FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D20013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not designed, nor implemented, at the School Corporationto ensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. The Reports were prepared byone employee without an oversite or review process in place to prevent, or detect and correct, errors.Additionally, one of the four Reports tested was not supported by the School Corporation's records.The financial information provided did not agree to all the data submitted in the Report; therefore, we couldnot determine the accuracy of the Report. Additionally, two of six key line items selected for testing couldnot be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor annually, from the date of the submission of the quarterly or annual financial report, respectively,as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.. . ."34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Reporting compliance requirement could resultin the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D20013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not designed, nor implemented, at the School Corporationto ensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. The Reports were prepared byone employee without an oversite or review process in place to prevent, or detect and correct, errors.Additionally, one of the four Reports tested was not supported by the School Corporation's records.The financial information provided did not agree to all the data submitted in the Report; therefore, we couldnot determine the accuracy of the Report. Additionally, two of six key line items selected for testing couldnot be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor annually, from the date of the submission of the quarterly or annual financial report, respectively,as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.. . ."34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Reporting compliance requirement could resultin the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D20013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not designed, nor implemented, at the School Corporationto ensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. The Reports were prepared byone employee without an oversite or review process in place to prevent, or detect and correct, errors.Additionally, one of the four Reports tested was not supported by the School Corporation's records.The financial information provided did not agree to all the data submitted in the Report; therefore, we couldnot determine the accuracy of the Report. Additionally, two of six key line items selected for testing couldnot be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor annually, from the date of the submission of the quarterly or annual financial report, respectively,as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.. . ."34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Reporting compliance requirement could resultin the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Criteria: 2 CFR 200.328 requires non-Federal entities to submit performance reports at an interval required by the Federal awarding agency or pass-through entity. Further, at a minimum Annual reports must be due 90 calendar days after the reporting period; quarterly or semiannual reports must be due 30 calendar days after the reporting period. Condition: The Auditor requested support for reporting as required under various grant award agreements for assistance listing 14.218. The Auditor noted multiple instances in which required demographic information, monthly, quarterly, or cumulative annual reports were either not evidenced as being submitted or were not submitted timely. Cause: CAC staff did not submit reporting as required by the grant award agreements. Management tasked with reviewing the grant award compliance requirements and ensuring reporting compliance for report submissions did not properly review or maintain the record of the required grant award reporting submissions. Effect: CAC was not in compliance with the requirements of 2 CFR 200.328 and the terms and conditions of the grant agreements. Recommendation: CAC management should ensure all reporting requirements documented in awards contracts are summarized in a written format and easily accessible. Additionally, CAC staff associated with the program should be trained to ensure deadlines are met. Views of Responsible Official(s) and Planned Corrective Actions: See the accompanying "Management's Corrective Action Plan."
Criteria: 2 CFR 200.328 requires non-Federal entities to submit performance reports at an interval required by the Federal awarding agency or pass-through entity. Further, at a minimum Annual reports must be due 90 calendar days after the reporting period; quarterly or semiannual reports must be due 30 calendar days after the reporting period. Condition: The Auditor requested support for reporting as required under various grant award agreements for assistance listing 14.218. The Auditor noted multiple instances in which required demographic information, monthly, quarterly, or cumulative annual reports were either not evidenced as being submitted or were not submitted timely. Cause: CAC staff did not submit reporting as required by the grant award agreements. Management tasked with reviewing the grant award compliance requirements and ensuring reporting compliance for report submissions did not properly review or maintain the record of the required grant award reporting submissions. Effect: CAC was not in compliance with the requirements of 2 CFR 200.328 and the terms and conditions of the grant agreements. Recommendation: CAC management should ensure all reporting requirements documented in awards contracts are summarized in a written format and easily accessible. Additionally, CAC staff associated with the program should be trained to ensure deadlines are met. Views of Responsible Official(s) and Planned Corrective Actions: See the accompanying "Management's Corrective Action Plan."
Criteria: 2 CFR 200.328 requires non-Federal entities to submit performance reports at an interval required by the Federal awarding agency or pass-through entity. Further, at a minimum Annual reports must be due 90 calendar days after the reporting period; quarterly or semiannual reports must be due 30 calendar days after the reporting period. Condition: The Auditor requested support for reporting as required under various grant award agreements for assistance listing 14.218. The Auditor noted multiple instances in which required demographic information, monthly, quarterly, or cumulative annual reports were either not evidenced as being submitted or were not submitted timely. Cause: CAC staff did not submit reporting as required by the grant award agreements. Management tasked with reviewing the grant award compliance requirements and ensuring reporting compliance for report submissions did not properly review or maintain the record of the required grant award reporting submissions. Effect: CAC was not in compliance with the requirements of 2 CFR 200.328 and the terms and conditions of the grant agreements. Recommendation: CAC management should ensure all reporting requirements documented in awards contracts are summarized in a written format and easily accessible. Additionally, CAC staff associated with the program should be trained to ensure deadlines are met. Views of Responsible Official(s) and Planned Corrective Actions: See the accompanying "Management's Corrective Action Plan."
Criteria: 2 CFR 200.328 requires non-Federal entities to submit performance reports at an interval required by the Federal awarding agency or pass-through entity. Further, at a minimum Annual reports must be due 90 calendar days after the reporting period; quarterly or semiannual reports must be due 30 calendar days after the reporting period. Condition: The Auditor requested support for reporting as required under various grant award agreements for assistance listing 14.218. The Auditor noted multiple instances in which required demographic information, monthly, quarterly, or cumulative annual reports were either not evidenced as being submitted or were not submitted timely. Cause: CAC staff did not submit reporting as required by the grant award agreements. Management tasked with reviewing the grant award compliance requirements and ensuring reporting compliance for report submissions did not properly review or maintain the record of the required grant award reporting submissions. Effect: CAC was not in compliance with the requirements of 2 CFR 200.328 and the terms and conditions of the grant agreements. Recommendation: CAC management should ensure all reporting requirements documented in awards contracts are summarized in a written format and easily accessible. Additionally, CAC staff associated with the program should be trained to ensure deadlines are met. Views of Responsible Official(s) and Planned Corrective Actions: See the accompanying "Management's Corrective Action Plan."
Criteria: 2 CFR 200.328 requires non-Federal entities to submit performance reports at an interval required by the Federal awarding agency or pass-through entity. Further, at a minimum Annual reports must be due 90 calendar days after the reporting period; quarterly or semiannual reports must be due 30 calendar days after the reporting period. Condition: The Auditor requested support for reporting as required under various grant award agreements for assistance listing 14.218. The Auditor noted multiple instances in which required demographic information, monthly, quarterly, or cumulative annual reports were either not evidenced as being submitted or were not submitted timely. Cause: CAC staff did not submit reporting as required by the grant award agreements. Management tasked with reviewing the grant award compliance requirements and ensuring reporting compliance for report submissions did not properly review or maintain the record of the required grant award reporting submissions. Effect: CAC was not in compliance with the requirements of 2 CFR 200.328 and the terms and conditions of the grant agreements. Recommendation: CAC management should ensure all reporting requirements documented in awards contracts are summarized in a written format and easily accessible. Additionally, CAC staff associated with the program should be trained to ensure deadlines are met. Views of Responsible Official(s) and Planned Corrective Actions: See the accompanying "Management's Corrective Action Plan."
Criteria: 2 CFR 200.328 requires non-Federal entities to submit performance reports at an interval required by the Federal awarding agency or pass-through entity. Further, at a minimum Annual reports must be due 90 calendar days after the reporting period; quarterly or semiannual reports must be due 30 calendar days after the reporting period. Condition: The Auditor requested support for reporting as required under various grant award agreements for assistance listing 14.218. The Auditor noted multiple instances in which required demographic information, monthly, quarterly, or cumulative annual reports were either not evidenced as being submitted or were not submitted timely. Cause: CAC staff did not submit reporting as required by the grant award agreements. Management tasked with reviewing the grant award compliance requirements and ensuring reporting compliance for report submissions did not properly review or maintain the record of the required grant award reporting submissions. Effect: CAC was not in compliance with the requirements of 2 CFR 200.328 and the terms and conditions of the grant agreements. Recommendation: CAC management should ensure all reporting requirements documented in awards contracts are summarized in a written format and easily accessible. Additionally, CAC staff associated with the program should be trained to ensure deadlines are met. Views of Responsible Official(s) and Planned Corrective Actions: See the accompanying "Management's Corrective Action Plan."
