1. FINDING NUMBER: 2024 - 002 2. THIS FINDING IS: New 3. Federal Program Name and Year: Child Nutrition Cluster - 2024 4. Project No.: 24-4210-00, 24-4220-00 5. AL No.: 10.553, 10.555 6. Passed Through: Illinois State Board of Education 7. Federal Agency: U.S. Department of Agriculture 8. Criteria or specific requirement (including statutory, regulatory, or other citation): According to 2 CFR §200.303, non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 9. Condition: During our audit of the Child Nutrition Cluster, we identified that the District did not have adequate disbursement controls in place. Specifically, duplicate invoices on multiple occasions were entered into the District's software system due to typographical errors, resulting in payments being made twice to each vendor for the same service. 10. Questioned Costs: The duplicated invoices do not impact the reimbursement received by the District due to the Child Nutrition Cluster being an open-ended entitlement grant, meaning they provide reimbursements based on the number of eligible meals served rather than all food service expenditures incurred. As a result, no questioned costs were identified. 11. Context: During our audit of the Child Nutrition Cluster's allowable activities, two separate instances of duplicated invoices were identified from a stratified sample size of forty. The sample was deemed not statistically valid. 12. Effect: The District incurred unnecessary expenses by paying vendors twice for the same service, which could result in financial losses and potential non-compliance with Federal regulations. The finding does not impact the reimbursement the District receives. 13. Cause: The lack of proper review and approval processes for invoice entry and payment, combined with typographical errors, led to the duplication of invoices and subsequent duplicate payments. 14. Recommendation: We recommend that the District implement stronger internal controls over the disbursement process. This includes establishing a review and approval process for all invoices before payment, implementing software controls to detect duplicate invoices, and providing training to staff on proper invoice processing procedures to minimize typographical errors. 15. Management's response: Management agrees with the finding and has initiated steps to enhance disbursement controls. These steps include revising the invoice approval process, upgrading the software system to flag duplicate invoices, and conducting training sessions for staff on the new procedures to reduce typographical errors.
FINDING 2024-004 Information on the federal program: Subject: Special Education Cluster (IDEA) – Activities Allowed or Unallowed Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): H027A220084, H027A230084 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards 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 terms and conditions of the Federal award. Condition: An effective internal control system was not in place at the School District to ensure compliance with requirements related to the Special Education Cluster and Activities Allowed or Unallowed. Cause: The School District's management had not developed a system of internal controls that would have ensured compliance with the Activities Allowed or Unallowed compliance requirement. Effect: The failure to establish an effective internal control system placed the School District at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There we no questioned costs identified. Context: During the testing of a sample of 40 payroll disbursements charged to the Special Education Cluster during the audit period, the following exceptions were noted: For eight transactions selected, management was unable to provide an approved contract to support the selected employees' bi-weekly pay rate. For two transactions selected, management was unable to provide approved timecards for the selected hourly employee and time period. For seven transactions selected, management was unable to provide time and effort logs to support the allocation of one employee’s salary between the federal grant and the Education fund. The lack of controls was systematic throughout the audit period. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School District's management establish a system of internal controls related to payroll disbursement charged to federal awards to ensure that the costs allocated are properly supported by contracts, timecards, and that the methodology for salary employees allocated to grant are supported by time and effort documentation. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2024-004 Information on the federal program: Subject: Special Education Cluster (IDEA) – Activities Allowed or Unallowed Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): H027A220084, H027A230084 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards 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 terms and conditions of the Federal award. Condition: An effective internal control system was not in place at the School District to ensure compliance with requirements related to the Special Education Cluster and Activities Allowed or Unallowed. Cause: The School District's management had not developed a system of internal controls that would have ensured compliance with the Activities Allowed or Unallowed compliance requirement. Effect: The failure to establish an effective internal control system placed the School District at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There we no questioned costs identified. Context: During the testing of a sample of 40 payroll disbursements charged to the Special Education Cluster during the audit period, the following exceptions were noted: For eight transactions selected, management was unable to provide an approved contract to support the selected employees' bi-weekly pay rate. For two transactions selected, management was unable to provide approved timecards for the selected hourly employee and time period. For seven transactions selected, management was unable to provide time and effort logs to support the allocation of one employee’s salary between the federal grant and the Education fund. The lack of controls was systematic throughout the audit period. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School District's management establish a system of internal controls related to payroll disbursement charged to federal awards to ensure that the costs allocated are properly supported by contracts, timecards, and that the methodology for salary employees allocated to grant are supported by time and effort documentation. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2024-002 Information on the federal program: Subject: COVID-19 – Education Stabilization Fund – Activities Allowed or Unallowed Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards 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 terms and conditions of the Federal award. Condition: An effective internal control system was not in place at the School District to ensure compliance with requirements related to the Education Stabilization Fund and Activities Allowed or Unallowed. Cause: The School District's management had not developed a system of internal controls that would have ensured compliance with the Activities Allowed or Unallowed compliance requirement. Effect: The failure to establish an effective internal control system placed the School District at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: $730.43 Context: During the testing of payroll disbursements charged to the Education Stabilization Fund grant awards during the audit period, the following exceptions were noted: For 16 payroll disbursements, in a sample of 40, management was unable to provide an approved employee contract or hourly rate ordinance to support the selected employees' bi-weekly pay rate. For one transaction selection, an employee received a $730.43 one-time payment for a Teacher Appreciation Grant (TAG) funded by the 84.425U award. The Teacher Appreciation Grant has its own fund and is a state/local grant received to reward high-performing, eligible certified staff. The selected employee is a non-certified employee and did not qualify for a TAG award. There was no documentation provided to support work performed under this award to support allowability of the cost incurred. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School District maintain supporting documentation for vendor and payroll disbursements to support costs charged to the federal grant awards. For payroll disbursements charged to Federal awards, management should maintain time records to support payroll costs allocated to Education Stabilization Grant funds to verify they are allowable and supported by documentation for work performed under the award. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2024-003 Information on the federal program: Subject: COVID-19 – Education Stabilization Fund – Reporting Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: An effective internal control system was not in place at the School District in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Cause: The School District's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School District at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: The School Corporation had not designed nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The reports were prepared and submitted in JotForm, the online application used by the Indiana Department of Education to collect information, without an oversight or secondary review process in place to prevent, or detect and correct, errors. During tie out of the Year 3 report, a variance between the underlying records and reported expenditures of $187,649 was noted due to the lack of effective controls surrounding annual data reporting. 84.425U expenditures submitted within the Year 3 report were overstated by $187,649. Identification as a repeat finding: Yes, see Finding 2022-001. Recommendation: We recommend someone other than the preparer of the report perform a documented, secondary review of the report information prior to submission to validate the accuracy and completeness of the data submitted. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding Number 2024-002: Timesheet versus Time Study Hours (Significant Deficiency in Internal Control over compliance – Allowable Costs/Cost Principles) FALN Number 93.778; Federal Agency/Pass-through Entity – Program Name Alameda Health Care Services Agency - Medical Assistance Program (Medi-Cal Administrative Activities); Award Number MAA MOU 2023-2024; Award Year 2023-2024 Criteria: 2024 Compliance Supplement and 2 CFR 200.303(a) stated that the non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the federal award. Condition/Context: As a result of our audit procedures, we noted 1 of 40 timesheets tested in which the hours on the employee’s timesheet did not agree to the hours reported on the time study as the time study was not prepared for an employee. Repeat Finding from Prior Year(s): Yes, Finding Number 2023-002 Cause and Effect: The Health System did not have proper controls in place to ensure hours reported on the timesheet agree to the hours on the time study and that a time study is properly prepared, which could lead to inaccurate hours being reported and disbursed to employees. Questioned Cost: None Recommendation: We recommend management review policies and procedures to ensure the hours reported on the timesheet agree to the hours on the time study, and to ensure a time study is properly prepared and retained. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System finalized the standard work procedures titled, Internal Controls for Proper Verification, which include procedures to ensure reported timesheet hours agree to hours on the time study and costs incurred are appropriately charged based on the contracts’ performance periods. Staff is implementing policy in fiscal year 2025."
