FINDING 2024-006 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425U, 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): 7000S425U210013, S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the following compliance requirements: Reporting. The School Corporation was required to submit an annual data report to the Indiana Department of Education via JotForm. Data to be submitted includes, but not limited to, current period expenditures, prior period expenditures, and expenditures per activity. Additionally, the School Corporation was required to submit an annual data report to the Indiana Department of Education via the 3E LEA ESSER III American Rescue Plan Annual Performance Report (Annual Performance Reports). Data to be submitted includes, but is not limited to, current period expenditures and expenditures per activity. During the audit period, the School Corporation submitted the 2021-2022 data report for ESSER I - Year 3, ESSER II - Year 2, ESSER III - Year 2, and 2022-2023 data report for ESSER II - Year 3 and ESSER III - Year 3. The reports were prepared by one employee and reviewed by another employee; however, the established internal control did not allow for the prevention, or detection and correction, of errors prior to submission. The ESSER III - Year 3 report which should have covered the period of July 1, 2022 to June 30, 2023, covered the prior year (July 1, 2021 to June 30, 2022) data information. Also, the expenditures reported in the ESSER I - Year 3 and ESSER III - Year 2 submissions did not agree to underlying supporting documentation. Additionally, an internal control was not designed or implemented over submission of the Annual Performance Reports. The Annual Performance Reports were prepared by one employee without a documented oversight and review process to allow for the prevention, or detection and correction, of errors prior to submission. Criteria 2 CFR 200.303 states in part: "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). . . ." Cause Management did not develop a system of internal controls that ensured that reports submitted were for the correct activity period and supported by underlying accounting records. Effect Reports submitted to the Federal Grantor Agency did not accurately reflect the expenditure activity of the School Corporation for the reporting periods as noted in the Condition and Context above. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls, including segregation of duties, related to the grant agreement and compliance requirements listed above. An internal control system, including segregation of duties, should be designed and operate effectively to provide reasonable assurance that material noncompliance with the grant agreement or a compliance requirement of a federal program will be prevented, or detected and corrected, on a timely basis. In order to have an effective internal control system, it is important to have proper segregation of duties. This is accomplished by making sure proper oversight, reviews, and approvals take place and to have a separation of functions over certain activities related to the program. The fundamental premise of segregation of duties is that an individual or small group of individuals should not be in a position to initiate, approve, undertake, and review the same activity. The internal controls should also have documentation to evidence that the control was in place. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-006 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425U, 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): 7000S425U210013, S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the following compliance requirements: Reporting. The School Corporation was required to submit an annual data report to the Indiana Department of Education via JotForm. Data to be submitted includes, but not limited to, current period expenditures, prior period expenditures, and expenditures per activity. Additionally, the School Corporation was required to submit an annual data report to the Indiana Department of Education via the 3E LEA ESSER III American Rescue Plan Annual Performance Report (Annual Performance Reports). Data to be submitted includes, but is not limited to, current period expenditures and expenditures per activity. During the audit period, the School Corporation submitted the 2021-2022 data report for ESSER I - Year 3, ESSER II - Year 2, ESSER III - Year 2, and 2022-2023 data report for ESSER II - Year 3 and ESSER III - Year 3. The reports were prepared by one employee and reviewed by another employee; however, the established internal control did not allow for the prevention, or detection and correction, of errors prior to submission. The ESSER III - Year 3 report which should have covered the period of July 1, 2022 to June 30, 2023, covered the prior year (July 1, 2021 to June 30, 2022) data information. Also, the expenditures reported in the ESSER I - Year 3 and ESSER III - Year 2 submissions did not agree to underlying supporting documentation. Additionally, an internal control was not designed or implemented over submission of the Annual Performance Reports. The Annual Performance Reports were prepared by one employee without a documented oversight and review process to allow for the prevention, or detection and correction, of errors prior to submission. Criteria 2 CFR 200.303 states in part: "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). . . ." Cause Management did not develop a system of internal controls that ensured that reports submitted were for the correct activity period and supported by underlying accounting records. Effect Reports submitted to the Federal Grantor Agency did not accurately reflect the expenditure activity of the School Corporation for the reporting periods as noted in the Condition and Context above. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls, including segregation of duties, related to the grant agreement and compliance requirements listed above. An internal control system, including segregation of duties, should be designed and operate effectively to provide reasonable assurance that material noncompliance with the grant agreement or a compliance requirement of a federal program will be prevented, or detected and corrected, on a timely basis. In order to have an effective internal control system, it is important to have proper segregation of duties. This is accomplished by making sure proper oversight, reviews, and approvals take place and to have a separation of functions over certain activities related to the program. The fundamental premise of segregation of duties is that an individual or small group of individuals should not be in a position to initiate, approve, undertake, and review the same activity. The internal controls should also have documentation to evidence that the control was in place. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-006 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425U, 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): 7000S425U210013, S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the following compliance requirements: Reporting. The School Corporation was required to submit an annual data report to the Indiana Department of Education via JotForm. Data to be submitted includes, but not limited to, current period expenditures, prior period expenditures, and expenditures per activity. Additionally, the School Corporation was required to submit an annual data report to the Indiana Department of Education via the 3E LEA ESSER III American Rescue Plan Annual Performance Report (Annual Performance Reports). Data to be submitted includes, but is not limited to, current period expenditures and expenditures per activity. During the audit period, the School Corporation submitted the 2021-2022 data report for ESSER I - Year 3, ESSER II - Year 2, ESSER III - Year 2, and 2022-2023 data report for ESSER II - Year 3 and ESSER III - Year 3. The reports were prepared by one employee and reviewed by another employee; however, the established internal control did not allow for the prevention, or detection and correction, of errors prior to submission. The ESSER III - Year 3 report which should have covered the period of July 1, 2022 to June 30, 2023, covered the prior year (July 1, 2021 to June 30, 2022) data information. Also, the expenditures reported in the ESSER I - Year 3 and ESSER III - Year 2 submissions did not agree to underlying supporting documentation. Additionally, an internal control was not designed or implemented over submission of the Annual Performance Reports. The Annual Performance Reports were prepared by one employee without a documented oversight and review process to allow for the prevention, or detection and correction, of errors prior to submission. Criteria 2 CFR 200.303 states in part: "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). . . ." Cause Management did not develop a system of internal controls that ensured that reports submitted were for the correct activity period and supported by underlying accounting records. Effect Reports submitted to the Federal Grantor Agency did not accurately reflect the expenditure activity of the School Corporation for the reporting periods as noted in the Condition and Context above. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls, including segregation of duties, related to the grant agreement and compliance requirements listed above. An internal control system, including segregation of duties, should be designed and operate effectively to provide reasonable assurance that material noncompliance with the grant agreement or a compliance requirement of a federal program will be prevented, or detected and corrected, on a timely basis. In order to have an effective internal control system, it is important to have proper segregation of duties. This is accomplished by making sure proper oversight, reviews, and approvals take place and to have a separation of functions over certain activities related to the program. The fundamental premise of segregation of duties is that an individual or small group of individuals should not be in a position to initiate, approve, undertake, and review the same activity. The internal controls should also have documentation to evidence that the control was in place. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-006 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425U, 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): 7000S425U210013, S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the following compliance requirements: Reporting. The School Corporation was required to submit an annual data report to the Indiana Department of Education via JotForm. Data to be submitted includes, but not limited to, current period expenditures, prior period expenditures, and expenditures per activity. Additionally, the School Corporation was required to submit an annual data report to the Indiana Department of Education via the 3E LEA ESSER III American Rescue Plan Annual Performance Report (Annual Performance Reports). Data to be submitted includes, but is not limited to, current period expenditures and expenditures per activity. During the audit period, the School Corporation submitted the 2021-2022 data report for ESSER I - Year 3, ESSER II - Year 2, ESSER III - Year 2, and 2022-2023 data report for ESSER II - Year 3 and ESSER III - Year 3. The reports were prepared by one employee and reviewed by another employee; however, the established internal control did not allow for the prevention, or detection and correction, of errors prior to submission. The ESSER III - Year 3 report which should have covered the period of July 1, 2022 to June 30, 2023, covered the prior year (July 1, 2021 to June 30, 2022) data information. Also, the expenditures reported in the ESSER I - Year 3 and ESSER III - Year 2 submissions did not agree to underlying supporting documentation. Additionally, an internal control was not designed or implemented over submission of the Annual Performance Reports. The Annual Performance Reports were prepared by one employee without a documented oversight and review process to allow for the prevention, or detection and correction, of errors prior to submission. Criteria 2 CFR 200.303 states in part: "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). . . ." Cause Management did not develop a system of internal controls that ensured that reports submitted were for the correct activity period and supported by underlying accounting records. Effect Reports submitted to the Federal Grantor Agency did not accurately reflect the expenditure activity of the School Corporation for the reporting periods as noted in the Condition and Context above. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls, including segregation of duties, related to the grant agreement and compliance requirements listed above. An internal control system, including segregation of duties, should be designed and operate effectively to provide reasonable assurance that material noncompliance with the grant agreement or a compliance requirement of a federal program will be prevented, or detected and corrected, on a timely basis. In order to have an effective internal control system, it is important to have proper segregation of duties. This is accomplished by making sure proper oversight, reviews, and approvals take place and to have a separation of functions over certain activities related to the program. The fundamental premise of segregation of duties is that an individual or small group of individuals should not be in a position to initiate, approve, undertake, and review the same activity. The internal controls should also have documentation to evidence that the control was in place. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Finding 2024‐002 Procurement Information on the federal/state program: Federal Programs: Research and Development Cluster (R&D) ALN: 93.855 Criteria or specific requirement (including statutory, regulatory or other citation): Federal Program 2 CFR 200.303(a) requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.318 (i) General Procurement Standards states, “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” Condition: The College did not maintain records for procurements sufficient to detail the history of procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Questioned costs: $65,815 Section III – Federal Award Findings and Questioned Costs (continued) Context: EY selected and tested 8 procurements over $50,000 with expenditures totaling, $1,779,434 from a population of $8,490,052 procurements over $50,000 during the year ended June 30, 2024. Of the 8 expenditures selected for testing 1 procurement totaling $65,815 did not have evidence of sole source justification. Effect or potential effect: The College did not comply with the general procurement standards and methods of procurement to be followed per the Uniform Guidance to maintain sufficient detail of the history of the procurement, including the rationale of the method of procurement. Cause: The College did not have effective internal controls and procedures in place to ensure the College maintained records for procurements sufficient to detail the history of procurement, including the rationale for the method of procurement and other required elements. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should retain written documentation for procurements, documenting the history of the procurement prior to the procurement of goods or services including, but not limited to, the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure that documentation is retained for sole source procurements.
Finding 2024‐002 Procurement Information on the federal/state program: Federal Programs: Research and Development Cluster (R&D) ALN: 93.855 Criteria or specific requirement (including statutory, regulatory or other citation): Federal Program 2 CFR 200.303(a) requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.318 (i) General Procurement Standards states, “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” Condition: The College did not maintain records for procurements sufficient to detail the history of procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Questioned costs: $65,815 Section III – Federal Award Findings and Questioned Costs (continued) Context: EY selected and tested 8 procurements over $50,000 with expenditures totaling, $1,779,434 from a population of $8,490,052 procurements over $50,000 during the year ended June 30, 2024. Of the 8 expenditures selected for testing 1 procurement totaling $65,815 did not have evidence of sole source justification. Effect or potential effect: The College did not comply with the general procurement standards and methods of procurement to be followed per the Uniform Guidance to maintain sufficient detail of the history of the procurement, including the rationale of the method of procurement. Cause: The College did not have effective internal controls and procedures in place to ensure the College maintained records for procurements sufficient to detail the history of procurement, including the rationale for the method of procurement and other required elements. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should retain written documentation for procurements, documenting the history of the procurement prior to the procurement of goods or services including, but not limited to, the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure that documentation is retained for sole source procurements.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.
Finding 2024‐003 Indirect Cost Information on the federal/state program: Federal Award agency; Research and Development Cluster COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: Various 21.027 Criteria or specific requirement (including statutory, regulatory or other citation): Internal Controls Federal Awards 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Condition: The College did not retain documentation and evidence of review of the indirect cost amounts being charged to the R&D and CSLFRF programs. Management performed a monthly control that included reviewing a sample of indirect costs charged to grants on a sample basis. The College had a new ERP implementation that went into effect on January 1, 2024. Management did not perform the monthly control subsequent to the ERP implementation for the last 6 months of year. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (continued) Context: During our testing over indirect cost, we selected 2 months during FY24 to test managements control. We observed that during FY24, BCM had a mid year ERP implementation in January 2024. After the ERP implementation, management no longer performed the monthly control for the remainder of FY24. As such for 6 months during FY24, the control was not in place. Effect or potential effect: The incorrect indirect cost rate could be applied to a grant. Cause: Management’s internal control over the review and approval of indirect cost expenditures for compliance was not consistently documented. Identification as a repeat finding, if applicable: This is not a repeat finding Recommendation: The College should reassess its internal controls over the review and approval of indirect cost expenditures post ERP implementation and ensure documentation is retained to evidence review and approval to support the allowability of the expenditure. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to ensure indirect costs are reviewed.