Criteria: 2 CFR 200.328 requires non-Federal entities to submit performance reports at an interval required by the Federal awarding agency or pass-through entity. Further, at a minimum Annual reports must be due 90 calendar days after the reporting period; quarterly or semiannual reports must be due 30 calendar days after the reporting period. Condition: The Auditor requested support for reporting as required under various grant award agreements for assistance listing 14.218. The Auditor noted multiple instances in which required demographic information, monthly, quarterly, or cumulative annual reports were either not evidenced as being submitted or were not submitted timely. Cause: CAC staff did not submit reporting as required by the grant award agreements. Management tasked with reviewing the grant award compliance requirements and ensuring reporting compliance for report submissions did not properly review or maintain the record of the required grant award reporting submissions. Effect: CAC was not in compliance with the requirements of 2 CFR 200.328 and the terms and conditions of the grant agreements. Recommendation: CAC management should ensure all reporting requirements documented in awards contracts are summarized in a written format and easily accessible. Additionally, CAC staff associated with the program should be trained to ensure deadlines are met. Views of Responsible Official(s) and Planned Corrective Actions: See the accompanying "Management's Corrective Action Plan."
Criteria: 2 CFR 200.328 requires non-Federal entities to submit performance reports at an interval required by the Federal awarding agency or pass-through entity. Further, at a minimum Annual reports must be due 90 calendar days after the reporting period; quarterly or semiannual reports must be due 30 calendar days after the reporting period. Condition: The Auditor requested support for reporting as required under various grant award agreements for assistance listing 14.218. The Auditor noted multiple instances in which required demographic information, monthly, quarterly, or cumulative annual reports were either not evidenced as being submitted or were not submitted timely. Cause: CAC staff did not submit reporting as required by the grant award agreements. Management tasked with reviewing the grant award compliance requirements and ensuring reporting compliance for report submissions did not properly review or maintain the record of the required grant award reporting submissions. Effect: CAC was not in compliance with the requirements of 2 CFR 200.328 and the terms and conditions of the grant agreements. Recommendation: CAC management should ensure all reporting requirements documented in awards contracts are summarized in a written format and easily accessible. Additionally, CAC staff associated with the program should be trained to ensure deadlines are met. Views of Responsible Official(s) and Planned Corrective Actions: See the accompanying "Management's Corrective Action Plan."
2022-005 — Reporting – Significant Deficiency in Internal Control Over Compliance and Noncompliance (Repeat of Finding 2021-002 and 2020-004) Federal program information: Funding agencies: U.S. Department of Interior and U.S. Department of Education Titles: Assistance to Tribally Controlled Community Colleges; Higher Education Institutional Aid; and Education Stabilization Fund ALN Number: 15.027, 84.031, and 84.425 Award years: Various Criteria: According to 2 CFR Section 200.328, nonfederal entities may be required to submit performance reports at least annually as required by the terms of the federal award. In addition, ALN 84.425 requires quarterly expenditure and budget reports. Condition: The College did not submit annual performance reports on time for all three programs. The annual report for ALN 84.031 was inaccurate. In addition, two quarterly reports required for ALN 84.425 were not submitted timely. Cause: The College did not have sufficient procedures in place to ensure that the reports were completed timely and accurately. Effect: The three annual reports and two quarterly reports examined were submitted after the required time and one report was inaccurate. Questioned Costs: None Context: The annual reports and two quarterly reports were not submitted timely and one report was not accurate. Recommendation: The College should ensure that all grant reports are prepared in a timely manner and are accurate. View of Responsible Officials: The College will ensure that all grant reports are reviewed in detail and information reported will be traced to the source reports by the reviewer. The College also implemented policies and procedures to ensure all grant reports are submitted prior to the due date.
2022-005 — Reporting – Significant Deficiency in Internal Control Over Compliance and Noncompliance (Repeat of Finding 2021-002 and 2020-004) Federal program information: Funding agencies: U.S. Department of Interior and U.S. Department of Education Titles: Assistance to Tribally Controlled Community Colleges; Higher Education Institutional Aid; and Education Stabilization Fund ALN Number: 15.027, 84.031, and 84.425 Award years: Various Criteria: According to 2 CFR Section 200.328, nonfederal entities may be required to submit performance reports at least annually as required by the terms of the federal award. In addition, ALN 84.425 requires quarterly expenditure and budget reports. Condition: The College did not submit annual performance reports on time for all three programs. The annual report for ALN 84.031 was inaccurate. In addition, two quarterly reports required for ALN 84.425 were not submitted timely. Cause: The College did not have sufficient procedures in place to ensure that the reports were completed timely and accurately. Effect: The three annual reports and two quarterly reports examined were submitted after the required time and one report was inaccurate. Questioned Costs: None Context: The annual reports and two quarterly reports were not submitted timely and one report was not accurate. Recommendation: The College should ensure that all grant reports are prepared in a timely manner and are accurate. View of Responsible Officials: The College will ensure that all grant reports are reviewed in detail and information reported will be traced to the source reports by the reviewer. The College also implemented policies and procedures to ensure all grant reports are submitted prior to the due date.
2022-005 — Reporting – Significant Deficiency in Internal Control Over Compliance and Noncompliance (Repeat of Finding 2021-002 and 2020-004) Federal program information: Funding agencies: U.S. Department of Interior and U.S. Department of Education Titles: Assistance to Tribally Controlled Community Colleges; Higher Education Institutional Aid; and Education Stabilization Fund ALN Number: 15.027, 84.031, and 84.425 Award years: Various Criteria: According to 2 CFR Section 200.328, nonfederal entities may be required to submit performance reports at least annually as required by the terms of the federal award. In addition, ALN 84.425 requires quarterly expenditure and budget reports. Condition: The College did not submit annual performance reports on time for all three programs. The annual report for ALN 84.031 was inaccurate. In addition, two quarterly reports required for ALN 84.425 were not submitted timely. Cause: The College did not have sufficient procedures in place to ensure that the reports were completed timely and accurately. Effect: The three annual reports and two quarterly reports examined were submitted after the required time and one report was inaccurate. Questioned Costs: None Context: The annual reports and two quarterly reports were not submitted timely and one report was not accurate. Recommendation: The College should ensure that all grant reports are prepared in a timely manner and are accurate. View of Responsible Officials: The College will ensure that all grant reports are reviewed in detail and information reported will be traced to the source reports by the reviewer. The College also implemented policies and procedures to ensure all grant reports are submitted prior to the due date.
2022-005 — Reporting – Significant Deficiency in Internal Control Over Compliance and Noncompliance (Repeat of Finding 2021-002 and 2020-004) Federal program information: Funding agencies: U.S. Department of Interior and U.S. Department of Education Titles: Assistance to Tribally Controlled Community Colleges; Higher Education Institutional Aid; and Education Stabilization Fund ALN Number: 15.027, 84.031, and 84.425 Award years: Various Criteria: According to 2 CFR Section 200.328, nonfederal entities may be required to submit performance reports at least annually as required by the terms of the federal award. In addition, ALN 84.425 requires quarterly expenditure and budget reports. Condition: The College did not submit annual performance reports on time for all three programs. The annual report for ALN 84.031 was inaccurate. In addition, two quarterly reports required for ALN 84.425 were not submitted timely. Cause: The College did not have sufficient procedures in place to ensure that the reports were completed timely and accurately. Effect: The three annual reports and two quarterly reports examined were submitted after the required time and one report was inaccurate. Questioned Costs: None Context: The annual reports and two quarterly reports were not submitted timely and one report was not accurate. Recommendation: The College should ensure that all grant reports are prepared in a timely manner and are accurate. View of Responsible Officials: The College will ensure that all grant reports are reviewed in detail and information reported will be traced to the source reports by the reviewer. The College also implemented policies and procedures to ensure all grant reports are submitted prior to the due date.
