Condition: During the test of 100% of expenditures, two (2) expenditures totaling $570,080, for the Coronavirus State and Local Fiscal Recovery Funds, the following noncompliance with the Reporting compliance requirement was noted: • The interim and the 3rd quarter reports were not submitted. • The 2nd quarter report was not timely submitted. • The County improperly reported a vendor as a subrecipient instead of as a vendor relationship. Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal expenditures are properly reported in accordance with federal compliance requirements. Effect of Condition: This condition resulted in noncompliance with federal grant guidelines. Recommendation: OSAI recommends the County gain an understanding of the requirements for this program and implement internal controls to ensure compliance with these requirements. Management Response: Board of County Commissioners: The Board of County Commissioners is responsible for the overall fiscal concerns of the county. See OKLA. STAT. Title 19, § 345. The Board of County Commissioners, with the cooperation and participation of all elected officials, reviews, develops and implements policies and procedures to create a strong internal control environment. The Board of County Commissioners will work with all elected officials, the third-party administrator, and federal, state and local partners to develop policies, procedures, and internal controls designed to accurately track grants, including the application process, verification, oversight, and reporting of grant requirements. These policies and procedures will be designed to identify requirements for recipients and sub-recipients of grants, ensure accurate equipment and real property management, procurement, recipient and subrecipient monitoring and reporting. Further, policies will ensure a proper understanding of all grant requirements and compliance of the same. To assist in this process, the Board of County Commissioners engaged a third-party administrator to oversee the grant process, including application, eligibility, review, requirements, contracting, recipient tracking and oversight, and documentation and reporting. The Board of County Commissioners will work with the third-party administrator to ensure proper grant administration. Criteria: Accountability and stewardship should be overall goals in management’s accounting of federal funds. Internal controls should be designed to monitor compliance with laws and regulations pertaining to grant contracts. Title 2 CFR § 200.303(a) Internal Controls, reads as follows: The non-federal entity must: Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework, “issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance and Reporting Guidance, State and Local Fiscal Recovery Funds (10. Reporting) reads as follows: All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlines in Part 2 of this guidance. Expenditures may be reported on a cash of accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Your organization should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. In addition, where appropriate, your organization needs to establish internal controls to ensure completion and timely submission of all mandatory performance and/or compliance reporting. Further, 2 CFR 200.329-Monitoring and reporting Program Performance (c)(1) reads as follows: (c)(1) 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. Intervals must be no less frequent than annually nor more frequent 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. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar gays after the period of performance end date. A subrecipient must submit to the pass-through entity, no later than 90 calendar days after the period of performance end date, all final performance reports as required by the terms and conditions of the Federal award. See also §200.344. If a justified request is submitted by a non-Federal entity, the Federal agency may extend the due date for any performance report.
Condition: The Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Compliance Report was not maintained and could not be produced. Federal expenditures as reported could not be tested resulting in unreported costs of $2,280,846. Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal expenditures are made in accordance with federal compliance requirements. Effect of Condition: This condition could result in noncompliance with grant requirements. Recommendation: OSAI recommends the County gain an understanding of the grant requirements for this program and implement internal controls to ensure compliance with these grant requirements. Management Response: Chairman of the Board of County Commissioners: This issue originated under the prior County Clerk’s administration where key reporting processes were not followed. The Board of County Commissioners and the other elected officials have made correcting this a top priority. Together, we are: • developing a comprehensive SOP to ensure accurate and timely tracking and reporting of federal funds, • improving communication and oversight between all county offices to ensure consistent reporting standards, • and ensuring annual compliance with federal reporting requirements. Our collective goal is to implement the policies and structures that will keep Osage County operating with the highest standard of accountability and excellence. County Clerk: I was not the County Clerk in office at this time. To correct this issue, the County plans to develop a SOP to timely and accurately track and report on federal funds. The SOP will be reviewed, adopted, and monitored by the Board of County Commissioners. County Treasurer: The County was under the understanding that once we established we were reporting as revenue loss, we would not have to submit the report annually. The final reporting was submitted prior to deadline. Criteria: Compliance and Reporting Guidance, State and Local Fiscal Recovery Funds (10. Reporting.) reads as follows: All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Your organization should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles.In addition, where appropriate, you organization needs to establish controls to ensure completion and timely submission of all mandatory performance and/or compliance reporting. Further, 2 CFR § 200.329 Monitoring and Reporting Program Performance (c)(1) reads as follows: 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. Intervals must be no less frequent than annually nor more frequent 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. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date. A subrecipient must submit to the pass-through entity, no later than 90 calendar days after the period of performance end date, all final performance reports as required by the terms and conditions of the Federal award. See also § 200.344. If a justified request is submitted by a non-Federal entity, the Federal agency may extend the due date for any performance report.
