Criteria or Requirement Per Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Subpart D, Section 200.303), the nonfederal entity must 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. Common Origination and Disbursement (COD) System (OMB No. 1845-0039) - All schools receiving Pell grants submit Pell payment data to the Department of Education through the COD System. Schools submit Pell origination records and disbursement records to the COD System. Institutions must report student payment data within 15 calendar days after the school makes a payment; or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Schools may do this by reporting once every 15 calendar days, bi-weekly or weekly or may set up their own system to ensure that changes are reported in a timely manner. Condition Found, Including Perspective We identified 12 students in a sample of 40 that had Pell disbursements that were reported to the COD System after the required 15 day deadline (on average 26 days). Cause and Possible Asserted Effect Management?s control over reporting Pell disbursement data to the COD System timely did not operate effectively. Questioned Costs There were no questioned costs associated with this finding. Statistical Validity The sample was not intended to be, and was not, a statistically valid sample.Repeat finding The audit finding is not a repeat of a finding in the immediately prior fiscal year. Recommendation We recommend that the College implement additional monitoring controls to ensure proper reporting of Pell disbursement data to the COD System within the required timeframe. Views of Responsible Officials Management recognizes the finding in Pell disbursement reporting to the Common Origination and Disbursement (COD) System (OMB No. 1845-0039). The COVID-19 Pandemic has presented the financial aid office with unprecedented administrative challenges, and we continue our efforts to return to pre-pandemic norms. Management would like to acknowledge the deficiency did not result in ineligible payments to students nor required the college to return any Title IV funds. The financial aid office has implemented reporting safeguards, including a secondary review of all Pell disbursements reporting prior to the COD reporting deadline, and the Associate Vice President for Financial Aid is now actively involved in ensuring timely reporting disbursements by reviewing monthly internal reports.
Criteria or Requirement Per Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Subpart D, Section 200.303), the nonfederal entity must 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. The COVID-19 ? Higher Education Emergency Relief Fund (HEERF) participating institutions are required to comply with Quarterly Public Reporting for Student Aid Portion and Institutional Portion. Each HEERF participating institution must publicly post the information on the institution?s primary website and update no later than 10 days after the end of each calendar quarter (March 31, June 30, September 30, and December 31).Condition Found, Including Perspective During our test work over the Institutional Portion reporting, we selected December 31, 2021 and March 31, 2022 quarterly reporting. We noted that the quarterly reporting for those quarters were publicly published on the College?s website on April 26, 2022, which is after the required 10 day deadline for both quarters. During our test work over Student Aid Portion reporting, we selected December 31, 2021 and March 31, 2022 quarterly reporting. We noted that there was no evidence that the Student Aid Portion reporting for the quarter ending December 31, 2021 was publicly published. Cause and Possible Asserted Effect Management?s control over HEERF Quarterly Public Reporting did not operate effectively to ensure compliance or timely reporting. Questioned Costs There were no questioned costs associated with this finding. Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding The audit finding is not a repeat of a finding in the immediately prior year. Recommendation We recommend that the College implement additional monitoring controls to ensure proper reporting within the required timeframe. Views of Responsible OfficialsManagement acknowledges the finding regarding the timeliness with which the student aid and institutional portion of HEERF quarterly reports were posted on the College?s website during the period under review. During the height of the pandemic, colleges and universities were confronted with unprecedented challenges. Due to the administrative burden imposed by these challenges, the urgency to provide students with funds, and the numerous regulatory changes to eligibility requirements, reporting deficiencies arose. In addition, the staff transition during the period under review attributed to the delay in posting of the quarterly HEERF reports for the institutional portion after the required reporting deadline. However, all quarterly and annual reports for the institutional portion were posted on the management?s website prior to the end of the reporting period. Management also acknowledges the finding relating to posting of the student portion of HEERF information on the College?s website, as well as the fact that annual reports were submitted on time to the Department of Education, demonstrating our efforts in adhering to the reporting guidelines.