2022-005 — Reporting – Significant Deficiency in Internal Control Over Compliance and Noncompliance (Repeat of Finding 2021-002 and 2020-004) Federal program information: Funding agencies: U.S. Department of Interior and U.S. Department of Education Titles: Assistance to Tribally Controlled Community Colleges; Higher Education Institutional Aid; and Education Stabilization Fund ALN Number: 15.027, 84.031, and 84.425 Award years: Various Criteria: According to 2 CFR Section 200.328, nonfederal entities may be required to submit performance reports at least annually as required by the terms of the federal award. In addition, ALN 84.425 requires quarterly expenditure and budget reports. Condition: The College did not submit annual performance reports on time for all three programs. The annual report for ALN 84.031 was inaccurate. In addition, two quarterly reports required for ALN 84.425 were not submitted timely. Cause: The College did not have sufficient procedures in place to ensure that the reports were completed timely and accurately. Effect: The three annual reports and two quarterly reports examined were submitted after the required time and one report was inaccurate. Questioned Costs: None Context: The annual reports and two quarterly reports were not submitted timely and one report was not accurate. Recommendation: The College should ensure that all grant reports are prepared in a timely manner and are accurate. View of Responsible Officials: The College will ensure that all grant reports are reviewed in detail and information reported will be traced to the source reports by the reviewer. The College also implemented policies and procedures to ensure all grant reports are submitted prior to the due date.
2022-005 — Reporting – Significant Deficiency in Internal Control Over Compliance and Noncompliance (Repeat of Finding 2021-002 and 2020-004) Federal program information: Funding agencies: U.S. Department of Interior and U.S. Department of Education Titles: Assistance to Tribally Controlled Community Colleges; Higher Education Institutional Aid; and Education Stabilization Fund ALN Number: 15.027, 84.031, and 84.425 Award years: Various Criteria: According to 2 CFR Section 200.328, nonfederal entities may be required to submit performance reports at least annually as required by the terms of the federal award. In addition, ALN 84.425 requires quarterly expenditure and budget reports. Condition: The College did not submit annual performance reports on time for all three programs. The annual report for ALN 84.031 was inaccurate. In addition, two quarterly reports required for ALN 84.425 were not submitted timely. Cause: The College did not have sufficient procedures in place to ensure that the reports were completed timely and accurately. Effect: The three annual reports and two quarterly reports examined were submitted after the required time and one report was inaccurate. Questioned Costs: None Context: The annual reports and two quarterly reports were not submitted timely and one report was not accurate. Recommendation: The College should ensure that all grant reports are prepared in a timely manner and are accurate. View of Responsible Officials: The College will ensure that all grant reports are reviewed in detail and information reported will be traced to the source reports by the reviewer. The College also implemented policies and procedures to ensure all grant reports are submitted prior to the due date.
Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
Federal Agency: Department of Education Federal Programs: COVID-19 – Education Stabilization Fund Assistance Listing Numbers: 84.425E, 84.425F, 84.425K Federal Award Identification Number and Year: P425E200449, P425F204781, P425K200022 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. There are three components to reporting for Higher Education Emergency Relief Funds (HEERF): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: The College is not in compliance with Quarterly and Annual reporting requirements for HEERF. Questioned Costs: None. Context: Out of 2 Quarterly Institutional and 2 Quarterly Student reports tested all 4 reports were not submitted timely. In addition, the annual report was not submitted timely. Cause: The College did not have appropriate controls in place to ensure reports were completed and published to the institution’s website in a timely manner. Effect: The institution is not meeting the reporting and information-sharing requirements determined by the Department of Education. As a result, the institution may be subject to additional enforcement actions by the Department of Education including a delay in funding for additional HEERF programs and possibly being determined ineligible for other program funding. Repeat Finding: No. Recommendation: We recommend the College review the reporting requirements and implement procedures to ensure that all required reports are issued/posted in an accurate and timely manner. Views of Responsible Officials: Management agrees with the finding and has prepared a plan to correct the finding.
Finding 2022-007: Significant Deficiency - Reporting Program: COVID-19 - Education Stabilization Fund CFDA Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E200145, P425F202178, P425M201123 Federal Award Year: June 30, 2022 Repeat of Prior Year Finding 2021-005 Criteria: The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education (ED) exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: For the annual report covering January 1, 2021 through December 31, 2021, the University reported the Strengthening Institutions Program funding spent in calendar year 2022 within its 2021 annual report. In addition, for the third quarter 2021 (quarter ending September 30, 2021) and the first quarter 2022 (quarter ending March 31, 2022) institutional portion reports, the University reported the full amount of section (a)(2) Strengthening Institutions Program funding awarded to the University on the section (a)(3) line, when the amount should have been included on the section (a)(2) line. For the third quarter 2021 institutional portion report, the University also reported the lost revenue claimed under the institutional portion of section (a)(1) in the section (a)(2) column, when the amount should have been included in the section (a)(1) column. Also, for the quarterly student portion reports, the University reported the student grants awarded, the number of students eligible to receive a student grant, and the number of students who received a student grant for each individual quarter and not cumulatively from the start of the programs. Questioned Costs: Not applicable. Context: Errors were noted in the one annual report, two quarterly institutional portion reports, and two quarterly student portion reports that were tested. The University was required to file one annual report, four quarterly institutional portion reports, and four quarterly student portion reports during the fiscal year. The sample was not considered statistically valid. Effect: The information included on the publicly-available reports and reports submitted to federal agencies was not accurate. Cause: The exceptions noted on the reports resulted from various factors, including misunderstanding of how reports were intended to be completed and turnover during the year in key personnel associated with preparing and reviewing the reports. Recommendation: It is recommended that the guidance surrounding the preparation of the annual and quarterly reports be reviewed. In addition, the review of reports by someone who is not the original preparer of the reports should include a detailed tie out of numbers included on the reports to the University's supporting documentation. Management's Response: The University agrees with the finding. While the University did not provide the public with data in accordance with the above noted columns and cumulative amounts in the top section related to the HEERF Institutional Aid Portion, the amounts listed and what they were expensed for was correct. Based on the information provided to the University by the Department of Education (ED) and attending other webinars regarding reporting requirements, the University believed it had filed the reports correctly. The University's initial report was reviewed and accepted by ED on June 5, 2020. Based on that acceptance, the University thought it was doing the reports correctly. Since the finding was identified during the audit, the University has submitted the revised reports stated above. The University has a committee to monitor reporting requirements of federal awards consisting of key members of the Executive Team, Business Office, IT and the respective project director. On February 4, 2022, the University received notification from ED that the updated reports had been received, reviewed and added to its file.
Finding 2022-007: Significant Deficiency - Reporting Program: COVID-19 - Education Stabilization Fund CFDA Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E200145, P425F202178, P425M201123 Federal Award Year: June 30, 2022 Repeat of Prior Year Finding 2021-005 Criteria: The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education (ED) exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: For the annual report covering January 1, 2021 through December 31, 2021, the University reported the Strengthening Institutions Program funding spent in calendar year 2022 within its 2021 annual report. In addition, for the third quarter 2021 (quarter ending September 30, 2021) and the first quarter 2022 (quarter ending March 31, 2022) institutional portion reports, the University reported the full amount of section (a)(2) Strengthening Institutions Program funding awarded to the University on the section (a)(3) line, when the amount should have been included on the section (a)(2) line. For the third quarter 2021 institutional portion report, the University also reported the lost revenue claimed under the institutional portion of section (a)(1) in the section (a)(2) column, when the amount should have been included in the section (a)(1) column. Also, for the quarterly student portion reports, the University reported the student grants awarded, the number of students eligible to receive a student grant, and the number of students who received a student grant for each individual quarter and not cumulatively from the start of the programs. Questioned Costs: Not applicable. Context: Errors were noted in the one annual report, two quarterly institutional portion reports, and two quarterly student portion reports that were tested. The University was required to file one annual report, four quarterly institutional portion reports, and four quarterly student portion reports during the fiscal year. The sample was not considered statistically valid. Effect: The information included on the publicly-available reports and reports submitted to federal agencies was not accurate. Cause: The exceptions noted on the reports resulted from various factors, including misunderstanding of how reports were intended to be completed and turnover during the year in key personnel associated with preparing and reviewing the reports. Recommendation: It is recommended that the guidance surrounding the preparation of the annual and quarterly reports be reviewed. In addition, the review of reports by someone who is not the original preparer of the reports should include a detailed tie out of numbers included on the reports to the University's supporting documentation. Management's Response: The University agrees with the finding. While the University did not provide the public with data in accordance with the above noted columns and cumulative amounts in the top section related to the HEERF Institutional Aid Portion, the amounts listed and what they were expensed for was correct. Based on the information provided to the University by the Department of Education (ED) and attending other webinars regarding reporting requirements, the University believed it had filed the reports correctly. The University's initial report was reviewed and accepted by ED on June 5, 2020. Based on that acceptance, the University thought it was doing the reports correctly. Since the finding was identified during the audit, the University has submitted the revised reports stated above. The University has a committee to monitor reporting requirements of federal awards consisting of key members of the Executive Team, Business Office, IT and the respective project director. On February 4, 2022, the University received notification from ED that the updated reports had been received, reviewed and added to its file.
