Finding No.: 2022-023 Federal Agency: U.S. Department of Education AL Program: 84.425 Education Stabilization Fund AL Sub-Program: 84.425E Higher Education Emergency Relief Fund (HEERF) - Student Aid Portion Federal Award No.: COVID-19 P425E204126 AL Sub-Program: 84.425F HEERF - Institutional Portion Federal Award No.: COVID-19 P425F202732 AL Sub-Program: 84.425L HEERF - Minority Serving Institution Federal Award No.: COVID-19 P425L200219 Area: Reporting Questioned Costs: $0 Criteria: Annual Reporting - Per OMB Compliance Supplement Addendum April 2022, ED will be collecting an annual report for HEERF grantees in April 2022. ED will require institutions to report on their uses of HEERF I CARES Act funds, HEERF II CRRSAA funds, and HEERF III ARP funds in advance of the ARP annual reporting deadline. Quarterly Public Reporting for (a)(1) Student Aid Portion - Per OMB Compliance Supplement Addendum April 2022, institutions that received a HEERF 18004(a)(1) Student Aid Portion award are required to publicly post certain information on their website no later than 30 days after award and update that information every 45 days thereafter. On August 31, 2020, the frequency of reporting after the initial 30-day period decreased from every 45 days thereafter to every calendar quarter. On May 13, 2021, ED published an additional notice for student aid public reporting under CRRSAA and ARP, which requires that institution publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter. Quarterly Public Reporting for (a)(1) Institutional Portion and (a)(2), and (a)(3) funds - Per OMB Compliance Supplement Addendum April 2022, Quarterly Budget and Expenditure form must be conspicuously posted on the institution’s primary website on the same page the reports of the IHE’s activities as to the emergency financial aid grants to students (Student Aid Portion) are posted. The form must be posted covering each quarterly reporting period no later than 10 days after the end of each calendar quarter. Any changes or updates after initial posting must be conspicuously noted after initial posting and the date of the change must be noted in the “Date of Report” line. Furthermore, as required by 2 CFR 200.334, regardless of the need to submit an audit, all financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the last HEERF grant’s final expenditure report. 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. Conditions: 1. Total annual expenditures per the Annual Report Data Collection System differ from cumulative expenditures from 01/01/21 through 12/31/21 per underlying accounting records, as follows: Annual Expenditures Student Portion Institution Portion Minority Serving Institution Annual Data Collection System $2,628,200 $2,223,328 $ --- Underlying accounting records 2,554,416 1,917,546 338,297 Over (under) reporting $ 73,784 $ 305,782 $(338,297) 2. ALN 84.425E COVID-19 HEERF-Student Aid Portion A. Quarterly reports for quarters ended 12/31/2021 and 03/31/2022 that were publicly posted in the website, along with relevant documentation evidencing compliance (i.e., webmaster logs, or other relevant documentation establishing good-faith indication that the institution posted the required information at approximately timelines established by the public reporting requirements) on whether the College was timely in publicly posting its quarterly report could not be provided. B. Relevant documentation evidencing compliance (i.e., webmaster logs, or other relevant documentation establishing good-faith indication that the institution posted the required information at approximately timelines established by the public reporting requirements) on whether the College was timely in publicly posting its quarterly report for quarters ended 06/30/2022 and 09/30/2022, could not be provided. 3. 84.425F COVID-19 HEERF-Institutional Portion 84.425L COVID-19 HEERF-Minority Serving Institution A. Relevant documentation evidencing compliance (i.e., webmaster logs, or other relevant documentation establishing good-faith indication that the institution posted the required information at approximately timelines established by the public reporting requirements) on whether the College was timely in publicly posting its quarterly report for quarters ended 12/31/2021, 03/31/2022, 06/30/2022 and 09/30/2022, could not be provided. Cause: The College lacks adequate internal controls over the timely and accurate preparation and review of required reports as stipulated in the Compliance Supplement. Furthermore, the College lacks adequate internal controls regarding retaining sufficient documentation to support all reported transactions. Effect: The College is not in compliance with the applicable reporting requirements. No questioned costs are presented as the identified reporting differences do not represent overpayments, and we are unable to quantify the impact of late reporting on the program. Identified as a Repeat Finding: 2021-017 Recommendation: College management should strengthen controls so that required reports are timely and accurately prepared and reviewed and submitted within the specified timeframes to evidence compliance with the applicable reporting requirements and retain sufficient documentation to support all reported transactions. Views of Auditee and Planned Corrective Actions: The College agrees with the finding and provides details in its Corrective Action Plan.