Finding Number 2024-003: Contract Requirements - Earmarking (Significant Deficiency in Internal Control over compliance and Instance of Noncompliance – Matching, Level of Effort, and Earmarking) FALN Number 93.959; Federal Agency/Pass-through Entity – Program Name Block Grants for Prevention and Treatment of Substance Abuse; Award Number 900077; Award Year 2023-2024 Criteria: 2024 Compliance Supplement and 2 CFR 200.303(a) stated that the non-Federal 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 terms and conditions of the federal award. Condition/Context: As a result of our audit procedures, we noted management did not have evidence retained to support its compliance with the program’s earmarking requirements related to Process Objectives, Quality Objectives and Impact Objectives. Repeat Finding from Prior Year(s): Yes, Finding Number 2023-004 Cause and Effect: The Health System did not have proper controls in place to ensure the fulfillment of the earmarking requirements are properly documented, which led to non-compliance with program requirements. Questioned Cost: None Recommendation: We recommend management implement policies and procedures to clearly identify the earmarking requirements of the program and retain proper documentations to support how the requirements are fulfilled. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System has drafted the policy titled, Alameda Health System Reports Policies – SUD Program, to ensure earmarking requirements of the program and proper documentation is retained to evidence fulfilled requirements. The policy will be finalized in fiscal year 2025.
Finding Number 2024-05: Untimely Reporting (Significant Deficiency in Internal Control over compliance and Instances of Noncompliance – Reporting) FALN Number 16.575; Federal Agency/Pass-through Entity – Program Name U.S. Department of Justice, Office of Victims of Crime – Crime Victim Assistance; Award Number 94-3302014; Award Year 2023-2024 Criteria: 2024 Compliance Supplement and 2 CFR 200.303(a) stated that the non-Federal 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 terms and conditions of the federal award. Condition/Context: As a result of our audit procedures, we noted 1 sample of untimely financial reporting submitting to the grantor. The financial report was for the quarter ended 9/30/2023 with a due date of 30 days after the reporting period; however, the report was submitted on 11/8/2023. We also noted 2 samples of performance report for the quarters ended 12/31/2023 and 9/30/2023 with due dates of 30 days after the reporting period; however, the reports were submitted on 3/19/2024 and 11/2/2023, respectively. Repeat Finding from Prior Year(s): Yes, Finding Number 2023-010 Cause and Effect: The Health System did not have proper controls in place to ensure financial and performance reports are submitted timely, which resulted in late report filings. Questioned Cost: None Recommendation: We recommend management implement policies and procedures to ensure financial and performance reports are submitted timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System will review, modify, and implement policies and procedures over the program to ensure that required reports are prepared and reviewed by separate individuals. Documentation will be maintained by the program to evidence preparation and review processes and timely filing of annual report.
Finding Number 2024-006: Charges Not Specified in Grant Contracts (Significant Deficiency in Internal Control over compliance and Instances of Noncompliance – Allowable Costs/Cost Principles) FALN Number 16.575; Federal Agency/Pass-through Entity – Program Name U.S. Department of Justice, Office of Victims of Crime – Crime Victim Assistance; Award Number 94-3302014; Award Year 2023-2024 Criteria: 2024 Compliance Supplement and 2 CFR 200.303(a) stated that the non-Federal 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 terms and conditions of the federal award. Condition/Context: As a result of our audit procedures, we noted 7 samples totaling $190 non-payroll expenditure for gift card purchases that were not outlined in the grant contract (RC22). Repeat Finding from Prior Year(s): No Cause and Effect: The Health System did not have proper controls in place to ensure expenditures being charged to the program are specifically identified in the grant contract. Questioned Cost: None Recommendation: We recommend management implement policies and procedures to ensure expenditures charged to the program are in accordance with the grant contracts. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System will review, modify, and implement policies and procedures over the program to ensure that expenditures being charged to the program are specifically identified in the grant contract.
