rate. The known questioned costs for 15.027 totals $148,287. The known questioned costs for 84.425K totals $263,299. Context: As a part of the audit of allowable costs and activities, it was noted that the College was not appropriately calculating the indirect costs to be charged to the federal program in accordance with the stated criteria. Cause: The College did not appropriately calculate the modified total direct costs in accordance with the stated criteria. Effect: The College claimed indirect costs in excess of what would be allowed by the stated criteria. Repeat Finding: No Recommendation: We recommend that the College develop a process and internal controls that will mitigate the risk of incorrectly calculating the indirect costs to be charged to federal programs. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 005: Reporting - Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425E & F Federal Award Identification Number and Year: P425K200020-20B -Year Ended June 30, 2022 Award Period: 05/28/2020 ? 06/30/2024 ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). An institution is required to publicly post its Quarterly Reporting Form for the Student (84.425E) and Institutional (84.425F) funding within ten (10) days of the end of the quarter. Annual reporting for all fund expended January 1, 2021 through December 31, 2021 was due May 6, 2022 Condition: The College did not maintain supporting documentation to illustrate timely posting of its quarterly reports. The annual report was submitted on May 9, 2022. Questioned costs: None Context: During our audit of the reporting requirements, submission of quarterly and annual reports was completed in accordance with the required deadlines. Cause: The College did not submit its quarterly and annual reports prior to the reporting deadlines. Effect: The College published quarterly reports after ten (10) days after the end of the quarter. The annual report was completed after the May 6, 2022 deadline. Repeat Finding: No Recommendation: We recommend that the College develop a process and internal controls to ensure timely publication and submission of required reports and maintain supporting documentation to verify compliance. Views of responsible officials: The College agrees with the auditor?s comments and has taken corrective action to ensure reporting consideration is added to policies and procedures.
2022 ? 002: Allowable Indirect Costs Federal Agency: U.S. Department of Interior Federal Program Name: Assistance to Tribally Controlled Community Colleges and Universities Assistance Listing Number: 15.027 Federal Award Identification Number and Year: A19AP00124 ? Year Ended June 30, 2022 Award Period: 7/1/2019 ? 6/30/2024 ____________________________________________________ Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425K Federal Award Identification Number and Year: P425K200020-20B ? Year Ended June 30, 2022 Award Period: 05/28/2020 ? 06/30/2024 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Material Noncompliance (Modified Opinion) Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Indirect costs should be calculated based on modified total direct costs excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs and the portion of each subaward in excess of $25,000, as stipulated by the College?s approved indirect cost rate agreement. Condition: The College applied their indirect cost rate to all direct costs of the Programs including tuition remission, scholarships, and payments to students. Questioned costs: The questioned costs have been calculated based on the recalculation of modified total direct costs multiplied by the College?s negotiated indirect cost rate. The known questioned costs for 15.027 totals $148,287. The known questioned costs for 84.425K totals $263,299. Context: As a part of the audit of allowable costs and activities, it was noted that the College was not appropriately calculating the indirect costs to be charged to the federal program in accordance with the stated criteria. Cause: The College did not appropriately calculate the modified total direct costs in accordance with the stated criteria. Effect: The College claimed indirect costs in excess of what would be allowed by the stated criteria. Repeat Finding: No Recommendation: We recommend that the College develop a process and internal controls that will mitigate the risk of incorrectly calculating the indirect costs to be charged to federal programs. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 003: Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Name: Rural Business Development Grant Assistance Listing Number: 10.351 Federal Award Identification Number and Year: Borrower ID: 32-087-295542779 - Year Ended June 30, 2022 Award Period: 7/1/2021 ? 6/30/2022 ____________________________________________________ Federal Agency: U.S. Department of Interior Federal Program Name: Assistance to Tribally Controlled Community Colleges and Universities Assistance Listing Number: 15.027 Federal Award Identification Number and Year: A19AP00124 ? Year Ended June 30, 2022 Award Period: 7/1/2019 ? 6/30/2024 ____________________________________________________ Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425K Federal Award Identification Number and Year: P425K200020-20B -Year Ended June 30, 2022 Award Period: 05/28/2020 ? 06/30/2024 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: The College had not established a policy or an effective internal control system related to the grant agreements and the Procurement, Suspension, and Debarment compliance requirement. The College?s current procurement policy does not include a documented process to ensure vendors meet suspension and debarment requirements. In addition, there was no documentation that the Authority had searched all applicable vendors on the System for Award Management (SAM) to ensure that the College?s vendors were not suspended or debarred. Questioned costs: None Context: Procurement policies were followed, but no documented process to ensure suspension and debarment noted. Cause: The current policy and internal control structure does not include a process for ensuring suspension and debarment requirements are met for all required vendors. Effect: The College may contract with or make subawards under covered transactions to parties that are suspended or debarred. Repeat Finding: No Recommendation: The College should consider updating their current procurement policy to include suspension and debarment processes and implement appropriate internal controls to ensure the processes are followed. Views of responsible officials: The College agrees with the auditor?s comments and has taken corrective action to ensure suspension and debarment consideration is added to policies and procedures.