Criteria or Requirement Per Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Subpart D, Section 200.303), the nonfederal entity must 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. The COVID-19 ? Higher Education Emergency Relief Fund (HEERF) participating institutions are required to comply with Quarterly Public Reporting for Student Aid Portion and Institutional Portion. Each HEERF participating institution must publicly post the information on the institution?s primary website and update no later than 10 days after the end of each calendar quarter (March 31, June 30, September 30, and December 31).Condition Found, Including Perspective During our test work over the Institutional Portion reporting, we selected December 31, 2021 and March 31, 2022 quarterly reporting. We noted that the quarterly reporting for those quarters were publicly published on the College?s website on April 26, 2022, which is after the required 10 day deadline for both quarters. During our test work over Student Aid Portion reporting, we selected December 31, 2021 and March 31, 2022 quarterly reporting. We noted that there was no evidence that the Student Aid Portion reporting for the quarter ending December 31, 2021 was publicly published. Cause and Possible Asserted Effect Management?s control over HEERF Quarterly Public Reporting did not operate effectively to ensure compliance or timely reporting. Questioned Costs There were no questioned costs associated with this finding. Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding The audit finding is not a repeat of a finding in the immediately prior year. Recommendation We recommend that the College implement additional monitoring controls to ensure proper reporting within the required timeframe. Views of Responsible OfficialsManagement acknowledges the finding regarding the timeliness with which the student aid and institutional portion of HEERF quarterly reports were posted on the College?s website during the period under review. During the height of the pandemic, colleges and universities were confronted with unprecedented challenges. Due to the administrative burden imposed by these challenges, the urgency to provide students with funds, and the numerous regulatory changes to eligibility requirements, reporting deficiencies arose. In addition, the staff transition during the period under review attributed to the delay in posting of the quarterly HEERF reports for the institutional portion after the required reporting deadline. However, all quarterly and annual reports for the institutional portion were posted on the management?s website prior to the end of the reporting period. Management also acknowledges the finding relating to posting of the student portion of HEERF information on the College?s website, as well as the fact that annual reports were submitted on time to the Department of Education, demonstrating our efforts in adhering to the reporting guidelines.
Criteria or Requirement Per Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Subpart D, Section 200.303), the nonfederal entity must 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. Common Origination and Disbursement (COD) System (OMB No. 1845-0039) - All schools receiving Pell grants submit Pell payment data to the Department of Education through the COD System. Schools submit Pell origination records and disbursement records to the COD System. Institutions must report student payment data within 15 calendar days after the school makes a payment; or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Schools may do this by reporting once every 15 calendar days, bi-weekly or weekly or may set up their own system to ensure that changes are reported in a timely manner. Condition Found, Including Perspective We identified 12 students in a sample of 40 that had Pell disbursements that were reported to the COD System after the required 15 day deadline (on average 26 days). Cause and Possible Asserted Effect Management?s control over reporting Pell disbursement data to the COD System timely did not operate effectively. Questioned Costs There were no questioned costs associated with this finding. Statistical Validity The sample was not intended to be, and was not, a statistically valid sample.Repeat finding The audit finding is not a repeat of a finding in the immediately prior fiscal year. Recommendation We recommend that the College implement additional monitoring controls to ensure proper reporting of Pell disbursement data to the COD System within the required timeframe. Views of Responsible Officials Management recognizes the finding in Pell disbursement reporting to the Common Origination and Disbursement (COD) System (OMB No. 1845-0039). The COVID-19 Pandemic has presented the financial aid office with unprecedented administrative challenges, and we continue our efforts to return to pre-pandemic norms. Management would like to acknowledge the deficiency did not result in ineligible payments to students nor required the college to return any Title IV funds. The financial aid office has implemented reporting safeguards, including a secondary review of all Pell disbursements reporting prior to the COD reporting deadline, and the Associate Vice President for Financial Aid is now actively involved in ensuring timely reporting disbursements by reviewing monthly internal reports.