Finding 2022-007: Significant Deficiency - Reporting Program: COVID-19 - Education Stabilization Fund CFDA Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E200145, P425F202178, P425M201123 Federal Award Year: June 30, 2022 Repeat of Prior Year Finding 2021-005 Criteria: The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education (ED) exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: For the annual report covering January 1, 2021 through December 31, 2021, the University reported the Strengthening Institutions Program funding spent in calendar year 2022 within its 2021 annual report. In addition, for the third quarter 2021 (quarter ending September 30, 2021) and the first quarter 2022 (quarter ending March 31, 2022) institutional portion reports, the University reported the full amount of section (a)(2) Strengthening Institutions Program funding awarded to the University on the section (a)(3) line, when the amount should have been included on the section (a)(2) line. For the third quarter 2021 institutional portion report, the University also reported the lost revenue claimed under the institutional portion of section (a)(1) in the section (a)(2) column, when the amount should have been included in the section (a)(1) column. Also, for the quarterly student portion reports, the University reported the student grants awarded, the number of students eligible to receive a student grant, and the number of students who received a student grant for each individual quarter and not cumulatively from the start of the programs. Questioned Costs: Not applicable. Context: Errors were noted in the one annual report, two quarterly institutional portion reports, and two quarterly student portion reports that were tested. The University was required to file one annual report, four quarterly institutional portion reports, and four quarterly student portion reports during the fiscal year. The sample was not considered statistically valid. Effect: The information included on the publicly-available reports and reports submitted to federal agencies was not accurate. Cause: The exceptions noted on the reports resulted from various factors, including misunderstanding of how reports were intended to be completed and turnover during the year in key personnel associated with preparing and reviewing the reports. Recommendation: It is recommended that the guidance surrounding the preparation of the annual and quarterly reports be reviewed. In addition, the review of reports by someone who is not the original preparer of the reports should include a detailed tie out of numbers included on the reports to the University's supporting documentation. Management's Response: The University agrees with the finding. While the University did not provide the public with data in accordance with the above noted columns and cumulative amounts in the top section related to the HEERF Institutional Aid Portion, the amounts listed and what they were expensed for was correct. Based on the information provided to the University by the Department of Education (ED) and attending other webinars regarding reporting requirements, the University believed it had filed the reports correctly. The University's initial report was reviewed and accepted by ED on June 5, 2020. Based on that acceptance, the University thought it was doing the reports correctly. Since the finding was identified during the audit, the University has submitted the revised reports stated above. The University has a committee to monitor reporting requirements of federal awards consisting of key members of the Executive Team, Business Office, IT and the respective project director. On February 4, 2022, the University received notification from ED that the updated reports had been received, reviewed and added to its file.
Criteria: Reporting ? Per 2 CFR Part 200.328 and 2CFR Part 200.329, institutions must publicly display on their website the total number of students who have received an Emergency Financial Aid Grant. Institutions are required to submit quarterly budget and expenditure reports detailing institutional expenditures of HEERF funds. Condition: The institution?s count of number of students who have received an Emergency Financial Aid Grant disclosed on the website is not accurate. A quarterly report for institutional portion expenditures was not submitted accurately. Questioned Costs: None. Context: Students eligible to receive an Emergency Financial Aid Grant were reported incorrectly. We received the listing of students used for the reporting disclosures and performed recounts. For the September 30, 2021 disbursement, the College reported 1,291 students received emergency funding instead of the actual number, 1,517, a difference of 226 students. Additionally, for the December 31, 2021 disbursement, the College reported 1,291 students received emergency funding instead of the actual number, 1,514, a difference of 223 students. Finally, the 4th quarter institutional share report inaccurately stated all disbursements were for lost revenues instead of $122,346 being allocated for COVID related expenses. Effect: The disclosures on the website are not accurate. Cause: Internal controls were not adequately designed and implemented to ensure compliance with the program?s reporting requirements. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend implementing controls to ensure the College complies with the programs reporting compliance requirements. Views of Responsible Officials and Planned Corrective Actions: Administration concurs with the findings. The College has corrected the website disclosure of number of students receiving Aid Grants under the program. The College will review and confirm accuracy of any future report submissions. Anticipated Completion Date: May 31, 2023
Criteria: Reporting ? Per 2 CFR Part 200.328 and 2CFR Part 200.329, institutions must publicly display on their website the total number of students who have received an Emergency Financial Aid Grant. Institutions are required to submit quarterly budget and expenditure reports detailing institutional expenditures of HEERF funds. Condition: The institution?s count of number of students who have received an Emergency Financial Aid Grant disclosed on the website is not accurate. A quarterly report for institutional portion expenditures was not submitted accurately. Questioned Costs: None. Context: Students eligible to receive an Emergency Financial Aid Grant were reported incorrectly. We received the listing of students used for the reporting disclosures and performed recounts. For the September 30, 2021 disbursement, the College reported 1,291 students received emergency funding instead of the actual number, 1,517, a difference of 226 students. Additionally, for the December 31, 2021 disbursement, the College reported 1,291 students received emergency funding instead of the actual number, 1,514, a difference of 223 students. Finally, the 4th quarter institutional share report inaccurately stated all disbursements were for lost revenues instead of $122,346 being allocated for COVID related expenses. Effect: The disclosures on the website are not accurate. Cause: Internal controls were not adequately designed and implemented to ensure compliance with the program?s reporting requirements. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend implementing controls to ensure the College complies with the programs reporting compliance requirements. Views of Responsible Officials and Planned Corrective Actions: Administration concurs with the findings. The College has corrected the website disclosure of number of students receiving Aid Grants under the program. The College will review and confirm accuracy of any future report submissions. Anticipated Completion Date: May 31, 2023
Finding 2022-001 ? Significant Deficiency: COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Funds - Reporting Federal Program: COVID-19 Education Stabilization Fund Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number: 84.425E, 84.425F Federal Award Number: P425E200445 Federal Award Year: June 30, 2022 Criteria: Section 18004 of the Coronavirus Aid, Relief and Economic Security (CARES) ACT and Section 314(e) of the Coronavirus Response and Relief Supplemental Appropriations (CRRSAA) Act directs institutions receiving funds to promptly and timely provide detailed accounting of the use and expenditures for HEERF (Higher Education Emergency Relief Funds) I, HEERF II, and HEERF III funds. Each institution is required to share in an easily accessible public location quarterly reports (September 30, December 31, March 31, June 30). The reporting is required for both the Student Portion and the Institutional Portion. While the American Rescue Plan (ARP) does not explicitly identify procedures by which institutions submit a report to the Secretary, the Department exercises this reporting authority under 2 CFR 200.328 and 2 CFR 200.329. Condition/Context: The College did not post the required quarterly reports for the Student Portion. Additionally, during the audit, it was noted that the College was unable to provide a copy of the annual report and supporting documentation for the year ended December 31, 2021. Cause: Staff turnover at the College was the primary factor leading to the issues noted above. Effect: The College did not provide the public and the Department with all required data related to HEERF and the Student Portion reports were not posted in a timely manner. Questioned Costs: Not applicable. Recommendation: The College should ensure it keeps up to date on the Department?s HEERF guidance and ensure that reporting is done accurately and timely. Management's Response: MCAD has experienced 100% turnover in the positions responsible for submitting the HEERF reporting. The internal data supporting these reports is accessible for future reporting to be done in a timely manner.