Finding Number 2024-007: FEMA Reporting (Significant Deficiency in Internal Control over compliance -Reporting) FALN Number 97.036; Federal Agency/Pass-through Entity – Program Name COVID 19 - Disaster Grants – Public Assistance (Presidentially Declared Disasters); Award Number FEMA-4482-DR-CA, Cal OES ID: 001-91020; Award Year 2023-2024 Criteria: 2024 Compliance Supplement and 2 CFR 200.303(a) stated that the non-Federal 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 terms and conditions of the federal award. Condition/Context: As a result of our audit procedures, we noted the only reimbursement request submitted to the grantor did not have clear evidence of preparer and reviewer of the report. Repeat Finding from Prior Year(s): No. Cause and Effect: The Health System did not have proper controls in place to ensure reimbursement request is prepared and reviewed by separate individuals with evidence of review documented and retained, which could lead to inaccurate information being reported and or submitted for reimbursement. Questioned Cost: None Recommendation: We recommend management implement policies and procedures to ensure reimbursement request is prepared and reviewed by separate individuals with evidence of review documented. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System will ensure that the FEMA reimbursement requests have clear evidence of the individuals preparing and reviewing of the submission. Documentation will be maintained to evidence preparation and review process.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Numbers: 84.268 and 84.063 Grant Award Period: July 1, 2023 through June 30, 2024 Grant Identification Numbers: N/A Compliance Requirement: Enrollment Reporting Criteria: 2 CFR 690.83(b)(2) and 2 CFR 685.309 requires participating schools in the Direct Loan Program and Pell Program to notify the Secretary of Education if a Direct Loan or Pell grant has been made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. This notification is required to be reported within 30 days, unless a roster will be submitted within 60 days. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Conditions Found: It was identified that the College did not have effective internal controls over the review over program level data changes submitted to National Student Loan Data System (NSLDS) for students who withdrew. During testwork over enrollment reporting, we selected 18 students who withdrew from the College during the fiscal year. We identified 5 students out of 18 selected whose enrollment change dates were not accurately reported to the NSLDS at the program level. For all selections, the enrollment change dates were accurately reported to NSLDS at the campus level. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None identified Repeat Finding: This finding is not a repeat finding in the immediately prior audit. Cause and Effect: The College did not review the listing of changes submitted to NSLDS at the program level, which caused the enrollment change dates for students who withdrew to not be reported accurately at the program level. Recommendation: We recommend the College enhance its internal control to ensure that the College has effective internal controls in place to ensure that the College conforms to required enrollment reporting as set forth in 2 CFR 690.83(b)(2) and 2 CFR 685.309. View of Responsible Officials: We concur with the finding and are in the process of implementing controls over reviewing the accuracy of program level enrollment status changes to ensure that they are appropriately reported to NSLDS.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Numbers: 84.268 and 84.063 Grant Award Period: July 1, 2023 through June 30, 2024 Grant Identification Numbers: N/A Compliance Requirement: Enrollment Reporting Criteria: 2 CFR 690.83(b)(2) and 2 CFR 685.309 requires participating schools in the Direct Loan Program and Pell Program to notify the Secretary of Education if a Direct Loan or Pell grant has been made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. This notification is required to be reported within 30 days, unless a roster will be submitted within 60 days. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Conditions Found: It was identified that the College did not have effective internal controls over the review over program level data changes submitted to National Student Loan Data System (NSLDS) for students who withdrew. During testwork over enrollment reporting, we selected 18 students who withdrew from the College during the fiscal year. We identified 5 students out of 18 selected whose enrollment change dates were not accurately reported to the NSLDS at the program level. For all selections, the enrollment change dates were accurately reported to NSLDS at the campus level. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None identified Repeat Finding: This finding is not a repeat finding in the immediately prior audit. Cause and Effect: The College did not review the listing of changes submitted to NSLDS at the program level, which caused the enrollment change dates for students who withdrew to not be reported accurately at the program level. Recommendation: We recommend the College enhance its internal control to ensure that the College has effective internal controls in place to ensure that the College conforms to required enrollment reporting as set forth in 2 CFR 690.83(b)(2) and 2 CFR 685.309. View of Responsible Officials: We concur with the finding and are in the process of implementing controls over reviewing the accuracy of program level enrollment status changes to ensure that they are appropriately reported to NSLDS.
Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: 24UT311N1099 - 2024 Pass-Through Agency: Colorado Department of Education Pass-Through Numbers: 4553, 4555, 4559, 6555 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures in place to ensure the required certifications for covered contracts and subawards are received, documented, and contracts are not made with a debarred or suspended party. Condition: We noted that the District does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted one out of eight vendors selected for testing had not been checked to verify they were not suspended or debarred. We did verify this vendor was not currently suspended or debarred through verification per SAM.gov and therefore, the District is in compliance with the grant requirements. Questioned costs: None Context: One vendor, out of a sample of eight, was found to have no evidence of verification that the vendor was not suspended or debarred. We did later verify that the vendor was not suspended or debarred. Cause: The District switched to working with the vendor directly mid-year and did not perform the suspension and debarment check at that time. The District’s Master Service Agreements contain a clause regarding suspension and debarment but a Master Service Agreement was not entered into with the vendor at that time. Effect: The District could not be compliance with suspension and debarment requirements for its federal programs. Repeat Finding: No Recommendation: We recommend that the District implement policies for verifying suspension and debarment compliance for all transactions with vendors who do not have an existing Master Services Agreement. For vendors with long term agreements, we also recommend reviewing the vendor’s status in SAM.gov at the start of each fiscal year. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: 24UT311N1099 - 2024 Pass-Through Agency: Colorado Department of Education Pass-Through Numbers: 4553, 4555, 4559, 6555 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures in place to ensure the required certifications for covered contracts and subawards are received, documented, and contracts are not made with a debarred or suspended party. Condition: We noted that the District does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted one out of eight vendors selected for testing had not been checked to verify they were not suspended or debarred. We did verify this vendor was not currently suspended or debarred through verification per SAM.gov and therefore, the District is in compliance with the grant requirements. Questioned costs: None Context: One vendor, out of a sample of eight, was found to have no evidence of verification that the vendor was not suspended or debarred. We did later verify that the vendor was not suspended or debarred. Cause: The District switched to working with the vendor directly mid-year and did not perform the suspension and debarment check at that time. The District’s Master Service Agreements contain a clause regarding suspension and debarment but a Master Service Agreement was not entered into with the vendor at that time. Effect: The District could not be compliance with suspension and debarment requirements for its federal programs. Repeat Finding: No Recommendation: We recommend that the District implement policies for verifying suspension and debarment compliance for all transactions with vendors who do not have an existing Master Services Agreement. For vendors with long term agreements, we also recommend reviewing the vendor’s status in SAM.gov at the start of each fiscal year. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: 24UT311N1099 - 2024 Pass-Through Agency: Colorado Department of Education Pass-Through Numbers: 4553, 4555, 4559, 6555 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures in place to ensure the required certifications for covered contracts and subawards are received, documented, and contracts are not made with a debarred or suspended party. Condition: We noted that the District does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted one out of eight vendors selected for testing had not been checked to verify they were not suspended or debarred. We did verify this vendor was not currently suspended or debarred through verification per SAM.gov and therefore, the District is in compliance with the grant requirements. Questioned costs: None Context: One vendor, out of a sample of eight, was found to have no evidence of verification that the vendor was not suspended or debarred. We did later verify that the vendor was not suspended or debarred. Cause: The District switched to working with the vendor directly mid-year and did not perform the suspension and debarment check at that time. The District’s Master Service Agreements contain a clause regarding suspension and debarment but a Master Service Agreement was not entered into with the vendor at that time. Effect: The District could not be compliance with suspension and debarment requirements for its federal programs. Repeat Finding: No Recommendation: We recommend that the District implement policies for verifying suspension and debarment compliance for all transactions with vendors who do not have an existing Master Services Agreement. For vendors with long term agreements, we also recommend reviewing the vendor’s status in SAM.gov at the start of each fiscal year. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: 24UT311N1099 - 2024 Pass-Through Agency: Colorado Department of Education Pass-Through Numbers: 4553, 4555, 4559, 6555 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures in place to ensure the required certifications for covered contracts and subawards are received, documented, and contracts are not made with a debarred or suspended party. Condition: We noted that the District does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted one out of eight vendors selected for testing had not been checked to verify they were not suspended or debarred. We did verify this vendor was not currently suspended or debarred through verification per SAM.gov and therefore, the District is in compliance with the grant requirements. Questioned costs: None Context: One vendor, out of a sample of eight, was found to have no evidence of verification that the vendor was not suspended or debarred. We did later verify that the vendor was not suspended or debarred. Cause: The District switched to working with the vendor directly mid-year and did not perform the suspension and debarment check at that time. The District’s Master Service Agreements contain a clause regarding suspension and debarment but a Master Service Agreement was not entered into with the vendor at that time. Effect: The District could not be compliance with suspension and debarment requirements for its federal programs. Repeat Finding: No Recommendation: We recommend that the District implement policies for verifying suspension and debarment compliance for all transactions with vendors who do not have an existing Master Services Agreement. For vendors with long term agreements, we also recommend reviewing the vendor’s status in SAM.gov at the start of each fiscal year. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: 24UT311N1099 - 2024 Pass-Through Agency: Colorado Department of Education Pass-Through Numbers: 4553, 4555, 4559, 6555 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures in place to ensure the required certifications for covered contracts and subawards are received, documented, and contracts are not made with a debarred or suspended party. Condition: We noted that the District does have policies and procedures in place for compliance with suspension and debarment requirements; however, we noted one out of eight vendors selected for testing had not been checked to verify they were not suspended or debarred. We did verify this vendor was not currently suspended or debarred through verification per SAM.gov and therefore, the District is in compliance with the grant requirements. Questioned costs: None Context: One vendor, out of a sample of eight, was found to have no evidence of verification that the vendor was not suspended or debarred. We did later verify that the vendor was not suspended or debarred. Cause: The District switched to working with the vendor directly mid-year and did not perform the suspension and debarment check at that time. The District’s Master Service Agreements contain a clause regarding suspension and debarment but a Master Service Agreement was not entered into with the vendor at that time. Effect: The District could not be compliance with suspension and debarment requirements for its federal programs. Repeat Finding: No Recommendation: We recommend that the District implement policies for verifying suspension and debarment compliance for all transactions with vendors who do not have an existing Master Services Agreement. For vendors with long term agreements, we also recommend reviewing the vendor’s status in SAM.gov at the start of each fiscal year. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per Uniform Guidance 34 CFR 668.164(h)(2)(i), title IV credit balance must be paid directly to the student no later than 14 days after the balance occurred. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing, 41 out of 51 credit balance refunds were returned later than 14 days after the credit balance occurred in student account. Questioned costs: None Context: The College was returning credit balance refunds longer than 14 days after they occurred. Cause: The College was holding financial aid balance until student's purchased bookstore items on student accounts. Effect: The students did not have access to their credit balance refunds timely. Repeat Finding: No Recommendation: We recommend the college update procedures around disbursements of credit balances and implement controls to ensure credit balances are being returned timely. Views of responsible officials: There is no disagreement with the audit finding. Prior to FY23 students signed a form acknowledging and authorizing the College to have credit balances held on their account in the event there would be classes added and to purchase books. During FY23 this procedure was discontinued for an unrelated reason and an unintended consequence was not meeting the 14-day requirement. The College is in the process of developing a new procedure which will be implemented in January, 2025.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted the College did not have adequate internal controls designed for properly documented reviews of return of title IV calculations or direct loan reconciliations. Questioned costs: None Context: During our testing, the College did not have formal documentation that return of title IV calculations or direct loan reconciliations were reviewed and approved. Cause: The College did not have formal procedures in place to review return of title IV calculations or direct loan reconciliations. Effect: If not properly reviewed, the College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned. Also, the direct loan reconciliations could have errors that would not be detected timely. Repeat Finding: No Recommendation: We recommend the College implement policies and procedures surrounding reviews of return of title IV calculations and direct loan reconciliations. Views of responsible officials: There is no disagreement with the audit finding. The return of title IV calculations and the direct loan reconciliations are generated by Colleague and verified by a Financial Aid Staff member utilizing a different method for the calculation. Effective immediately the Financial Director will review the calculation and initial approval.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as "financial institutions" and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the College to establish and maintain effective internal controls over Federal awards. Condition: During our testing of the College's information technology, we noted the College did not maintain a comprehensive written security program that included the minimum required elements. Questioned costs: None Context: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Cause: The College has continued to make progress in updating the College to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Effect: The student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend the College work to update the written security program to ensure compliance with all of the required elements. Views of responsible officials: There is no disagreement with the audit finding. While the College's "written" information security program did not include the minimum requirements, all required activities were being performed. The College is in the process of updating its written information security program to achieve compliance with the Gramm-Leach-Bliley Act.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per Uniform Guidance 34 CFR 668.164(h)(2)(i), title IV credit balance must be paid directly to the student no later than 14 days after the balance occurred. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing, 41 out of 51 credit balance refunds were returned later than 14 days after the credit balance occurred in student account. Questioned costs: None Context: The College was returning credit balance refunds longer than 14 days after they occurred. Cause: The College was holding financial aid balance until student's purchased bookstore items on student accounts. Effect: The students did not have access to their credit balance refunds timely. Repeat Finding: No Recommendation: We recommend the college update procedures around disbursements of credit balances and implement controls to ensure credit balances are being returned timely. Views of responsible officials: There is no disagreement with the audit finding. Prior to FY23 students signed a form acknowledging and authorizing the College to have credit balances held on their account in the event there would be classes added and to purchase books. During FY23 this procedure was discontinued for an unrelated reason and an unintended consequence was not meeting the 14-day requirement. The College is in the process of developing a new procedure which will be implemented in January, 2025.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted the College did not have adequate internal controls designed for properly documented reviews of return of title IV calculations or direct loan reconciliations. Questioned costs: None Context: During our testing, the College did not have formal documentation that return of title IV calculations or direct loan reconciliations were reviewed and approved. Cause: The College did not have formal procedures in place to review return of title IV calculations or direct loan reconciliations. Effect: If not properly reviewed, the College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned. Also, the direct loan reconciliations could have errors that would not be detected timely. Repeat Finding: No Recommendation: We recommend the College implement policies and procedures surrounding reviews of return of title IV calculations and direct loan reconciliations. Views of responsible officials: There is no disagreement with the audit finding. The return of title IV calculations and the direct loan reconciliations are generated by Colleague and verified by a Financial Aid Staff member utilizing a different method for the calculation. Effective immediately the Financial Director will review the calculation and initial approval.