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.
DEPARTMENT OF EDUCATION ALN #: 84.425F Condition: HEERF reporting was not always done accurately or timely. During the audit, it was noted that the College did not continue to update their website with the HEERF reporting requirements as listed in their grant agreements. The first and second quarterly reports for institutional funds (quarters ended September 30, 2021 and December 31, 2021) was not completed for HEERF II. Criteria: 2 CFR 200.329, 86 FR 26213 The College was required to post the Institutional Quarterly Report to their website within 10 days of the end of the quarter in which the funds were spent. Questioned Costs: None Cause: Turnover in staffing. There were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements of the HEERF reporting. Effect: The College was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the College complete the HEERF quarterly reporting until the HEERF funding is spent to ensure compliance is maintained. Views of Responsible Officials and Planned Corrective Action: See Corrective Action Plan.
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.
DEPARTMENT OF EDUCATION ALN #: 84.425F Condition: HEERF reporting was not always done accurately or timely. During the audit, it was noted that the College did not continue to update their website with the HEERF reporting requirements as listed in their grant agreements. The first and second quarterly reports for institutional funds (quarters ended September 30, 2021 and December 31, 2021) was not completed for HEERF II. Criteria: 2 CFR 200.329, 86 FR 26213 The College was required to post the Institutional Quarterly Report to their website within 10 days of the end of the quarter in which the funds were spent. Questioned Costs: None Cause: Turnover in staffing. There were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements of the HEERF reporting. Effect: The College was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the College complete the HEERF quarterly reporting until the HEERF funding is spent to ensure compliance is maintained. Views of Responsible Officials and Planned Corrective Action: See Corrective Action Plan.
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.
Education Stabilization Fund Reporting Significant Deficiency DEPARTMENT OF EDUCATION ALN#: 84.425E and 84.425F Federal Award Identification #: P425E203311 and P425F203100 Condition: The University did not post the required Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) reports to their website as required for institutional and student aid portions expended from the Coronavirus Aid, Relief and Economic Security Act (CARES), Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA), and American Rescue Plan (ARP). The University also did not retain a copy of the 2nd annual report and supporting data so the accuracy of that report was not able to be tested. Criteria: 86 FR 262132, CFR 200.329 The University was required to post the Institutional Quarterly Report to their website within 10 days of the end of the quarter in which the funds were spent. Additionally, for each student grant disbursement made, the University is required to report quarterly to their website a summary of how the funds were allocated and disbursed. The University is also required to retain supporting documentation for all HEERF reports. Questioned Costs: None Context: During the audit, it was noted that the University had initially disclosed the required CARES Act reporting for the HEERF student emergency grants disbursed but made no further disclosure after December 2020. The CARES Act Institutional Quarterly Budget and Expenditure reports for March 31, 2021, and each subsequent quarter were not completed and posted to their website as required. Subsequent to year end and as part of the audit process, the University completed and posted the required reports to their website. For the 2nd annual report, the University has not yet been able to obtain a copy from the Department of Education as the portal is closed. Cause: Along with staffing challenges brought on by COVID, there were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements for HEERF reporting. Effect: The University was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: 2021-003 Recommendation: We recommend that the University complete the HEERF quarterly reporting until the HEERF funding is spent to ensure compliance is maintained. We also recommend that a copy of the annual reports be retained along with all supporting data used to compile the reports for record retention purposes. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Education Stabilization Fund Reporting Significant Deficiency DEPARTMENT OF EDUCATION ALN#: 84.425E and 84.425F Federal Award Identification #: P425E203311 and P425F203100 Condition: The University did not post the required Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) reports to their website as required for institutional and student aid portions expended from the Coronavirus Aid, Relief and Economic Security Act (CARES), Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA), and American Rescue Plan (ARP). The University also did not retain a copy of the 2nd annual report and supporting data so the accuracy of that report was not able to be tested. Criteria: 86 FR 262132, CFR 200.329 The University was required to post the Institutional Quarterly Report to their website within 10 days of the end of the quarter in which the funds were spent. Additionally, for each student grant disbursement made, the University is required to report quarterly to their website a summary of how the funds were allocated and disbursed. The University is also required to retain supporting documentation for all HEERF reports. Questioned Costs: None Context: During the audit, it was noted that the University had initially disclosed the required CARES Act reporting for the HEERF student emergency grants disbursed but made no further disclosure after December 2020. The CARES Act Institutional Quarterly Budget and Expenditure reports for March 31, 2021, and each subsequent quarter were not completed and posted to their website as required. Subsequent to year end and as part of the audit process, the University completed and posted the required reports to their website. For the 2nd annual report, the University has not yet been able to obtain a copy from the Department of Education as the portal is closed. Cause: Along with staffing challenges brought on by COVID, there were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements for HEERF reporting. Effect: The University was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: 2021-003 Recommendation: We recommend that the University complete the HEERF quarterly reporting until the HEERF funding is spent to ensure compliance is maintained. We also recommend that a copy of the annual reports be retained along with all supporting data used to compile the reports for record retention purposes. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See 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.