Finding 2022-001 ? Significant Deficiency: COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Funds - Reporting Federal Program: COVID-19 Education Stabilization Fund Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number: 84.425E, 84.425F Federal Award Number: P425E200445 Federal Award Year: June 30, 2022 Criteria: Section 18004 of the Coronavirus Aid, Relief and Economic Security (CARES) ACT and Section 314(e) of the Coronavirus Response and Relief Supplemental Appropriations (CRRSAA) Act directs institutions receiving funds to promptly and timely provide detailed accounting of the use and expenditures for HEERF (Higher Education Emergency Relief Funds) I, HEERF II, and HEERF III funds. Each institution is required to share in an easily accessible public location quarterly reports (September 30, December 31, March 31, June 30). The reporting is required for both the Student Portion and the Institutional Portion. While the American Rescue Plan (ARP) does not explicitly identify procedures by which institutions submit a report to the Secretary, the Department exercises this reporting authority under 2 CFR 200.328 and 2 CFR 200.329. Condition/Context: The College did not post the required quarterly reports for the Student Portion. Additionally, during the audit, it was noted that the College was unable to provide a copy of the annual report and supporting documentation for the year ended December 31, 2021. Cause: Staff turnover at the College was the primary factor leading to the issues noted above. Effect: The College did not provide the public and the Department with all required data related to HEERF and the Student Portion reports were not posted in a timely manner. Questioned Costs: Not applicable. Recommendation: The College should ensure it keeps up to date on the Department?s HEERF guidance and ensure that reporting is done accurately and timely. Management's Response: MCAD has experienced 100% turnover in the positions responsible for submitting the HEERF reporting. The internal data supporting these reports is accessible for future reporting to be done in a timely manner.
Finding 2022-001 Federal program: Education Stabilization Fund -Higher Education Emergency Relief Fund (HEERF): COVID-19 CARES Act- Student Aid Portion AL #: 84.425E Award Year: 2021/2022 Type of finding: Deficiency and Noncompliance Compliance requirement: Reporting - Special Reporting Criteria: Under 2 CFR 200.328 and 200.329, Universities must publicly post certain information relating to Student Aid awards on their website no later than 30 days after award, and update that information within 10 days after the end of every calendar quarter by posting a new report. Condition: Due to the timing of the prior year finding being identified, the award notification report, and first and second quarter reports for FY 2022 were also not posted timely as required. No issues were noted with the accuracy of the disclosure, but the timing was past the required due date. Questioned costs: None Context: The Student Aid grant awards were not reported on the University?s website on a timely basis for the first and second quarters of FY22. Cause: The University established reporting processes according to the compliance supplement. However, in the process of assigning responsibility for each reporting requirement, this requirement of updating the HEERF award disclosures quarterly was missed. Effect: The HEERF Student Aid award information was not reported publicly on the University?s website. As a result, students and other interested parties did not have readily presented access to this data. Repeat finding: Yes ? 2021-001. The finding is limited to the HEERF Student Aid first and second quarter reporting of FY22. Recommendations: We recommend that the University have controls in place to ensure that all required reporting is performed timely. Views of responsible officials: HEERF was issued to institutions of higher education in the spring of 2020 to support students and campus operations in the midst of the COVID-19 pandemic. Quarterly reporting requirements were later established by the Department of Education. Student Aid grant award reporting was overlooked by the responsible official due to confusion of duty with the emergency relief program. When the prior-year finding was identified, a system of controls was established to ensure future compliance and timely reporting. Specifically, the responsible reporting officials for the institutional and student portions of HEERF funding combined report information into a single web posting request prior to the deadline each quarter. This single request provided another check for the posting official to confirm the quarterly report was comprehensive.
Finding 2022-007: Significant Deficiency - Reporting Program: COVID-19 - Education Stabilization Fund CFDA Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E200145, P425F202178, P425M201123 Federal Award Year: June 30, 2022 Repeat of Prior Year Finding 2021-005 Criteria: The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education (ED) exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: For the annual report covering January 1, 2021 through December 31, 2021, the University reported the Strengthening Institutions Program funding spent in calendar year 2022 within its 2021 annual report. In addition, for the third quarter 2021 (quarter ending September 30, 2021) and the first quarter 2022 (quarter ending March 31, 2022) institutional portion reports, the University reported the full amount of section (a)(2) Strengthening Institutions Program funding awarded to the University on the section (a)(3) line, when the amount should have been included on the section (a)(2) line. For the third quarter 2021 institutional portion report, the University also reported the lost revenue claimed under the institutional portion of section (a)(1) in the section (a)(2) column, when the amount should have been included in the section (a)(1) column. Also, for the quarterly student portion reports, the University reported the student grants awarded, the number of students eligible to receive a student grant, and the number of students who received a student grant for each individual quarter and not cumulatively from the start of the programs. Questioned Costs: Not applicable. Context: Errors were noted in the one annual report, two quarterly institutional portion reports, and two quarterly student portion reports that were tested. The University was required to file one annual report, four quarterly institutional portion reports, and four quarterly student portion reports during the fiscal year. The sample was not considered statistically valid. Effect: The information included on the publicly-available reports and reports submitted to federal agencies was not accurate. Cause: The exceptions noted on the reports resulted from various factors, including misunderstanding of how reports were intended to be completed and turnover during the year in key personnel associated with preparing and reviewing the reports. Recommendation: It is recommended that the guidance surrounding the preparation of the annual and quarterly reports be reviewed. In addition, the review of reports by someone who is not the original preparer of the reports should include a detailed tie out of numbers included on the reports to the University's supporting documentation. Management's Response: The University agrees with the finding. While the University did not provide the public with data in accordance with the above noted columns and cumulative amounts in the top section related to the HEERF Institutional Aid Portion, the amounts listed and what they were expensed for was correct. Based on the information provided to the University by the Department of Education (ED) and attending other webinars regarding reporting requirements, the University believed it had filed the reports correctly. The University's initial report was reviewed and accepted by ED on June 5, 2020. Based on that acceptance, the University thought it was doing the reports correctly. Since the finding was identified during the audit, the University has submitted the revised reports stated above. The University has a committee to monitor reporting requirements of federal awards consisting of key members of the Executive Team, Business Office, IT and the respective project director. On February 4, 2022, the University received notification from ED that the updated reports had been received, reviewed and added to its file.
Finding 2022-007: Significant Deficiency - Reporting Program: COVID-19 - Education Stabilization Fund CFDA Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E200145, P425F202178, P425M201123 Federal Award Year: June 30, 2022 Repeat of Prior Year Finding 2021-005 Criteria: The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education (ED) exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: For the annual report covering January 1, 2021 through December 31, 2021, the University reported the Strengthening Institutions Program funding spent in calendar year 2022 within its 2021 annual report. In addition, for the third quarter 2021 (quarter ending September 30, 2021) and the first quarter 2022 (quarter ending March 31, 2022) institutional portion reports, the University reported the full amount of section (a)(2) Strengthening Institutions Program funding awarded to the University on the section (a)(3) line, when the amount should have been included on the section (a)(2) line. For the third quarter 2021 institutional portion report, the University also reported the lost revenue claimed under the institutional portion of section (a)(1) in the section (a)(2) column, when the amount should have been included in the section (a)(1) column. Also, for the quarterly student portion reports, the University reported the student grants awarded, the number of students eligible to receive a student grant, and the number of students who received a student grant for each individual quarter and not cumulatively from the start of the programs. Questioned Costs: Not applicable. Context: Errors were noted in the one annual report, two quarterly institutional portion reports, and two quarterly student portion reports that were tested. The University was required to file one annual report, four quarterly institutional portion reports, and four quarterly student portion reports during the fiscal year. The sample was not considered statistically valid. Effect: The information included on the publicly-available reports and reports submitted to federal agencies was not accurate. Cause: The exceptions noted on the reports resulted from various factors, including misunderstanding of how reports were intended to be completed and turnover during the year in key personnel associated with preparing and reviewing the reports. Recommendation: It is recommended that the guidance surrounding the preparation of the annual and quarterly reports be reviewed. In addition, the review of reports by someone who is not the original preparer of the reports should include a detailed tie out of numbers included on the reports to the University's supporting documentation. Management's Response: The University agrees with the finding. While the University did not provide the public with data in accordance with the above noted columns and cumulative amounts in the top section related to the HEERF Institutional Aid Portion, the amounts listed and what they were expensed for was correct. Based on the information provided to the University by the Department of Education (ED) and attending other webinars regarding reporting requirements, the University believed it had filed the reports correctly. The University's initial report was reviewed and accepted by ED on June 5, 2020. Based on that acceptance, the University thought it was doing the reports correctly. Since the finding was identified during the audit, the University has submitted the revised reports stated above. The University has a committee to monitor reporting requirements of federal awards consisting of key members of the Executive Team, Business Office, IT and the respective project director. On February 4, 2022, the University received notification from ED that the updated reports had been received, reviewed and added to its file.