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as "financial institutions" and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the College to establish and maintain effective internal controls over Federal awards. Condition: During our testing of the College's information technology, we noted the College did not maintain a comprehensive written security program that included the minimum required elements. Questioned costs: None Context: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Cause: The College has continued to make progress in updating the College to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Effect: The student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend the College work to update the written security program to ensure compliance with all of the required elements. Views of responsible officials: There is no disagreement with the audit finding. While the College's "written" information security program did not include the minimum requirements, all required activities were being performed. The College is in the process of updating its written information security program to achieve compliance with the Gramm-Leach-Bliley Act.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per Uniform Guidance 34 CFR 668.164(h)(2)(i), title IV credit balance must be paid directly to the student no later than 14 days after the balance occurred. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing, 41 out of 51 credit balance refunds were returned later than 14 days after the credit balance occurred in student account. Questioned costs: None Context: The College was returning credit balance refunds longer than 14 days after they occurred. Cause: The College was holding financial aid balance until student's purchased bookstore items on student accounts. Effect: The students did not have access to their credit balance refunds timely. Repeat Finding: No Recommendation: We recommend the college update procedures around disbursements of credit balances and implement controls to ensure credit balances are being returned timely. Views of responsible officials: There is no disagreement with the audit finding. Prior to FY23 students signed a form acknowledging and authorizing the College to have credit balances held on their account in the event there would be classes added and to purchase books. During FY23 this procedure was discontinued for an unrelated reason and an unintended consequence was not meeting the 14-day requirement. The College is in the process of developing a new procedure which will be implemented in January, 2025.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted the College did not have adequate internal controls designed for properly documented reviews of return of title IV calculations or direct loan reconciliations. Questioned costs: None Context: During our testing, the College did not have formal documentation that return of title IV calculations or direct loan reconciliations were reviewed and approved. Cause: The College did not have formal procedures in place to review return of title IV calculations or direct loan reconciliations. Effect: If not properly reviewed, the College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned. Also, the direct loan reconciliations could have errors that would not be detected timely. Repeat Finding: No Recommendation: We recommend the College implement policies and procedures surrounding reviews of return of title IV calculations and direct loan reconciliations. Views of responsible officials: There is no disagreement with the audit finding. The return of title IV calculations and the direct loan reconciliations are generated by Colleague and verified by a Financial Aid Staff member utilizing a different method for the calculation. Effective immediately the Financial Director will review the calculation and initial approval.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as "financial institutions" and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the College to establish and maintain effective internal controls over Federal awards. Condition: During our testing of the College's information technology, we noted the College did not maintain a comprehensive written security program that included the minimum required elements. Questioned costs: None Context: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Cause: The College has continued to make progress in updating the College to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Effect: The student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend the College work to update the written security program to ensure compliance with all of the required elements. Views of responsible officials: There is no disagreement with the audit finding. While the College's "written" information security program did not include the minimum requirements, all required activities were being performed. The College is in the process of updating its written information security program to achieve compliance with the Gramm-Leach-Bliley Act.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per Uniform Guidance 34 CFR 668.164(h)(2)(i), title IV credit balance must be paid directly to the student no later than 14 days after the balance occurred. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing, 41 out of 51 credit balance refunds were returned later than 14 days after the credit balance occurred in student account. Questioned costs: None Context: The College was returning credit balance refunds longer than 14 days after they occurred. Cause: The College was holding financial aid balance until student's purchased bookstore items on student accounts. Effect: The students did not have access to their credit balance refunds timely. Repeat Finding: No Recommendation: We recommend the college update procedures around disbursements of credit balances and implement controls to ensure credit balances are being returned timely. Views of responsible officials: There is no disagreement with the audit finding. Prior to FY23 students signed a form acknowledging and authorizing the College to have credit balances held on their account in the event there would be classes added and to purchase books. During FY23 this procedure was discontinued for an unrelated reason and an unintended consequence was not meeting the 14-day requirement. The College is in the process of developing a new procedure which will be implemented in January, 2025.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted the College did not have adequate internal controls designed for properly documented reviews of return of title IV calculations or direct loan reconciliations. Questioned costs: None Context: During our testing, the College did not have formal documentation that return of title IV calculations or direct loan reconciliations were reviewed and approved. Cause: The College did not have formal procedures in place to review return of title IV calculations or direct loan reconciliations. Effect: If not properly reviewed, the College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned. Also, the direct loan reconciliations could have errors that would not be detected timely. Repeat Finding: No Recommendation: We recommend the College implement policies and procedures surrounding reviews of return of title IV calculations and direct loan reconciliations. Views of responsible officials: There is no disagreement with the audit finding. The return of title IV calculations and the direct loan reconciliations are generated by Colleague and verified by a Financial Aid Staff member utilizing a different method for the calculation. Effective immediately the Financial Director will review the calculation and initial approval.
Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as "financial institutions" and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the College to establish and maintain effective internal controls over Federal awards. Condition: During our testing of the College's information technology, we noted the College did not maintain a comprehensive written security program that included the minimum required elements. Questioned costs: None Context: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Cause: The College has continued to make progress in updating the College to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Effect: The student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend the College work to update the written security program to ensure compliance with all of the required elements. Views of responsible officials: There is no disagreement with the audit finding. While the College's "written" information security program did not include the minimum requirements, all required activities were being performed. The College is in the process of updating its written information security program to achieve compliance with the Gramm-Leach-Bliley Act.
Finding: Special Tests and Provisions (Assessment System Security) Federal Assistance Listing Number 84.010A – Title I Passed-Through Colorado Department of Education Award Number – 4010, 5010, 6010, 7010, 9202, 90204, 9205, 9206, 9211, 9212, 9213, 9214; Award Year 2024 Criteria: According to 2 CFR Part 200.303 – The non-Federal entity must (a) 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). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District did not have documentation that the internal controls in place over the Assessment System Security compliance requirement were always followed. Questioned Costs: None. Context: The District was unable to provide supporting documentation that the internal controls in place over the Assessment System Security compliance requirement were followed during 2024 for two of the sixteen schools tested. As a result, we were unable to rely on internal controls over this compliance requirement. Effect: The District did not have adequate internal controls in place over Assessment System Security requirements, which could result in an assessment system that is not valid, reliable or consistent with the terms and conditions of the Federal award. Cause: As there were no checklists in place, employees within the responsible department were unaware the internal controls in place over the Assessment System Security process were part of their duties. Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's Grant Administration team and Assessment Administration team create a checklist to ensure that all required internal controls are completed. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