Education Stabilization Fund Reporting Significant Deficiency DEPARTMENT OF EDUCATION ALN#: 84.425E and 84.425F Federal Award Identification #: P425E203311 and P425F203100 Condition: The University did not post the required Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) reports to their website as required for institutional and student aid portions expended from the Coronavirus Aid, Relief and Economic Security Act (CARES), Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA), and American Rescue Plan (ARP). The University also did not retain a copy of the 2nd annual report and supporting data so the accuracy of that report was not able to be tested. Criteria: 86 FR 262132, CFR 200.329 The University was required to post the Institutional Quarterly Report to their website within 10 days of the end of the quarter in which the funds were spent. Additionally, for each student grant disbursement made, the University is required to report quarterly to their website a summary of how the funds were allocated and disbursed. The University is also required to retain supporting documentation for all HEERF reports. Questioned Costs: None Context: During the audit, it was noted that the University had initially disclosed the required CARES Act reporting for the HEERF student emergency grants disbursed but made no further disclosure after December 2020. The CARES Act Institutional Quarterly Budget and Expenditure reports for March 31, 2021, and each subsequent quarter were not completed and posted to their website as required. Subsequent to year end and as part of the audit process, the University completed and posted the required reports to their website. For the 2nd annual report, the University has not yet been able to obtain a copy from the Department of Education as the portal is closed. Cause: Along with staffing challenges brought on by COVID, there were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements for HEERF reporting. Effect: The University was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: 2021-003 Recommendation: We recommend that the University complete the HEERF quarterly reporting until the HEERF funding is spent to ensure compliance is maintained. We also recommend that a copy of the annual reports be retained along with all supporting data used to compile the reports for record retention purposes. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Education Stabilization Fund Reporting Significant Deficiency DEPARTMENT OF EDUCATION ALN#: 84.425E and 84.425F Federal Award Identification #: P425E203311 and P425F203100 Condition: The University did not post the required Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) reports to their website as required for institutional and student aid portions expended from the Coronavirus Aid, Relief and Economic Security Act (CARES), Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA), and American Rescue Plan (ARP). The University also did not retain a copy of the 2nd annual report and supporting data so the accuracy of that report was not able to be tested. Criteria: 86 FR 262132, CFR 200.329 The University was required to post the Institutional Quarterly Report to their website within 10 days of the end of the quarter in which the funds were spent. Additionally, for each student grant disbursement made, the University is required to report quarterly to their website a summary of how the funds were allocated and disbursed. The University is also required to retain supporting documentation for all HEERF reports. Questioned Costs: None Context: During the audit, it was noted that the University had initially disclosed the required CARES Act reporting for the HEERF student emergency grants disbursed but made no further disclosure after December 2020. The CARES Act Institutional Quarterly Budget and Expenditure reports for March 31, 2021, and each subsequent quarter were not completed and posted to their website as required. Subsequent to year end and as part of the audit process, the University completed and posted the required reports to their website. For the 2nd annual report, the University has not yet been able to obtain a copy from the Department of Education as the portal is closed. Cause: Along with staffing challenges brought on by COVID, there were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements for HEERF reporting. Effect: The University was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: 2021-003 Recommendation: We recommend that the University complete the HEERF quarterly reporting until the HEERF funding is spent to ensure compliance is maintained. We also recommend that a copy of the annual reports be retained along with all supporting data used to compile the reports for record retention purposes. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See 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.