Finding 2022-007: Significant Deficiency - Reporting Program: COVID-19 - Education Stabilization Fund CFDA Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E200145, P425F202178, P425M201123 Federal Award Year: June 30, 2022 Repeat of Prior Year Finding 2021-005 Criteria: The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education (ED) exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: For the annual report covering January 1, 2021 through December 31, 2021, the University reported the Strengthening Institutions Program funding spent in calendar year 2022 within its 2021 annual report. In addition, for the third quarter 2021 (quarter ending September 30, 2021) and the first quarter 2022 (quarter ending March 31, 2022) institutional portion reports, the University reported the full amount of section (a)(2) Strengthening Institutions Program funding awarded to the University on the section (a)(3) line, when the amount should have been included on the section (a)(2) line. For the third quarter 2021 institutional portion report, the University also reported the lost revenue claimed under the institutional portion of section (a)(1) in the section (a)(2) column, when the amount should have been included in the section (a)(1) column. Also, for the quarterly student portion reports, the University reported the student grants awarded, the number of students eligible to receive a student grant, and the number of students who received a student grant for each individual quarter and not cumulatively from the start of the programs. Questioned Costs: Not applicable. Context: Errors were noted in the one annual report, two quarterly institutional portion reports, and two quarterly student portion reports that were tested. The University was required to file one annual report, four quarterly institutional portion reports, and four quarterly student portion reports during the fiscal year. The sample was not considered statistically valid. Effect: The information included on the publicly-available reports and reports submitted to federal agencies was not accurate. Cause: The exceptions noted on the reports resulted from various factors, including misunderstanding of how reports were intended to be completed and turnover during the year in key personnel associated with preparing and reviewing the reports. Recommendation: It is recommended that the guidance surrounding the preparation of the annual and quarterly reports be reviewed. In addition, the review of reports by someone who is not the original preparer of the reports should include a detailed tie out of numbers included on the reports to the University's supporting documentation. Management's Response: The University agrees with the finding. While the University did not provide the public with data in accordance with the above noted columns and cumulative amounts in the top section related to the HEERF Institutional Aid Portion, the amounts listed and what they were expensed for was correct. Based on the information provided to the University by the Department of Education (ED) and attending other webinars regarding reporting requirements, the University believed it had filed the reports correctly. The University's initial report was reviewed and accepted by ED on June 5, 2020. Based on that acceptance, the University thought it was doing the reports correctly. Since the finding was identified during the audit, the University has submitted the revised reports stated above. The University has a committee to monitor reporting requirements of federal awards consisting of key members of the Executive Team, Business Office, IT and the respective project director. On February 4, 2022, the University received notification from ED that the updated reports had been received, reviewed and added to its file.
Criteria: Reporting ? Per 2 CFR Part 200.328 and 2CFR Part 200.329, institutions must publicly display on their website the total number of students who have received an Emergency Financial Aid Grant. Institutions are required to submit quarterly budget and expenditure reports detailing institutional expenditures of HEERF funds. Condition: The institution?s count of number of students who have received an Emergency Financial Aid Grant disclosed on the website is not accurate. A quarterly report for institutional portion expenditures was not submitted accurately. Questioned Costs: None. Context: Students eligible to receive an Emergency Financial Aid Grant were reported incorrectly. We received the listing of students used for the reporting disclosures and performed recounts. For the September 30, 2021 disbursement, the College reported 1,291 students received emergency funding instead of the actual number, 1,517, a difference of 226 students. Additionally, for the December 31, 2021 disbursement, the College reported 1,291 students received emergency funding instead of the actual number, 1,514, a difference of 223 students. Finally, the 4th quarter institutional share report inaccurately stated all disbursements were for lost revenues instead of $122,346 being allocated for COVID related expenses. Effect: The disclosures on the website are not accurate. Cause: Internal controls were not adequately designed and implemented to ensure compliance with the program?s reporting requirements. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend implementing controls to ensure the College complies with the programs reporting compliance requirements. Views of Responsible Officials and Planned Corrective Actions: Administration concurs with the findings. The College has corrected the website disclosure of number of students receiving Aid Grants under the program. The College will review and confirm accuracy of any future report submissions. Anticipated Completion Date: May 31, 2023
Criteria: Reporting ? Per 2 CFR Part 200.328 and 2CFR Part 200.329, institutions must publicly display on their website the total number of students who have received an Emergency Financial Aid Grant. Institutions are required to submit quarterly budget and expenditure reports detailing institutional expenditures of HEERF funds. Condition: The institution?s count of number of students who have received an Emergency Financial Aid Grant disclosed on the website is not accurate. A quarterly report for institutional portion expenditures was not submitted accurately. Questioned Costs: None. Context: Students eligible to receive an Emergency Financial Aid Grant were reported incorrectly. We received the listing of students used for the reporting disclosures and performed recounts. For the September 30, 2021 disbursement, the College reported 1,291 students received emergency funding instead of the actual number, 1,517, a difference of 226 students. Additionally, for the December 31, 2021 disbursement, the College reported 1,291 students received emergency funding instead of the actual number, 1,514, a difference of 223 students. Finally, the 4th quarter institutional share report inaccurately stated all disbursements were for lost revenues instead of $122,346 being allocated for COVID related expenses. Effect: The disclosures on the website are not accurate. Cause: Internal controls were not adequately designed and implemented to ensure compliance with the program?s reporting requirements. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend implementing controls to ensure the College complies with the programs reporting compliance requirements. Views of Responsible Officials and Planned Corrective Actions: Administration concurs with the findings. The College has corrected the website disclosure of number of students receiving Aid Grants under the program. The College will review and confirm accuracy of any future report submissions. Anticipated Completion Date: May 31, 2023
Finding 2022-001 ? Significant Deficiency: COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Funds - Reporting Federal Program: COVID-19 Education Stabilization Fund Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number: 84.425E, 84.425F Federal Award Number: P425E200445 Federal Award Year: June 30, 2022 Criteria: Section 18004 of the Coronavirus Aid, Relief and Economic Security (CARES) ACT and Section 314(e) of the Coronavirus Response and Relief Supplemental Appropriations (CRRSAA) Act directs institutions receiving funds to promptly and timely provide detailed accounting of the use and expenditures for HEERF (Higher Education Emergency Relief Funds) I, HEERF II, and HEERF III funds. Each institution is required to share in an easily accessible public location quarterly reports (September 30, December 31, March 31, June 30). The reporting is required for both the Student Portion and the Institutional Portion. While the American Rescue Plan (ARP) does not explicitly identify procedures by which institutions submit a report to the Secretary, the Department exercises this reporting authority under 2 CFR 200.328 and 2 CFR 200.329. Condition/Context: The College did not post the required quarterly reports for the Student Portion. Additionally, during the audit, it was noted that the College was unable to provide a copy of the annual report and supporting documentation for the year ended December 31, 2021. Cause: Staff turnover at the College was the primary factor leading to the issues noted above. Effect: The College did not provide the public and the Department with all required data related to HEERF and the Student Portion reports were not posted in a timely manner. Questioned Costs: Not applicable. Recommendation: The College should ensure it keeps up to date on the Department?s HEERF guidance and ensure that reporting is done accurately and timely. Management's Response: MCAD has experienced 100% turnover in the positions responsible for submitting the HEERF reporting. The internal data supporting these reports is accessible for future reporting to be done in a timely manner.
Finding 2022-001 ? Significant Deficiency: COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Funds - Reporting Federal Program: COVID-19 Education Stabilization Fund Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number: 84.425E, 84.425F Federal Award Number: P425E200445 Federal Award Year: June 30, 2022 Criteria: Section 18004 of the Coronavirus Aid, Relief and Economic Security (CARES) ACT and Section 314(e) of the Coronavirus Response and Relief Supplemental Appropriations (CRRSAA) Act directs institutions receiving funds to promptly and timely provide detailed accounting of the use and expenditures for HEERF (Higher Education Emergency Relief Funds) I, HEERF II, and HEERF III funds. Each institution is required to share in an easily accessible public location quarterly reports (September 30, December 31, March 31, June 30). The reporting is required for both the Student Portion and the Institutional Portion. While the American Rescue Plan (ARP) does not explicitly identify procedures by which institutions submit a report to the Secretary, the Department exercises this reporting authority under 2 CFR 200.328 and 2 CFR 200.329. Condition/Context: The College did not post the required quarterly reports for the Student Portion. Additionally, during the audit, it was noted that the College was unable to provide a copy of the annual report and supporting documentation for the year ended December 31, 2021. Cause: Staff turnover at the College was the primary factor leading to the issues noted above. Effect: The College did not provide the public and the Department with all required data related to HEERF and the Student Portion reports were not posted in a timely manner. Questioned Costs: Not applicable. Recommendation: The College should ensure it keeps up to date on the Department?s HEERF guidance and ensure that reporting is done accurately and timely. Management's Response: MCAD has experienced 100% turnover in the positions responsible for submitting the HEERF reporting. The internal data supporting these reports is accessible for future reporting to be done in a timely manner.