Finding: Special Tests and Provisions (Assessment System Security) Federal Assistance Listing Number 84.010A – Title I Passed-Through Colorado Department of Education Award Number – 4010, 5010, 6010, 7010, 9202, 90204, 9205, 9206, 9211, 9212, 9213, 9214; Award Year 2024 Criteria: According to 2 CFR Part 200.303 – The non-Federal entity must (a) 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). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District did not have documentation that the internal controls in place over the Assessment System Security compliance requirement were always followed. Questioned Costs: None. Context: The District was unable to provide supporting documentation that the internal controls in place over the Assessment System Security compliance requirement were followed during 2024 for two of the sixteen schools tested. As a result, we were unable to rely on internal controls over this compliance requirement. Effect: The District did not have adequate internal controls in place over Assessment System Security requirements, which could result in an assessment system that is not valid, reliable or consistent with the terms and conditions of the Federal award. Cause: As there were no checklists in place, employees within the responsible department were unaware the internal controls in place over the Assessment System Security process were part of their duties. Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's Grant Administration team and Assessment Administration team create a checklist to ensure that all required internal controls are completed. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
Finding: Special Tests and Provisions (Assessment System Security) Federal Assistance Listing Number 84.010A – Title I Passed-Through Colorado Department of Education Award Number – 4010, 5010, 6010, 7010, 9202, 90204, 9205, 9206, 9211, 9212, 9213, 9214; Award Year 2024 Criteria: According to 2 CFR Part 200.303 – The non-Federal entity must (a) 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). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District did not have documentation that the internal controls in place over the Assessment System Security compliance requirement were always followed. Questioned Costs: None. Context: The District was unable to provide supporting documentation that the internal controls in place over the Assessment System Security compliance requirement were followed during 2024 for two of the sixteen schools tested. As a result, we were unable to rely on internal controls over this compliance requirement. Effect: The District did not have adequate internal controls in place over Assessment System Security requirements, which could result in an assessment system that is not valid, reliable or consistent with the terms and conditions of the Federal award. Cause: As there were no checklists in place, employees within the responsible department were unaware the internal controls in place over the Assessment System Security process were part of their duties. Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's Grant Administration team and Assessment Administration team create a checklist to ensure that all required internal controls are completed. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
Finding: Special Tests and Provisions (Assessment System Security) Federal Assistance Listing Number 84.010A – Title I Passed-Through Colorado Department of Education Award Number – 4010, 5010, 6010, 7010, 9202, 90204, 9205, 9206, 9211, 9212, 9213, 9214; Award Year 2024 Criteria: According to 2 CFR Part 200.303 – The non-Federal entity must (a) 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). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District did not have documentation that the internal controls in place over the Assessment System Security compliance requirement were always followed. Questioned Costs: None. Context: The District was unable to provide supporting documentation that the internal controls in place over the Assessment System Security compliance requirement were followed during 2024 for two of the sixteen schools tested. As a result, we were unable to rely on internal controls over this compliance requirement. Effect: The District did not have adequate internal controls in place over Assessment System Security requirements, which could result in an assessment system that is not valid, reliable or consistent with the terms and conditions of the Federal award. Cause: As there were no checklists in place, employees within the responsible department were unaware the internal controls in place over the Assessment System Security process were part of their duties. Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's Grant Administration team and Assessment Administration team create a checklist to ensure that all required internal controls are completed. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
Finding: Special Tests and Provisions (Assessment System Security) Federal Assistance Listing Number 84.010A – Title I Passed-Through Colorado Department of Education Award Number – 4010, 5010, 6010, 7010, 9202, 90204, 9205, 9206, 9211, 9212, 9213, 9214; Award Year 2024 Criteria: According to 2 CFR Part 200.303 – The non-Federal entity must (a) 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). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District did not have documentation that the internal controls in place over the Assessment System Security compliance requirement were always followed. Questioned Costs: None. Context: The District was unable to provide supporting documentation that the internal controls in place over the Assessment System Security compliance requirement were followed during 2024 for two of the sixteen schools tested. As a result, we were unable to rely on internal controls over this compliance requirement. Effect: The District did not have adequate internal controls in place over Assessment System Security requirements, which could result in an assessment system that is not valid, reliable or consistent with the terms and conditions of the Federal award. Cause: As there were no checklists in place, employees within the responsible department were unaware the internal controls in place over the Assessment System Security process were part of their duties. Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's Grant Administration team and Assessment Administration team create a checklist to ensure that all required internal controls are completed. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
Finding: Special Tests and Provisions (Assessment System Security) Federal Assistance Listing Number 84.010A – Title I Passed-Through Colorado Department of Education Award Number – 4010, 5010, 6010, 7010, 9202, 90204, 9205, 9206, 9211, 9212, 9213, 9214; Award Year 2024 Criteria: According to 2 CFR Part 200.303 – The non-Federal entity must (a) 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). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District did not have documentation that the internal controls in place over the Assessment System Security compliance requirement were always followed. Questioned Costs: None. Context: The District was unable to provide supporting documentation that the internal controls in place over the Assessment System Security compliance requirement were followed during 2024 for two of the sixteen schools tested. As a result, we were unable to rely on internal controls over this compliance requirement. Effect: The District did not have adequate internal controls in place over Assessment System Security requirements, which could result in an assessment system that is not valid, reliable or consistent with the terms and conditions of the Federal award. Cause: As there were no checklists in place, employees within the responsible department were unaware the internal controls in place over the Assessment System Security process were part of their duties. Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's Grant Administration team and Assessment Administration team create a checklist to ensure that all required internal controls are completed. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
Finding: Special Tests and Provisions (Assessment System Security) Federal Assistance Listing Number 84.010A – Title I Passed-Through Colorado Department of Education Award Number – 4010, 5010, 6010, 7010, 9202, 90204, 9205, 9206, 9211, 9212, 9213, 9214; Award Year 2024 Criteria: According to 2 CFR Part 200.303 – The non-Federal entity must (a) 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). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District did not have documentation that the internal controls in place over the Assessment System Security compliance requirement were always followed. Questioned Costs: None. Context: The District was unable to provide supporting documentation that the internal controls in place over the Assessment System Security compliance requirement were followed during 2024 for two of the sixteen schools tested. As a result, we were unable to rely on internal controls over this compliance requirement. Effect: The District did not have adequate internal controls in place over Assessment System Security requirements, which could result in an assessment system that is not valid, reliable or consistent with the terms and conditions of the Federal award. Cause: As there were no checklists in place, employees within the responsible department were unaware the internal controls in place over the Assessment System Security process were part of their duties. Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's Grant Administration team and Assessment Administration team create a checklist to ensure that all required internal controls are completed. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
Finding: Special Tests and Provisions (Assessment System Security) Federal Assistance Listing Number 84.010A – Title I Passed-Through Colorado Department of Education Award Number – 4010, 5010, 6010, 7010, 9202, 90204, 9205, 9206, 9211, 9212, 9213, 9214; Award Year 2024 Criteria: According to 2 CFR Part 200.303 – The non-Federal entity must (a) 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). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District did not have documentation that the internal controls in place over the Assessment System Security compliance requirement were always followed. Questioned Costs: None. Context: The District was unable to provide supporting documentation that the internal controls in place over the Assessment System Security compliance requirement were followed during 2024 for two of the sixteen schools tested. As a result, we were unable to rely on internal controls over this compliance requirement. Effect: The District did not have adequate internal controls in place over Assessment System Security requirements, which could result in an assessment system that is not valid, reliable or consistent with the terms and conditions of the Federal award. Cause: As there were no checklists in place, employees within the responsible department were unaware the internal controls in place over the Assessment System Security process were part of their duties. Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's Grant Administration team and Assessment Administration team create a checklist to ensure that all required internal controls are completed. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