Criteria: Per the Compliance Requirements-Procurement and Suspension and Debarment-Compliance Requirement-Procurement, “Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR section 200.329(a) and (b). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in case of acquisitions for construction subject to Wage Rate Requirement (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.32 (a). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (CFR section 200.320 (b)). “ Condition: For the procurement of small purchases over $10,000, the Management Agent did not obtain price or rate quotations from an adequate number of qualified sources for the following procurements per the Uniform Guidance Effect: The Project did not follow small purchase procedures set forth in Compliance Requirements-Procurement. Cause: Due to the turnover of Management Agent personnel, the documentation to support small purchases was unavailable and/or not performed. Recommendation: We recommend that the Project follows a small purchase method for procurement that exceeds $10,000.
Criteria: Per the Compliance Requirements-Procurement and Suspension and Debarment-Compliance Requirement-Procurement, “Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR section 200.329(a) and (b). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in case of acquisitions for construction subject to Wage Rate Requirement (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.32 (a). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (CFR section 200.320 (b)). “ Condition: For the procurement of small purchases over $10,000, the Management Agent did not obtain price or rate quotations from an adequate number of qualified sources for the following procurements per the Uniform Guidance for a security vendor for the amount of $131,808. Effect: The Project did not follow small purchase procedures set forth in Compliance Requirements-Procurement. Cause: Due to the turnover of Management Agent personnel, the documentation to support small purchases was unavailable and/or not performed. Recommendation: We recommend that the Project follows a small purchase method for procurement that exceeds $10,000. Views of Responsible Officials and Corrective Action Plan: No disagreements with the audit finding.
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.
Criteria: Per the Compliance Requirements-Procurement and Suspension and Debarment-Compliance Requirement-Procurement, “Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR section 200.329(a) and (b). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in case of acquisitions for construction subject to Wage Rate Requirement (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.32 (a). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (CFR section 200.320 (b)). “ Condition: For the procurement of small purchases over $10,000, the Management Agent did not obtain price or rate quotations from an adequate number of qualified sources for the following procurements per the Uniform Guidance Effect: The Project did not follow small purchase procedures set forth in Compliance Requirements-Procurement. Cause: Due to the turnover of Management Agent personnel, the documentation to support small purchases was unavailable and/or not performed. Recommendation: We recommend that the Project follows a small purchase method for procurement that exceeds $10,000.
Criteria: Per the Compliance Requirements-Procurement and Suspension and Debarment-Compliance Requirement-Procurement, “Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR section 200.329(a) and (b). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in case of acquisitions for construction subject to Wage Rate Requirement (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.32 (a). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (CFR section 200.320 (b)). “ Condition: For the procurement of small purchases over $10,000, the Management Agent did not obtain price or rate quotations from an adequate number of qualified sources for the following procurements per the Uniform Guidance for a security vendor for the amount of $131,808. Effect: The Project did not follow small purchase procedures set forth in Compliance Requirements-Procurement. Cause: Due to the turnover of Management Agent personnel, the documentation to support small purchases was unavailable and/or not performed. Recommendation: We recommend that the Project follows a small purchase method for procurement that exceeds $10,000. Views of Responsible Officials and Corrective Action Plan: No disagreements with the audit finding.
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.
REPORTING, I DID NOT NOTE ANY OF THE REQUIRED QUARTERLY REPORTING FOR THE CARES ACT GRANT. I ALSO DID NOT NOTE ANY INTERIM OR ANNUAL REPORTS FILED FOR THE ARP GRANT. PER 2 CFR, SECTION 200.328 AND 200.329, THE NVT MUST COMPLY WITH ANY FINANCIAL AND PROGRAMMATIC REPORTING REQUIREMENTS. NO QUESTIONED COSTS. MANAGEMENT DID NOT HAVE CONTROLS IN PLACE TO ENSURE THAT ALL GRANT REPORTS WERE FILED TIMELY. I WAS NOT ABLE TO REVIEW ANY OF THE 4 QUARTERLY FINANCIAL OR NARRATIVE REPORTS FOR THE CARES ACT GRANT. I WAS ALSO NOT ABLE TO REVIEW THE ANNUAL REQUIRED REPORT FOR THE ARP GRANT. THE NVT IS DELINQUENT IN ITS REPORTING FOR THESE TWO GRANTS. MANAGEMENT NEEDS TO ENSURE THAT ALL GRANT REPORTS ARE DONE AND SUBMITTED TIMELY AND RETAINED WITHIN THE GRANT FILES OF THE NVT. THIS FINDING WAS NOTED AS FINDING 2020-002.
