Finding 1177681 (2024-013)

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

AI Summary

  • Core Issue: The College used a sole source procurement for a training simulator but did not provide its own determination, relying instead on the vendor's.
  • Impacted Requirements: This violates 2 CFR 200.303(a) and 2 CFR 200.318(i), which require effective internal controls and proper documentation of procurement decisions.
  • Recommended Follow-Up: The College should establish its own sole source determination process and ensure compliance with federal procurement guidelines to avoid potential questioned costs.

Finding Text

2024-013 (2023-008) PROCUREMENT, ABOVE SIMPLE ACQUISITION THRESHOLD Federal Agency: U.S. Department of Energy Federal Program Title and Assistance Listing Number: Environmental Remediation and Waste Processing and Disposal, 81.104 Type of Finding: Significant Deficiency in Internal Controls over Compliance Compliance Area: Procurement and suspension and debarment Federal Award Year: 2024 Questioned Costs: None Condition During our review of procurement testing, the College acquired a training simulator through a sole source procurement. The College displayed on their website the “vendor’s determination”, not the “College’s determination”. In 2024, the College prepaid $1,577,250 on this procurement. 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 200.318(i), non-federal entities must retain documentation sufficient to detail the history of procurement decisions. Cause The College did not provide their own independent sole source determination. Effect The College may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the grantor agency.

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

Procurement, Suspension & Debarment

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
  • 1177674 2024-012
    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
  • 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