Finding: Special Tests and Provisions (Assessment System Security) Federal Assistance Listing Number 84.010A – Title I Passed-Through Colorado Department of Education Award Number – 4010, 5010, 6010, 7010, 9202, 90204, 9205, 9206, 9211, 9212, 9213, 9214; Award Year 2024 Criteria: According to 2 CFR Part 200.303 – The non-Federal entity must (a) 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). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District did not have documentation that the internal controls in place over the Assessment System Security compliance requirement were always followed. Questioned Costs: None. Context: The District was unable to provide supporting documentation that the internal controls in place over the Assessment System Security compliance requirement were followed during 2024 for two of the sixteen schools tested. As a result, we were unable to rely on internal controls over this compliance requirement. Effect: The District did not have adequate internal controls in place over Assessment System Security requirements, which could result in an assessment system that is not valid, reliable or consistent with the terms and conditions of the Federal award. Cause: As there were no checklists in place, employees within the responsible department were unaware the internal controls in place over the Assessment System Security process were part of their duties. Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's Grant Administration team and Assessment Administration team create a checklist to ensure that all required internal controls are completed. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
Finding: Special Tests and Provisions (Assessment System Security) Federal Assistance Listing Number 84.010A – Title I Passed-Through Colorado Department of Education Award Number – 4010, 5010, 6010, 7010, 9202, 90204, 9205, 9206, 9211, 9212, 9213, 9214; Award Year 2024 Criteria: According to 2 CFR Part 200.303 – The non-Federal entity must (a) 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). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District did not have documentation that the internal controls in place over the Assessment System Security compliance requirement were always followed. Questioned Costs: None. Context: The District was unable to provide supporting documentation that the internal controls in place over the Assessment System Security compliance requirement were followed during 2024 for two of the sixteen schools tested. As a result, we were unable to rely on internal controls over this compliance requirement. Effect: The District did not have adequate internal controls in place over Assessment System Security requirements, which could result in an assessment system that is not valid, reliable or consistent with the terms and conditions of the Federal award. Cause: As there were no checklists in place, employees within the responsible department were unaware the internal controls in place over the Assessment System Security process were part of their duties. Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's Grant Administration team and Assessment Administration team create a checklist to ensure that all required internal controls are completed. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
Finding: Special Tests and Provisions (Assessment System Security) Federal Assistance Listing Number 84.010A – Title I Passed-Through Colorado Department of Education Award Number – 4010, 5010, 6010, 7010, 9202, 90204, 9205, 9206, 9211, 9212, 9213, 9214; Award Year 2024 Criteria: According to 2 CFR Part 200.303 – The non-Federal entity must (a) 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). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District did not have documentation that the internal controls in place over the Assessment System Security compliance requirement were always followed. Questioned Costs: None. Context: The District was unable to provide supporting documentation that the internal controls in place over the Assessment System Security compliance requirement were followed during 2024 for two of the sixteen schools tested. As a result, we were unable to rely on internal controls over this compliance requirement. Effect: The District did not have adequate internal controls in place over Assessment System Security requirements, which could result in an assessment system that is not valid, reliable or consistent with the terms and conditions of the Federal award. Cause: As there were no checklists in place, employees within the responsible department were unaware the internal controls in place over the Assessment System Security process were part of their duties. Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's Grant Administration team and Assessment Administration team create a checklist to ensure that all required internal controls are completed. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
Finding: Special Tests and Provisions (Assessment System Security) Federal Assistance Listing Number 84.010A – Title I Passed-Through Colorado Department of Education Award Number – 4010, 5010, 6010, 7010, 9202, 90204, 9205, 9206, 9211, 9212, 9213, 9214; Award Year 2024 Criteria: According to 2 CFR Part 200.303 – The non-Federal entity must (a) 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). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District did not have documentation that the internal controls in place over the Assessment System Security compliance requirement were always followed. Questioned Costs: None. Context: The District was unable to provide supporting documentation that the internal controls in place over the Assessment System Security compliance requirement were followed during 2024 for two of the sixteen schools tested. As a result, we were unable to rely on internal controls over this compliance requirement. Effect: The District did not have adequate internal controls in place over Assessment System Security requirements, which could result in an assessment system that is not valid, reliable or consistent with the terms and conditions of the Federal award. Cause: As there were no checklists in place, employees within the responsible department were unaware the internal controls in place over the Assessment System Security process were part of their duties. Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's Grant Administration team and Assessment Administration team create a checklist to ensure that all required internal controls are completed. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
Finding: Item 2024-001 – Internal Controls over Federal Programs Significant Deficiency Federal Program – Refugee and Entrant Assistance State/Replacement Designee Administered Programs Assistance Listing Number – 93.566 Federal Award Number – 8309026721 Federal Agency – U.S. Department of Health and Human Services Pass-Through Entity – Oklahoma Department of Human Services Criteria: 2 CFR 200.303 requires that organizations receiving federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing Federal awards in compliance with Federal statutes, regulations and terms and conditions of the Federal award. Condition/context: Formal controls were not followed surrounding the following compliance requirement specified for this grant under 2 CFR Part 200, Appendix XI: Activities allowed or unallowed and allowable cost principles – payroll expenditures submitted for reimbursement included the allocation of an employee twice. Cause: A deficiency in the Organization's internal control policies resulted in inaccurate payroll expenditures submitted for reimbursement. Effect: Payroll expenditures charged to the grant were overbilled by $31,565. Questioned cost: $31,565 Repeat finding: This is not a repeat finding. Recommendation: The Organization should enhance existing internal control policies to ensure the accuracy of payroll expenditures being charged to the grant. View of responsible officials: Management's response is reported in "Corrective Action Plan" at the end of this report.
2024-001 Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: None Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211837-01 Award Period: 3/3/2021 – 12/31/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal 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. These internal controls should comply with the 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).Condition/Context: For one of five vendors selected for testing, the Board was unable to provide documentation that it had verified the suspension and debarment status before entering into covered transactions with the vendor. Questioned Costs: There are no questioned costs related to this finding as the vendor was not federally suspended or debarred. Cause: The Board’s procedures and internal controls over suspension and debarment are not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: No Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: There is no disagreement with the finding.
2024-002 Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: None Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211837-01 Award Period: 3/3/2021 – 12/31/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Control: Per 2 CFR section 200.303(a), a non-Federal 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. These internal controls should comply with the 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). Condition/Context: The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland State Department of Education (MSDE). MSDE utilizes these reports as reimbursement requests and subsequently submits payment to the Board based on reported expenditures. For one of four monthly FSR selected for testing, the August 2023 report, the Board was unable to provide documentation that it had reviewed and approved the report prior to submission to MSDE. Questioned Costs: There are no questioned costs related to this finding as the FSR was properly supported by underlying documentation of the associated expenditures. Cause: The Board did not have sufficient policies and procedures over internal controls to maintain evidence of review and approval of the FSR reports until November 2023. Effect: The lack of a formal review and approval process could result in inaccurate amounts reported and reimbursed for the Federal programs. Repeat Finding: NoRecommendation: We recommend that the Board continue with established policies and procedures implemented in November 2023 to ensure that documentation supporting the Board’s review and approval of the monthly FSR reimbursement requests are retained for audit purposes. Views of responsible officials: There is no disagreement with the finding.