2022 ? 005: Reporting - Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425E & F Federal Award Identification Number and Year: P425K200020-20B -Year Ended June 30, 2022 Award Period: 05/28/2020 ? 06/30/2024 ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). An institution is required to publicly post its Quarterly Reporting Form for the Student (84.425E) and Institutional (84.425F) funding within ten (10) days of the end of the quarter. Annual reporting for all fund expended January 1, 2021 through December 31, 2021 was due May 6, 2022 Condition: The College did not maintain supporting documentation to illustrate timely posting of its quarterly reports. The annual report was submitted on May 9, 2022. Questioned costs: None Context: During our audit of the reporting requirements, submission of quarterly and annual reports was completed in accordance with the required deadlines. Cause: The College did not submit its quarterly and annual reports prior to the reporting deadlines. Effect: The College published quarterly reports after ten (10) days after the end of the quarter. The annual report was completed after the May 6, 2022 deadline. Repeat Finding: No Recommendation: We recommend that the College develop a process and internal controls to ensure timely publication and submission of required reports and maintain supporting documentation to verify compliance. Views of responsible officials: The College agrees with the auditor?s comments and has taken corrective action to ensure reporting consideration is added to policies and procedures.
2022 ? 002: Allowable Indirect Costs Federal Agency: U.S. Department of Interior Federal Program Name: Assistance to Tribally Controlled Community Colleges and Universities Assistance Listing Number: 15.027 Federal Award Identification Number and Year: A19AP00124 ? Year Ended June 30, 2022 Award Period: 7/1/2019 ? 6/30/2024 ____________________________________________________ Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425K Federal Award Identification Number and Year: P425K200020-20B ? Year Ended June 30, 2022 Award Period: 05/28/2020 ? 06/30/2024 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Material Noncompliance (Modified Opinion) Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Indirect costs should be calculated based on modified total direct costs excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs and the portion of each subaward in excess of $25,000, as stipulated by the College?s approved indirect cost rate agreement. Condition: The College applied their indirect cost rate to all direct costs of the Programs including tuition remission, scholarships, and payments to students. Questioned costs: The questioned costs have been calculated based on the recalculation of modified total direct costs multiplied by the College?s negotiated indirect cost rate. The known questioned costs for 15.027 totals $148,287. The known questioned costs for 84.425K totals $263,299. Context: As a part of the audit of allowable costs and activities, it was noted that the College was not appropriately calculating the indirect costs to be charged to the federal program in accordance with the stated criteria. Cause: The College did not appropriately calculate the modified total direct costs in accordance with the stated criteria. Effect: The College claimed indirect costs in excess of what would be allowed by the stated criteria. Repeat Finding: No Recommendation: We recommend that the College develop a process and internal controls that will mitigate the risk of incorrectly calculating the indirect costs to be charged to federal programs. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 003: Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Name: Rural Business Development Grant Assistance Listing Number: 10.351 Federal Award Identification Number and Year: Borrower ID: 32-087-295542779 - Year Ended June 30, 2022 Award Period: 7/1/2021 ? 6/30/2022 ____________________________________________________ Federal Agency: U.S. Department of Interior Federal Program Name: Assistance to Tribally Controlled Community Colleges and Universities Assistance Listing Number: 15.027 Federal Award Identification Number and Year: A19AP00124 ? Year Ended June 30, 2022 Award Period: 7/1/2019 ? 6/30/2024 ____________________________________________________ Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425K Federal Award Identification Number and Year: P425K200020-20B -Year Ended June 30, 2022 Award Period: 05/28/2020 ? 06/30/2024 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: The College had not established a policy or an effective internal control system related to the grant agreements and the Procurement, Suspension, and Debarment compliance requirement. The College?s current procurement policy does not include a documented process to ensure vendors meet suspension and debarment requirements. In addition, there was no documentation that the Authority had searched all applicable vendors on the System for Award Management (SAM) to ensure that the College?s vendors were not suspended or debarred. Questioned costs: None Context: Procurement policies were followed, but no documented process to ensure suspension and debarment noted. Cause: The current policy and internal control structure does not include a process for ensuring suspension and debarment requirements are met for all required vendors. Effect: The College may contract with or make subawards under covered transactions to parties that are suspended or debarred. Repeat Finding: No Recommendation: The College should consider updating their current procurement policy to include suspension and debarment processes and implement appropriate internal controls to ensure the processes are followed. Views of responsible officials: The College agrees with the auditor?s comments and has taken corrective action to ensure suspension and debarment consideration is added to policies and procedures.
2022 ? 005: Reporting - Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425E & F Federal Award Identification Number and Year: P425K200020-20B -Year Ended June 30, 2022 Award Period: 05/28/2020 ? 06/30/2024 ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). An institution is required to publicly post its Quarterly Reporting Form for the Student (84.425E) and Institutional (84.425F) funding within ten (10) days of the end of the quarter. Annual reporting for all fund expended January 1, 2021 through December 31, 2021 was due May 6, 2022 Condition: The College did not maintain supporting documentation to illustrate timely posting of its quarterly reports. The annual report was submitted on May 9, 2022. Questioned costs: None Context: During our audit of the reporting requirements, submission of quarterly and annual reports was completed in accordance with the required deadlines. Cause: The College did not submit its quarterly and annual reports prior to the reporting deadlines. Effect: The College published quarterly reports after ten (10) days after the end of the quarter. The annual report was completed after the May 6, 2022 deadline. Repeat Finding: No Recommendation: We recommend that the College develop a process and internal controls to ensure timely publication and submission of required reports and maintain supporting documentation to verify compliance. Views of responsible officials: The College agrees with the auditor?s comments and has taken corrective action to ensure reporting consideration is added to policies and procedures.