Finding 1160139 (2022-020)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2022
Accepted
2025-10-06
Audit: 370531
Organization: College of the Marshall Islands (MH)

AI Summary

  • Core Issue: The College lacks adequate internal controls to ensure compliance with federal regulations on allowable costs, specifically in documenting transactions.
  • Impacted Requirements: The College must adhere to 2 CFR 200.303(a) and maintain effective internal controls for managing federal awards.
  • Recommended Follow-Up: College management should enhance internal control policies to ensure proper documentation for all transactions, as outlined in their Corrective Action Plan.

Finding Text

Finding No.: 2022-020 Federal Agency: U.S. Department of Education AL Program: 84.425 Education Stabilization Fund AL Sub-Program: 84.425F HEERF - Institutional Portion Federal Award No.: COVID-19 P425F202732 Area: Allowable Costs/Cost Principles Questioned Costs: $0 Criteria: Federal program expenditures should be necessary and reasonable for the performance of the Federal award in accordance with allowable costs/cost principles requirements and be adequately documented. Furthermore, 2 CFR 200.303(a) states that the subrecipient must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the COSO. Condition: : For two items (or 3%) of seventy-six items, aggregating $4,539,770 of $10,127,277 in total non-payroll expenditures, deficiencies were noted as follows: Item # PO# Description Expense Amount Questioned Cost 1 21-PO-2102 Small tools $311,212 $311,212 2 21-PO-2102 Small tools 311,211 311,211 $622,423 $622,423 Item #s 1 and 2 pertain to purchase of 750 units of laptop, however, there was no student distribution log to support distribution made to students. Cause: The College lacks adequate internal controls over compliance with the applicable federal regulations relating to allowable costs/cost principles, specifically, obtaining and retaining sufficient documentation to support all transactions. Effect: The College is not in compliance with the applicable allowable costs/cost principles requirements. No questioned costs are reported at this finding as questioned costs are reported at finding # 2022-022. Identified as a Repeat Finding: 2021-015 Recommendation: College management should improve internal control policies and strengthen controls requiring obtaining and retaining sufficient documentation to support all transactions. Views of Auditee and Planned Corrective Actions: The College agrees with the finding and provides details in its Corrective Action Plan.

Corrective Action Plan

Allowable Costs/ Cost Principles: The College agrees with the finding. To address the repeat finding, the College will evaluate and strengthen internal controls by updating its policies/procedures addressing activities allowed or unallowed requirements. The College will conduct regular refresher training to ensure proper and full use and utilization of its document management system and all other College systems.

Categories

Allowable Costs / Cost Principles Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 1160126 2022-008
    Material Weakness Repeat
  • 1160127 2022-009
    Material Weakness Repeat
  • 1160128 2022-010
    Material Weakness Repeat
  • 1160129 2022-011
    Material Weakness Repeat
  • 1160130 2022-012
    Material Weakness Repeat
  • 1160131 2022-013
    Material Weakness Repeat
  • 1160132 2022-014
    Material Weakness Repeat
  • 1160133 2022-015
    Material Weakness Repeat
  • 1160134 2022-016
    Material Weakness Repeat
  • 1160135 2022-017
    Material Weakness Repeat
  • 1160136 2022-018
    Material Weakness Repeat
  • 1160137 2022-019
    Material Weakness Repeat
  • 1160138 2022-019
    Material Weakness Repeat
  • 1160140 2022-021
    Material Weakness Repeat
  • 1160141 2022-021
    Material Weakness Repeat
  • 1160142 2022-021
    Material Weakness Repeat
  • 1160143 2022-022
    Material Weakness Repeat
  • 1160144 2022-022
    Material Weakness Repeat
  • 1160145 2022-023
    Material Weakness Repeat
  • 1160146 2022-023
    Material Weakness Repeat
  • 1160147 2022-023
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $7.50M
84.425 Education Stabilization Fund $3.02M
15.875 Economic, Social, and Political Development of the Territories $1.69M
84.047 Trio Upward Bound $269,114
93.107 Area Health Education Centers $90,102
10.308 Resident Instruction, Agriculture, and Food Science Facilities and Equipment Grants $45,256
47.076 Stem Education (formerly Education and Human Resources) $16,725