Finding 2022-003 Activities Allowed or Unallowed, Allowable Costs/Cost Principles and Period of Performance Material Weakness in Internal Control over Compliance and Material Noncompliance Finding Summary: Through testing of operational expenditures of the College, it was determined; o Payroll expen...
Finding 2022-003 Activities Allowed or Unallowed, Allowable Costs/Cost Principles and Period of Performance Material Weakness in Internal Control over Compliance and Material Noncompliance Finding Summary: Through testing of operational expenditures of the College, it was determined; o Payroll expenditures charged to the award were not for costs newly associated with the coronavirus, a requirement communicated within the supplemental guidance in the Higher Education Emergency Relief Fund III Frequently Asked Questions published May 11, 2021 and updated May 24, 2021. Through testing of disbursements to students, it was determined; o No support could not be provided to substantiate a secondary level of review was completed prior to disbursement of funds. o 26 instances identified in which the College directly controlled how student?s use their emergency financial aid grant. o 8 instances identified in which college discharged outstanding balance on student account for costs incurred prior to March 13, 2020. o 2 instances identified in which the College charged coronavirus vaccine incentive payments under the student portion of HEERF award. Responsible Individuals: Dr. Lane Azure, President Corrective Action Plan: o In response to the payroll finding, this was funded through MSI (no Student or Institutional funds were used for payroll). SWC president attended weekly meetings with American Indian Higher Education Consortium (AIHEC) who assisted and advocated for these HEERF monies for all Tribal Colleges and Universities (TCU). Handouts (attached) of slides were given to each institution and Payroll was an allowable cost with the exception of the President. The college president believed in order to allow the college to stay open and not lose students and staff, subsidies had to be included in payroll. There were no predictions on how long this world-wide pandemic was going to last or how much funds the government was going to give to IHE. SWC is a small tribal college where hiring and maintaining qualified personnel has been difficult long before the pandemic and now even more so. SWC could not afford to hire new staff even if it was feasible to find someone to fill new positions. Therefore, SWC used HEERF to make payroll on many employees whose job duties changed so they could assist the college in staying open and transition to a completely different method of delivering education to SWC students. SWC president was told by the Department of Education and AIHEC that these funds had to be exhausted in a limited amount of time. In addition, there was a limited number of items that the funds could be spent on, but it was changing every day to be more liberal. In March 2020, SWC had to begin offering courses via distance delivery which was a completely new method for this college. In summer 2020, the college did not offer classes and in fall 2020 SWC had to begin offering a hybrid method of delivery. Every single employee of this college had to do their day to day duties differently in order to support the new delivery method for education ranging from contact tracing, hyflex delivery, social distancing, hygiene, masking up, staff meetings, parking, teaching, and etc. The range of employees went from admissions, student services, academic staff, faculty, and the business office. All employees were coming in at different shifts, and/or working remotely, while social distancing. o The College will ensure documented secondary level of review and approval is retained. o For grant payments funded by institutional portion, Grant payments were applied to student accounts and if no outstanding balance, a check was given to the student. For grants funded by MSI, a formula was used to distribute $125 per credit and an allowance for books and fees. The COARS was a financial aid grant to the student who applied for the relief. o Any debt relief provided for students was for those students who could not attend the current academic year because of a prior balance. In order to attend college during the pandemic, MSI funds were used to discharge the student?s balance at the discretion of the student. o The checks for these instances were given directly to the student to defray costs of going to get the vaccine, for transportation, for cost of the office visit, or whatever it may have been they needed in order to get the vaccine. It was emergency aid to the student. Anticipated Completion Date: July 1, 2022