Criteria or Requirement Per Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Subpart D, Section 200.303), the nonfederal entity must 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. The COVID-19 ? Higher Education Emergency Relief Fund (HEERF) participating institutions are required to comply with Quarterly Public Reporting for Student Aid Portion and Institutional Portion. Each HEERF participating institution must publicly post the information on the institution?s primary website and update no later than 10 days after the end of each calendar quarter (March 31, June 30, September 30, and December 31).Condition Found, Including Perspective During our test work over the Institutional Portion reporting, we selected December 31, 2021 and March 31, 2022 quarterly reporting. We noted that the quarterly reporting for those quarters were publicly published on the College?s website on April 26, 2022, which is after the required 10 day deadline for both quarters. During our test work over Student Aid Portion reporting, we selected December 31, 2021 and March 31, 2022 quarterly reporting. We noted that there was no evidence that the Student Aid Portion reporting for the quarter ending December 31, 2021 was publicly published. Cause and Possible Asserted Effect Management?s control over HEERF Quarterly Public Reporting did not operate effectively to ensure compliance or timely reporting. Questioned Costs There were no questioned costs associated with this finding. Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding The audit finding is not a repeat of a finding in the immediately prior year. Recommendation We recommend that the College implement additional monitoring controls to ensure proper reporting within the required timeframe. Views of Responsible OfficialsManagement acknowledges the finding regarding the timeliness with which the student aid and institutional portion of HEERF quarterly reports were posted on the College?s website during the period under review. During the height of the pandemic, colleges and universities were confronted with unprecedented challenges. Due to the administrative burden imposed by these challenges, the urgency to provide students with funds, and the numerous regulatory changes to eligibility requirements, reporting deficiencies arose. In addition, the staff transition during the period under review attributed to the delay in posting of the quarterly HEERF reports for the institutional portion after the required reporting deadline. However, all quarterly and annual reports for the institutional portion were posted on the management?s website prior to the end of the reporting period. Management also acknowledges the finding relating to posting of the student portion of HEERF information on the College?s website, as well as the fact that annual reports were submitted on time to the Department of Education, demonstrating our efforts in adhering to the reporting guidelines.
Criteria or Requirement Per Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Subpart D, Section 200.303), the nonfederal entity must 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. The COVID-19 ? Higher Education Emergency Relief Fund (HEERF) participating institutions are required to comply with Quarterly Public Reporting for Student Aid Portion and Institutional Portion. Each HEERF participating institution must publicly post the information on the institution?s primary website and update no later than 10 days after the end of each calendar quarter (March 31, June 30, September 30, and December 31).Condition Found, Including Perspective During our test work over the Institutional Portion reporting, we selected December 31, 2021 and March 31, 2022 quarterly reporting. We noted that the quarterly reporting for those quarters were publicly published on the College?s website on April 26, 2022, which is after the required 10 day deadline for both quarters. During our test work over Student Aid Portion reporting, we selected December 31, 2021 and March 31, 2022 quarterly reporting. We noted that there was no evidence that the Student Aid Portion reporting for the quarter ending December 31, 2021 was publicly published. Cause and Possible Asserted Effect Management?s control over HEERF Quarterly Public Reporting did not operate effectively to ensure compliance or timely reporting. Questioned Costs There were no questioned costs associated with this finding. Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding The audit finding is not a repeat of a finding in the immediately prior year. Recommendation We recommend that the College implement additional monitoring controls to ensure proper reporting within the required timeframe. Views of Responsible OfficialsManagement acknowledges the finding regarding the timeliness with which the student aid and institutional portion of HEERF quarterly reports were posted on the College?s website during the period under review. During the height of the pandemic, colleges and universities were confronted with unprecedented challenges. Due to the administrative burden imposed by these challenges, the urgency to provide students with funds, and the numerous regulatory changes to eligibility requirements, reporting deficiencies arose. In addition, the staff transition during the period under review attributed to the delay in posting of the quarterly HEERF reports for the institutional portion after the required reporting deadline. However, all quarterly and annual reports for the institutional portion were posted on the management?s website prior to the end of the reporting period. Management also acknowledges the finding relating to posting of the student portion of HEERF information on the College?s website, as well as the fact that annual reports were submitted on time to the Department of Education, demonstrating our efforts in adhering to the reporting guidelines.