Finding 2022-001 Federal program: Education Stabilization Fund -Higher Education Emergency Relief Fund (HEERF): COVID-19 CARES Act- Student Aid Portion AL #: 84.425E Award Year: 2021/2022 Type of finding: Deficiency and Noncompliance Compliance requirement: Reporting - Special Reporting Criteria: Under 2 CFR 200.328 and 200.329, Universities must publicly post certain information relating to Student Aid awards on their website no later than 30 days after award, and update that information within 10 days after the end of every calendar quarter by posting a new report. Condition: Due to the timing of the prior year finding being identified, the award notification report, and first and second quarter reports for FY 2022 were also not posted timely as required. No issues were noted with the accuracy of the disclosure, but the timing was past the required due date. Questioned costs: None Context: The Student Aid grant awards were not reported on the University?s website on a timely basis for the first and second quarters of FY22. Cause: The University established reporting processes according to the compliance supplement. However, in the process of assigning responsibility for each reporting requirement, this requirement of updating the HEERF award disclosures quarterly was missed. Effect: The HEERF Student Aid award information was not reported publicly on the University?s website. As a result, students and other interested parties did not have readily presented access to this data. Repeat finding: Yes ? 2021-001. The finding is limited to the HEERF Student Aid first and second quarter reporting of FY22. Recommendations: We recommend that the University have controls in place to ensure that all required reporting is performed timely. Views of responsible officials: HEERF was issued to institutions of higher education in the spring of 2020 to support students and campus operations in the midst of the COVID-19 pandemic. Quarterly reporting requirements were later established by the Department of Education. Student Aid grant award reporting was overlooked by the responsible official due to confusion of duty with the emergency relief program. When the prior-year finding was identified, a system of controls was established to ensure future compliance and timely reporting. Specifically, the responsible reporting officials for the institutional and student portions of HEERF funding combined report information into a single web posting request prior to the deadline each quarter. This single request provided another check for the posting official to confirm the quarterly report was comprehensive.
Criteria: Section 18004 of the Coronavirus Aid, Relief and Economic Security (CARES) ACT and Section 314(e) of the Coronavirus Response and Relief Supplemental Appropriations (CRRSAA) Act directs institutions receiving funds to promptly and timely provide detailed accounting of the use and expenditures for HEERF (Higher Education Emergency Relief Funds) I, HEERF II, and HEERF III funds. Each institution is required to share in an easily accessible public location quarterly reports (September 30, December 31, March 31, June 30). The reporting is required for both the Student Portion and the Institutional Portion. While the American Rescue Plan (ARP) does not explicitly identify procedures by which institutions submit a report to the Secretary, the Department exercises this reporting authority under 2 CFR 200.328 and 2 CFR 200.329. Condition/Context: The College did not post a report for the Student Portion of HEERF funds for the quarter ended June 30, 2021. This would have been the first quarter of HEERF III reporting and there were no funds disbursed to students during that quarter. The College posted to the website their quarterly report for September 30, 2021 with in the required timeframe. Upon review, it was noted that the report did not include the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CRRSAA and ARP (a)(1) and (a)(4) programs. Questioned Costs: Not applicable. Cause: The College missed the June 30th report as there were no expenditures from the Student Portion that quarter. The College also missed the requirement to report the estimated number of students eligible to receive Emergency Financial Aid Grants to Students. Effect: The College did not provide all of the information required for the HEERF Student Aid Portion. Recommendation: The College should correct the reporting to include the missing pieces. Management's Response: The College will update the September 30, 2021 quarterly report currently posted on the website to include the estimated number of students eligible for HEERF funds. The College will post an additional report for the quarter ending June 30, 2021, indicating the receipt of funds and that no funds were distributed during the quarter.
Finding No. 2022-007 Federal Agency: U.S. Department of Health and Human Services AL Program: 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Award No.: H8031624, H8F41048, H8D36529 Area: Reporting Questioned Costs: $-0- Criteria: In accordance with 2 CFR section 200.328 and applicable reporting requirements, the Program is required to submit an accurate SF-425, Federal Financial Report. Condition: For three (or 100%) SF-425 reports tested, the following variances were noted: 1. Grant Award H80CS31624 - 04/30/2022 Reporting Period End Date: 2. Grant Award H8DCS36429 - 03/31/2022 Reporting Period End Date: 3. Grant Award H8FCS41048 - 03/31/2022 Reporting Period End Date: Finding No. 2022-007, continued Federal Agency: U.S. Department of Health and Human Services AL Program: 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Award No.: H8031624, H8F41048, H8D36529 Area: Reporting Questioned Costs: $-0- Cause: KCHC did not effectively monitor the accuracy and completeness of the SF 425 report based on underlying accounting records. Effect: KCHC is in noncompliance with the SF-425 federal reporting requirements. No questioned costs are presented as the variances are due to reporting errors. Identification as a Repeat Finding: Finding No. 2021-007 Recommendation: Responsible personnel should take steps to monitor reports and determine that expenditures and program income reported on the SF-425 report are supported by underlying accounting reports. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding. Refer to separate Corrective Action Plan.
Finding No. 2022-007 Federal Agency: U.S. Department of Health and Human Services AL Program: 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Award No.: H8031624, H8F41048, H8D36529 Area: Reporting Questioned Costs: $-0- Criteria: In accordance with 2 CFR section 200.328 and applicable reporting requirements, the Program is required to submit an accurate SF-425, Federal Financial Report. Condition: For three (or 100%) SF-425 reports tested, the following variances were noted: 1. Grant Award H80CS31624 - 04/30/2022 Reporting Period End Date: 2. Grant Award H8DCS36429 - 03/31/2022 Reporting Period End Date: 3. Grant Award H8FCS41048 - 03/31/2022 Reporting Period End Date: Finding No. 2022-007, continued Federal Agency: U.S. Department of Health and Human Services AL Program: 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Award No.: H8031624, H8F41048, H8D36529 Area: Reporting Questioned Costs: $-0- Cause: KCHC did not effectively monitor the accuracy and completeness of the SF 425 report based on underlying accounting records. Effect: KCHC is in noncompliance with the SF-425 federal reporting requirements. No questioned costs are presented as the variances are due to reporting errors. Identification as a Repeat Finding: Finding No. 2021-007 Recommendation: Responsible personnel should take steps to monitor reports and determine that expenditures and program income reported on the SF-425 report are supported by underlying accounting reports. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding. Refer to separate Corrective Action Plan.
Finding No. 2022-007 Federal Agency: U.S. Department of Health and Human Services AL Program: 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Award No.: H8031624, H8F41048, H8D36529 Area: Reporting Questioned Costs: $-0- Criteria: In accordance with 2 CFR section 200.328 and applicable reporting requirements, the Program is required to submit an accurate SF-425, Federal Financial Report. Condition: For three (or 100%) SF-425 reports tested, the following variances were noted: 1. Grant Award H80CS31624 - 04/30/2022 Reporting Period End Date: 2. Grant Award H8DCS36429 - 03/31/2022 Reporting Period End Date: 3. Grant Award H8FCS41048 - 03/31/2022 Reporting Period End Date: Finding No. 2022-007, continued Federal Agency: U.S. Department of Health and Human Services AL Program: 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Award No.: H8031624, H8F41048, H8D36529 Area: Reporting Questioned Costs: $-0- Cause: KCHC did not effectively monitor the accuracy and completeness of the SF 425 report based on underlying accounting records. Effect: KCHC is in noncompliance with the SF-425 federal reporting requirements. No questioned costs are presented as the variances are due to reporting errors. Identification as a Repeat Finding: Finding No. 2021-007 Recommendation: Responsible personnel should take steps to monitor reports and determine that expenditures and program income reported on the SF-425 report are supported by underlying accounting reports. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding. Refer to separate Corrective Action Plan.
