Finding 1177674 (2024-012)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2024
Accepted
2026-03-10

AI Summary

  • Core Issue: The College lacks proper documentation for payroll charges to federal grants, with 25% of sampled disbursements missing required time sheets and approvals.
  • Impacted Requirements: This finding violates 2 CFR 200.303(a) and 2 CFR 200.430(i)(1), which mandate effective internal controls and accurate records for federal awards.
  • Recommended Follow-Up: Implement stronger internal controls to ensure all payroll documentation is complete and approved before charging federal grants.

Finding Text

2024-012 (2023-006) PAYROLL Federal Agency: U.S. Department of Education Federal Program Title and Assistance Listing Number: Higher Educational Institutional Aid, 84.031 Type of Finding: Significant Deficiency in Internal Controls over Compliance/Material Non-compliance Compliance Area: Activities Allowed or unallowed, Allowable cost/cost principles Federal Award Year: 2024 Questioned Costs: None Condition The College’s supporting documentation did not agree to the amount of employee’s pay charged to grant. Of the 40 payroll disbursement samples tested, 10 samples (25%) lacked time sheets with evidence of supervisory approval or review. Management indicated that the College no longer has access to ADP, the payroll system used during the first half of FY2024, and therefore was unable to provide the required supporting documentation Criteria Per 2 CFR 200.303(a), 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). Per 2 CFR section 200.430(i)(1) – Compensation – personal services, Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Cause The College does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. Effect Lack of approval and inaccurate documentation for costs charged to grants puts the College at risk of charging unallowable costs, which in turn could result in required repayment to grantor agencies.

Corrective Action Plan

Recommendation We recommend the College develop and implement adequate policies and procedures to ensure charging of expenses for allowability are based off approved amounts. Corrective Action Unfortunately, due to the untimely completion and release of the June 30, 2023 audit report (released on August 8, 2025 - over two years after the end of the June 30, 2023 fiscal year audit), the College did not have the opportunity to review and begin a timely process of addressing a majority of the audit findings until well after the end of the audit period. While the College is committed to corrective action, the delayed delivery of the June 30, 2023 audit limited the ability to implement corrective measures earlier. The College is working proactively to ensure that these issues are resolved going forward. It is important to note that Southeast New Mexico College was a newly established independent community college, having formally separated from New Mexico State University (NMSU) as of April 2022. During this transition period, many administrative processes, including federal grant compliance procedures, were in the process of being developed, transitioned, and implemented independently from NMSU systems. As a result, certain policies, procedures, and documentation processes were not yet fully established or operational at the time of the audit. Corrective Action Taken / Planned: Policy and Procedure Development The institution will revise or develop written policies and procedures to ensure compliance with 2 CFR §200.430. The revised procedures will include: • Detailed requirements for supporting documentation for payroll costs. • Clear guidance on time and effort reporting. • Procedures for periodic payroll reconciliation between payroll records and grant charges. Staff Training Training will be provided for payroll, grants accounting, and department personnel involved in charging payroll costs to federal awards to ensure understanding and compliance with the new procedures. Payroll Reconciliation A process will be established to reconcile payroll charges to the grant with actual payroll records at least quarterly, with reviews and approvals documented. Effort Certification Employees whose salaries are charged to federal grants will be required to complete effort certifications, which will be reviewed and retained per federal guidelines. Monitoring and Review Grant accounting and payroll offices will implement an annual review process to ensure continued compliance and address any gaps or errors identified. Due Date of Completion: August 31, 2025 Responsible Part(ies) Vice President for Business and Finance (or appropriate official), Dean of Business and Finance, Restricted Funds Manager, Payroll Manager

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1177664 2024-011
    Material Weakness Repeat
  • 1177665 2024-012
    Material Weakness Repeat
  • 1177666 2024-015
    Material Weakness Repeat
  • 1177667 2024-011
    Material Weakness Repeat
  • 1177668 2024-012
    Material Weakness Repeat
  • 1177669 2024-015
    Material Weakness Repeat
  • 1177670 2024-011
    Material Weakness Repeat
  • 1177671 2024-012
    Material Weakness Repeat
  • 1177672 2024-015
    Material Weakness Repeat
  • 1177673 2024-011
    Material Weakness Repeat
  • 1177675 2024-015
    Material Weakness Repeat
  • 1177676 2024-014
    Material Weakness Repeat
  • 1177677 2024-015
    Material Weakness Repeat
  • 1177678 2024-014
    Material Weakness Repeat
  • 1177679 2024-015
    Material Weakness Repeat
  • 1177680 2024-015
    Material Weakness Repeat
  • 1177681 2024-013
    Material Weakness Repeat
  • 1177682 2024-015
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.031 HIGHER EDUCATION INSTITUTIONAL AID $1.01M
84.063 FEDERAL PELL GRANT PROGRAM $830,018
81.104 ENVIRONMENTAL REMEDIATION AND WASTE PROCESSING AND DISPOSAL $555,833
84.268 FEDERAL DIRECT STUDENT LOANS $145,293
84.002A ADULT EDUCATION - BASIC GRANTS TO STATES $90,960