OTHER, THE NVT DID NOT SUBMIT THE REPORTING PACKAGE TIMELY IN ACCORDANCE WITH THE UNIFORM GUIDANCE REQUIREMENT OF SUBMITTING THE AUDIT WITHIN THE EARLIER OF 30 DAYS AFTER RECEIPT OF THE AUDIT REPORT, OR NINE MONTHS AFTER THE END OF THE AUDIT PERIOD. PER 2 CFR, SECTION 200.328 AND 200.329, THE COUNCIL MUST COMPLY WITH ANY FINANCIAL AND PROGRAMATTIC REPORTING REQUIREMENTS. PER SECTION 200.501, THE NVT MUST HAEV AN AUDIT PERFORMED AND SUBMITTED WITHIN 9 MONTHS OF YEAR END. NO QUESTIONED COSTS. MANAGEMENT DID NOT ENSURE THAT THE AUDITS WERE PERFORMED TIMELY. LATE REPORTING COULD JEOPARDIZE GRANT FUNDING. I RECOMMEND THAT THE COUNCIL ENSURE TIMELY AUDITS FOR FUTURE AUDITS. THIS FINDING WAS NOTED AS FINDING 2020-003
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Child Care and Development Block Grant Assistance Listing Number: 93.575 Award Period: July 1, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria: Financial reporting requirements are identified in 2 CFR section 200.328. Monitoring and reporting program performance requirements are identified in 2 CFR section 200.329. Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Condition: 1) There was no evidence of date of timely submission for 11 reports tested; 2) There was no evidence of review for five reports tested; 3) Five reports tested did not tie to the underlying support by an immaterial amount. Context: There was a total of 28 financial reports and four performance reports. Questioned Costs: N/A Cause: Internal controls surrounding reporting were not properly designed and implemented and an audit trail for timely submission and approval of reports was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over reporting requirements provides an opportunity for noncompliance and errors. Repeat Finding: N/A Recommendation: We recommend that the Organization design, implement, and monitor internal controls over reporting as well as maintain source documentation to support amounts reported. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Child Care and Development Block Grant Assistance Listing Number: 93.575 Award Period: July 1, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria: Financial reporting requirements are identified in 2 CFR section 200.328. Monitoring and reporting program performance requirements are identified in 2 CFR section 200.329. Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Condition: 1) There was no evidence of date of timely submission for 11 reports tested; 2) There was no evidence of review for five reports tested; 3) Five reports tested did not tie to the underlying support by an immaterial amount. Context: There was a total of 28 financial reports and four performance reports. Questioned Costs: N/A Cause: Internal controls surrounding reporting were not properly designed and implemented and an audit trail for timely submission and approval of reports was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over reporting requirements provides an opportunity for noncompliance and errors. Repeat Finding: N/A Recommendation: We recommend that the Organization design, implement, and monitor internal controls over reporting as well as maintain source documentation to support amounts reported. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Child Care and Development Block Grant Assistance Listing Number: 93.575 Award Period: July 1, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria: Financial reporting requirements are identified in 2 CFR section 200.328. Monitoring and reporting program performance requirements are identified in 2 CFR section 200.329. Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Condition: 1) There was no evidence of date of timely submission for 11 reports tested; 2) There was no evidence of review for five reports tested; 3) Five reports tested did not tie to the underlying support by an immaterial amount. Context: There was a total of 28 financial reports and four performance reports. Questioned Costs: N/A Cause: Internal controls surrounding reporting were not properly designed and implemented and an audit trail for timely submission and approval of reports was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over reporting requirements provides an opportunity for noncompliance and errors. Repeat Finding: N/A Recommendation: We recommend that the Organization design, implement, and monitor internal controls over reporting as well as maintain source documentation to support amounts reported. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Child Care and Development Block Grant Assistance Listing Number: 93.575 Award Period: July 1, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria: Financial reporting requirements are identified in 2 CFR section 200.328. Monitoring and reporting program performance requirements are identified in 2 CFR section 200.329. Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Condition: 1) There was no evidence of date of timely submission for 11 reports tested; 2) There was no evidence of review for five reports tested; 3) Five reports tested did not tie to the underlying support by an immaterial amount. Context: There was a total of 28 financial reports and four performance reports. Questioned Costs: N/A Cause: Internal controls surrounding reporting were not properly designed and implemented and an audit trail for timely submission and approval of reports was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over reporting requirements provides an opportunity for noncompliance and errors. Repeat Finding: N/A Recommendation: We recommend that the Organization design, implement, and monitor internal controls over reporting as well as maintain source documentation to support amounts reported. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Child Care and Development Block Grant Assistance Listing Number: 93.575 Award Period: July 1, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria: Financial reporting requirements are identified in 2 CFR section 200.328. Monitoring and reporting program performance requirements are identified in 2 CFR section 200.329. Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Condition: 1) There was no evidence of date of timely submission for 11 reports tested; 2) There was no evidence of review for five reports tested; 3) Five reports tested did not tie to the underlying support by an immaterial amount. Context: There was a total of 28 financial reports and four performance reports. Questioned Costs: N/A Cause: Internal controls surrounding reporting were not properly designed and implemented and an audit trail for timely submission and approval of reports was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over reporting requirements provides an opportunity for noncompliance and errors. Repeat Finding: N/A Recommendation: We recommend that the Organization design, implement, and monitor internal controls over reporting as well as maintain source documentation to support amounts reported. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
Auditee has improperly tracked grant awards and expenditures. Federal Programs Impacted: 17,258 (WIOA Cluster). Questioned Costs: None. Condition: The WDBEA expended more than $750,000 in federal awards, triggering a single audit requirement. However, when asked to provide a schedule of expenditures of federal awards, client gave different amounts of revenues and expenditures than those provided through external confirmation by oversight agencies. Criteria: 2 CFR Section 200.329 states that it is the auditee's responsibility to monitor their activities for which federal awards are used. Cause: Unallowable costs among other items were included in the client's schedule of expenditures of federal awards. In addition, the books kept by the former finance manager were inadequate to properly track grant awards and expenditures. Effect: Difficulty in ascertaining the true balances of federal revenues and expenditures as reported on the schedule of expenditures of federal awards. Recommendation: We recommend the WDBEA maintains an effort to properly track and report federal awards and expenditures. Management Response: Managmeent will develop procedures which adequately address shortcomings of grant tracking and further solidify the processes for tracking and reporting of grant funds.
Internal control failtures including two employee timesheets being unreviewed by agreed-upon personnel. Federal Programs Impacted: 17.258 (WIOA Cluster) Questioned Costs: None. Condition: Per the auditee's internal control procedures, employee timesheets are to be signed off on by one of the individual listed above. However, we noted two exceptions throughout all procedures applied. Criteria: 2 CFR Section 200.329 states that it is the auditee's responsibility to monitor their activities for which federal awards are used. A component of this is to develop effective internal controls to ensure compliance with relevant compliance requirements. Cause: Internal control procedures failed, and management missed two timesheets for which review was needed. Effect: Disallowed costs related to payroll could have been charged to federal awards. Recommendation: We recommend management ensure all internal control procedures are being followed as outlined. Management Response: Management agrees with this finding and will ensure internal controls are followed as outlined.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Child Care and Development Block Grant Assistance Listing Number: 93.575 Award Period: July 1, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria: Financial reporting requirements are identified in 2 CFR section 200.328. Monitoring and reporting program performance requirements are identified in 2 CFR section 200.329. Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Condition: 1) There was no evidence of date of timely submission for 11 reports tested; 2) There was no evidence of review for five reports tested; 3) Five reports tested did not tie to the underlying support by an immaterial amount. Context: There was a total of 28 financial reports and four performance reports. Questioned Costs: N/A Cause: Internal controls surrounding reporting were not properly designed and implemented and an audit trail for timely submission and approval of reports was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over reporting requirements provides an opportunity for noncompliance and errors. Repeat Finding: N/A Recommendation: We recommend that the Organization design, implement, and monitor internal controls over reporting as well as maintain source documentation to support amounts reported. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Child Care and Development Block Grant Assistance Listing Number: 93.575 Award Period: July 1, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria: Financial reporting requirements are identified in 2 CFR section 200.328. Monitoring and reporting program performance requirements are identified in 2 CFR section 200.329. Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Condition: 1) There was no evidence of date of timely submission for 11 reports tested; 2) There was no evidence of review for five reports tested; 3) Five reports tested did not tie to the underlying support by an immaterial amount. Context: There was a total of 28 financial reports and four performance reports. Questioned Costs: N/A Cause: Internal controls surrounding reporting were not properly designed and implemented and an audit trail for timely submission and approval of reports was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over reporting requirements provides an opportunity for noncompliance and errors. Repeat Finding: N/A Recommendation: We recommend that the Organization design, implement, and monitor internal controls over reporting as well as maintain source documentation to support amounts reported. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Child Care and Development Block Grant Assistance Listing Number: 93.575 Award Period: July 1, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria: Financial reporting requirements are identified in 2 CFR section 200.328. Monitoring and reporting program performance requirements are identified in 2 CFR section 200.329. Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Condition: 1) There was no evidence of date of timely submission for 11 reports tested; 2) There was no evidence of review for five reports tested; 3) Five reports tested did not tie to the underlying support by an immaterial amount. Context: There was a total of 28 financial reports and four performance reports. Questioned Costs: N/A Cause: Internal controls surrounding reporting were not properly designed and implemented and an audit trail for timely submission and approval of reports was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over reporting requirements provides an opportunity for noncompliance and errors. Repeat Finding: N/A Recommendation: We recommend that the Organization design, implement, and monitor internal controls over reporting as well as maintain source documentation to support amounts reported. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Child Care and Development Block Grant Assistance Listing Number: 93.575 Award Period: July 1, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria: Financial reporting requirements are identified in 2 CFR section 200.328. Monitoring and reporting program performance requirements are identified in 2 CFR section 200.329. Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Condition: 1) There was no evidence of date of timely submission for 11 reports tested; 2) There was no evidence of review for five reports tested; 3) Five reports tested did not tie to the underlying support by an immaterial amount. Context: There was a total of 28 financial reports and four performance reports. Questioned Costs: N/A Cause: Internal controls surrounding reporting were not properly designed and implemented and an audit trail for timely submission and approval of reports was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over reporting requirements provides an opportunity for noncompliance and errors. Repeat Finding: N/A Recommendation: We recommend that the Organization design, implement, and monitor internal controls over reporting as well as maintain source documentation to support amounts reported. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Child Care and Development Block Grant Assistance Listing Number: 93.575 Award Period: July 1, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria: Financial reporting requirements are identified in 2 CFR section 200.328. Monitoring and reporting program performance requirements are identified in 2 CFR section 200.329. Recipients of federal funds are required to establish and maintain effective internal controls over federal funds received, per 2 CFR section 200.303. Condition: 1) There was no evidence of date of timely submission for 11 reports tested; 2) There was no evidence of review for five reports tested; 3) Five reports tested did not tie to the underlying support by an immaterial amount. Context: There was a total of 28 financial reports and four performance reports. Questioned Costs: N/A Cause: Internal controls surrounding reporting were not properly designed and implemented and an audit trail for timely submission and approval of reports was not maintained. Effect: The lack of evidence for audit trail and lack of effective internal controls over reporting requirements provides an opportunity for noncompliance and errors. Repeat Finding: N/A Recommendation: We recommend that the Organization design, implement, and monitor internal controls over reporting as well as maintain source documentation to support amounts reported. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
Auditee has improperly tracked grant awards and expenditures. Federal Programs Impacted: 17,258 (WIOA Cluster). Questioned Costs: None. Condition: The WDBEA expended more than $750,000 in federal awards, triggering a single audit requirement. However, when asked to provide a schedule of expenditures of federal awards, client gave different amounts of revenues and expenditures than those provided through external confirmation by oversight agencies. Criteria: 2 CFR Section 200.329 states that it is the auditee's responsibility to monitor their activities for which federal awards are used. Cause: Unallowable costs among other items were included in the client's schedule of expenditures of federal awards. In addition, the books kept by the former finance manager were inadequate to properly track grant awards and expenditures. Effect: Difficulty in ascertaining the true balances of federal revenues and expenditures as reported on the schedule of expenditures of federal awards. Recommendation: We recommend the WDBEA maintains an effort to properly track and report federal awards and expenditures. Management Response: Managmeent will develop procedures which adequately address shortcomings of grant tracking and further solidify the processes for tracking and reporting of grant funds.