Criteria: Section 18004 of the Coronavirus Aid, Relief and Economic Security (CARES) ACT and Section 314(e) of the Coronavirus Response and Relief Supplemental Appropriations (CRRSAA) Act directs institutions receiving funds to promptly and timely provide detailed accounting of the use and expenditures for HEERF (Higher Education Emergency Relief Funds) I, HEERF II, and HEERF III funds. Each institution is required to share in an easily accessible public location quarterly reports (September 30, December 31, March 31, June 30). The reporting is required for both the Student Portion and the Institutional Portion. While the American Rescue Plan (ARP) does not explicitly identify procedures by which institutions submit a report to the Secretary, the Department exercises this reporting authority under 2 CFR 200.328 and 2 CFR 200.329. Condition/Context: The College did not post a report for the Student Portion of HEERF funds for the quarter ended June 30, 2021. This would have been the first quarter of HEERF III reporting and there were no funds disbursed to students during that quarter. The College posted to the website their quarterly report for September 30, 2021 with in the required timeframe. Upon review, it was noted that the report did not include the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CRRSAA and ARP (a)(1) and (a)(4) programs. Questioned Costs: Not applicable. Cause: The College missed the June 30th report as there were no expenditures from the Student Portion that quarter. The College also missed the requirement to report the estimated number of students eligible to receive Emergency Financial Aid Grants to Students. Effect: The College did not provide all of the information required for the HEERF Student Aid Portion. Recommendation: The College should correct the reporting to include the missing pieces. Management's Response: The College will update the September 30, 2021 quarterly report currently posted on the website to include the estimated number of students eligible for HEERF funds. The College will post an additional report for the quarter ending June 30, 2021, indicating the receipt of funds and that no funds were distributed during the quarter.
Finding No. 2022-007 Federal Agency: U.S. Department of Health and Human Services AL Program: 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Award No.: H8031624, H8F41048, H8D36529 Area: Reporting Questioned Costs: $-0- Criteria: In accordance with 2 CFR section 200.328 and applicable reporting requirements, the Program is required to submit an accurate SF-425, Federal Financial Report. Condition: For three (or 100%) SF-425 reports tested, the following variances were noted: 1. Grant Award H80CS31624 - 04/30/2022 Reporting Period End Date: 2. Grant Award H8DCS36429 - 03/31/2022 Reporting Period End Date: 3. Grant Award H8FCS41048 - 03/31/2022 Reporting Period End Date: Finding No. 2022-007, continued Federal Agency: U.S. Department of Health and Human Services AL Program: 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Award No.: H8031624, H8F41048, H8D36529 Area: Reporting Questioned Costs: $-0- Cause: KCHC did not effectively monitor the accuracy and completeness of the SF 425 report based on underlying accounting records. Effect: KCHC is in noncompliance with the SF-425 federal reporting requirements. No questioned costs are presented as the variances are due to reporting errors. Identification as a Repeat Finding: Finding No. 2021-007 Recommendation: Responsible personnel should take steps to monitor reports and determine that expenditures and program income reported on the SF-425 report are supported by underlying accounting reports. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding. Refer to separate Corrective Action Plan.
Finding No. 2022-007 Federal Agency: U.S. Department of Health and Human Services AL Program: 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Award No.: H8031624, H8F41048, H8D36529 Area: Reporting Questioned Costs: $-0- Criteria: In accordance with 2 CFR section 200.328 and applicable reporting requirements, the Program is required to submit an accurate SF-425, Federal Financial Report. Condition: For three (or 100%) SF-425 reports tested, the following variances were noted: 1. Grant Award H80CS31624 - 04/30/2022 Reporting Period End Date: 2. Grant Award H8DCS36429 - 03/31/2022 Reporting Period End Date: 3. Grant Award H8FCS41048 - 03/31/2022 Reporting Period End Date: Finding No. 2022-007, continued Federal Agency: U.S. Department of Health and Human Services AL Program: 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Award No.: H8031624, H8F41048, H8D36529 Area: Reporting Questioned Costs: $-0- Cause: KCHC did not effectively monitor the accuracy and completeness of the SF 425 report based on underlying accounting records. Effect: KCHC is in noncompliance with the SF-425 federal reporting requirements. No questioned costs are presented as the variances are due to reporting errors. Identification as a Repeat Finding: Finding No. 2021-007 Recommendation: Responsible personnel should take steps to monitor reports and determine that expenditures and program income reported on the SF-425 report are supported by underlying accounting reports. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding. Refer to separate Corrective Action Plan.
Finding No. 2022-007 Federal Agency: U.S. Department of Health and Human Services AL Program: 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Award No.: H8031624, H8F41048, H8D36529 Area: Reporting Questioned Costs: $-0- Criteria: In accordance with 2 CFR section 200.328 and applicable reporting requirements, the Program is required to submit an accurate SF-425, Federal Financial Report. Condition: For three (or 100%) SF-425 reports tested, the following variances were noted: 1. Grant Award H80CS31624 - 04/30/2022 Reporting Period End Date: 2. Grant Award H8DCS36429 - 03/31/2022 Reporting Period End Date: 3. Grant Award H8FCS41048 - 03/31/2022 Reporting Period End Date: Finding No. 2022-007, continued Federal Agency: U.S. Department of Health and Human Services AL Program: 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Award No.: H8031624, H8F41048, H8D36529 Area: Reporting Questioned Costs: $-0- Cause: KCHC did not effectively monitor the accuracy and completeness of the SF 425 report based on underlying accounting records. Effect: KCHC is in noncompliance with the SF-425 federal reporting requirements. No questioned costs are presented as the variances are due to reporting errors. Identification as a Repeat Finding: Finding No. 2021-007 Recommendation: Responsible personnel should take steps to monitor reports and determine that expenditures and program income reported on the SF-425 report are supported by underlying accounting reports. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding. Refer to separate Corrective Action Plan.
Finding 2021-006 Program: Office for Coastal Management Federal Financial Assistance Listing: 11.473 Federal Grantor: U.S. Department of Commerce Passed-through: National Fish and Wildlife Foundation Award No. and Year: 0318.19.070225 (2020) Compliance Requirements: Reporting Type of Finding: Material Non-Compliance/Material Weakness Criteria: 2 CFR 200.328 - Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. 2 CFR 200.329(c)(1) -Requirements state that the non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Condition: For three of the four reports selected for testing, CFSC did not submit the reports to the National Fish and Wildlife Foundation by the required date. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was not used. We selected all four reports filed during year. The condition noted above was identified during our procedures over the CFSC’s reporting provisions. Repeat Finding from Prior Year: No Effect: CFSC did not submit required reports in a timely manner, increasing the risk of noncompliance. Cause: CFSC’s procedures did not consistently ensure that the required reports were submitted on a timely basis. Recommendation: We recommend that CFSC modify and strengthen its current policies and procedures to ensure that all required reports are submitted on a timely basis to the appropriate Federal Agency or Pass-Through Entity. Views of Responsible Officials and Planned Corrective Actions: See Separate Corrective Action Plan.
Finding 2021-007 Program: Office for Coastal Management Federal Financial Assistance Listing: 11.473 Federal Grantor: U.S. Department of Commerce Passed-through: National Fish and Wildlife Foundation Award No. and Year: 0318.19.070225 (2020) Compliance Requirements: Reporting Type of Finding: Material Non-Compliance/Material Weakness Criteria: 2 CFR 200.302(b)(2) - Requirements state that there must be accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. Condition: Expenditures for one financial report that was selected for testing did not agree with the expenditures that were reported on the SEFA and recorded in the General Ledger (difference of $11,791), based on the dates requested in the report. CFSC did not include known operational expenses for the period that were program costs at the time the report was due, which resulted in underreporting expenditures by $11,791. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was not used. We selected all four reports filed during year. The condition noted above was identified during our procedures over CFSC’s reporting provisions. Repeat Finding from Prior Year: No Effect: CFSC did not include all known expenditures at the time the report was submitted to the National Fish and Wildlife Foundation, increasing the risk of noncompliance. Cause: CFSC’s procedures did not consistently ensure that all known expenditures at the time the report was submitted were included. Recommendation: We recommend that CFSC modify and strengthen its current policies and procedures to ensure that all known expenditures are included at the time reports are required to be submitted. Views of Responsible Officials and Planned Corrective Actions: See Separate Corrective Action Plan.