2024-002 Internal Control over Compliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Payroll Activities Identification of the Federal Program: Federal Agency: United States Housing & Urban Development Program Name: Community Development Block Grant - Disaster Recovery Whole Community Resilience Planning Program Assistance Listing Number: 14.228 Award Number: B-17-DM-72-0001 Passthrough Entity: Government of Puerto Rico Department of Housing Pass-Through Entity Identifying Number: FFNMUBT6WCM1 Sub-award Period: 1/30/2023-9/30/2024 Criteria - The Code of Federal Regulations 2 CFR 200.303, Internal Control, requires the non-federal entity to establish and maintain effective internal control over Federal awards that provides reasonable assurance that the non-federal entity is managing Federal awards in compliance with Federal statutes, regulations, and other terms and conditions. Per 2 CFR Section 200.430 Compensation – Personal Services: “Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity’s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.” 2 CFR Section 200.430(i): “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.” Condition – During the audit, we noted that the Trust has a system of internal control in whichemployees who charge time to the Federal programs, are required to complete a timeslip and have their Timeslips reports reviewed and approved by the employees’ supervisors on a monthly basis. During our testing, we noted that five out of seven employees selected for testing charged time to the Federal program between July 1, 2023 and April 30, 2024, but the timeslips reports were not reviewed and approved by their supervisors until June 2024. There was a lack of timely approval of hours charged to the federal program by the supervisors. However, we validated that the employees who charged time to the federal awards as part of our sample selection were included in the budgets for the federal programs. Cause – The Trust did not follow its documented policies and procedures in place to ensure compliance with the requirements regarding activities allowed or unallowed and allowable costs/cost principles – payroll activities. Effect or Potential Effect - Without timely approvals that the personnel costs charged are accurate, the Trust is not able to demonstrate that key elements in a system of internal control over the recording of time exists. Questioned Costs - None. Context - This is a condition identified based upon our review of the Trust’s compliance with specified requirements. The sample was selected based on a non-statistical basis. The prevalence of these findings is detailed in the condition section above. Repeat finding - This is not a repeat finding. Recommendation - We recommend that the Trust strengthen its current policies and procedures to ensure that payroll costs charged to federal awards are supported by a system of internal controls that allows for timely employee preparation, certification, and supervisory approval of time charged to the federal awards. Views of Responsible Officials – Time charged to this program had to be captured both as part of the billing process to the Federal funder, United States Housing and Urban Development (HUD) and through Timeslips system as required by internal policy. Time entries were downloaded from the Timeslips system and formatted for approvals using a time certification form template as required and approved by HUD. Billing to HUD occurs monthly. However, there were significant delays by HUD in reviewing and approving monthly invoices along with frequent changes to the requested documentation needed to substantiate costs. Although internal Timeslips reports were available for review and approval on a monthly basis, the program manager’s approvals were only documented on the time certification form as required by HUD. As a result, evidence of timely approvals on a monthly basis were not available as internal policy states. Procedures will be enforced to ensure that program managers are documenting approvals for hours charged to all federal awards according to both federal and internal policies as required on a monthly basis.
Criteria or specific requirement: The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62). The Code of Federal Regulations (34 CFR 690.80(b)(1)) states if the student’s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure students are awarded and disbursed the proper federal fund amounts. Condition: During our eligibility testing, we identified that 2 out of 38 students who received Pell grants were over awarded and overpaid. The explanation provided indicated that the system packages Pell awards based on the annual award, divides it to calculate per-term disbursements, and then rounds the amounts up or down. CLA recalculated the awards using the annual award and found that the system was incorrectly rounding up, resulting in the over awards. Questioned Costs: None Context: During our eligibility testing of thirty-eight students who received Pell, we noted two students that were over awarded and overpaid in Pell grants. Cause: The software that is used to auto package Pell awards has rounding rules inconsistent with that of the rules outlined in the Federal Student Aid handbook and was rounding amounts up when then it should have been rounded down. Effect: A student received more aid than they were eligible for. Repeat Finding: No. Recommendation: The College changed systems since the end of this fiscal year, and we recommend the College review the auto-packaging rounding rules of its new system to ensure that the Pell award is calculated in accordance with federal regulations. Views of responsible officials: There is no disagreement with the finding.
Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted two of the 20 Pell grant disbursements were not reported to COD timely. Additionally, we did not note evidence of a key control occurring for COD disbursement reporting. Questioned Costs: None Context: During our eligibility testing, we noted two of 20 Pell disbursements were not reported to COD within 15 days of the disbursement date. Additionally, we did not note evidence of a key control occurring for COD disbursement reporting. Cause: The College did not have proper control or procedures in place to verify disbursements were reported to COD within the required 15 days after disbursement. Effect: A lack of timely reporting may prevent the College and other schools from having the most accurate student information which may lead to over awards. Repeat Finding: Yes. Prior year finding 2023-002. Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. In addition, the College should revise their procedures to include documentation of the key control. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted two of the 20 Pell grant disbursements were not reported to COD timely. Additionally, we did not note evidence of a key control occurring for COD disbursement reporting. Questioned Costs: None Context: During our eligibility testing, we noted two of 20 Pell disbursements were not reported to COD within 15 days of the disbursement date. Additionally, we did not note evidence of a key control occurring for COD disbursement reporting. Cause: The College did not have proper control or procedures in place to verify disbursements were reported to COD within the required 15 days after disbursement. Effect: A lack of timely reporting may prevent the College and other schools from having the most accurate student information which may lead to over awards. Repeat Finding: Yes. Prior year finding 2023-002. Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. In addition, the College should revise their procedures to include documentation of the key control. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR part 200 section 200.303 requires that non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. The Code of federal Regulations, 34 CFR 688.164, requires any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. If a check or an EFT is returned, the College may make additional attempts to deliver the funds, provided that those attempts are made no later than 45 days after the funds were returned or rejected. In case where the College does not make another attempt, the funds must be returned before the end of the initial 45-day period. The College must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. Under no circumstances may unclaimed Title IV FSA funds escheat to the state, or revert to the college, or any other third party. Condition: The College does not have a control or process in place that would specifically monitor outstanding checks to students for Title IV federal funded checks so that the College would be able to timely return the money prior to 240 days after issuance of the check. Questioned Costs: None Context: During our testing, it was noted the College did not have a control in place to identify the outstanding Title IV federal funded checks that were old and needed to be returned to the U.S. Department of Education prior to 240 days after issuance. During our testing of outstanding checks, we did not note any checks that were out of compliance with this requirement. Cause: The College did not have a process in place to specifically monitor the federal checks throughout the year. Effect: The College is not in compliance with Department of Education requirements. Repeat Finding: No. Recommendation: We recommend the College review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR part 200 section 200.303 requires that non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. The Code of federal Regulations, 34 CFR 688.164, requires any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. If a check or an EFT is returned, the College may make additional attempts to deliver the funds, provided that those attempts are made no later than 45 days after the funds were returned or rejected. In case where the College does not make another attempt, the funds must be returned before the end of the initial 45-day period. The College must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. Under no circumstances may unclaimed Title IV FSA funds escheat to the state, or revert to the college, or any other third party. Condition: The College does not have a control or process in place that would specifically monitor outstanding checks to students for Title IV federal funded checks so that the College would be able to timely return the money prior to 240 days after issuance of the check. Questioned Costs: None Context: During our testing, it was noted the College did not have a control in place to identify the outstanding Title IV federal funded checks that were old and needed to be returned to the U.S. Department of Education prior to 240 days after issuance. During our testing of outstanding checks, we did not note any checks that were out of compliance with this requirement. Cause: The College did not have a process in place to specifically monitor the federal checks throughout the year. Effect: The College is not in compliance with Department of Education requirements. Repeat Finding: No. Recommendation: We recommend the College review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Views of responsible officials: There is no disagreement with the audit finding.