Finding 1241788 (2024-007)

Material Weakness Repeat Finding
Requirement
H
Questioned Costs
-
Year
2024
Accepted
2026-11-06
Audit: 415778
Organization: College of the Marshall Islands (MH)

AI Summary

  • Core Issue: Salaries were charged to the program before the allowed funding period, leading to noncompliance with federal requirements.
  • Impacted Requirements: The College failed to adhere to 2 CFR 200.344(c) regarding the period of performance and lacked effective internal controls as mandated by 2 CFR 200.303(a).
  • Recommended Follow-Up: College management should enhance internal controls to ensure all costs are incurred within the specified funding period and conduct regular reviews for compliance.

Finding Text

Finding No.: 2024-007 - Period of Performance Identification of the federal program: Federal Agency: U.S. Department of the Interior AL No. and Title: 15.875 Economic, Social and Political Development of the Territories Federal Award No.: Compact of Free Association Program, As Amended Criteria or specific requirement (including statutory, regulatory or other citation): The terms of the sub-awards administered by RepMar under the Compact of Free Association grant awards stipulate the period of performance during where costs resulting from obligations of the funding period may be charged. 2 CFR 200.344(c) states: The recipient must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the conclusion of the period of performance. When justified, the Federal agency or pass-through entity may approve extensions for the recipient or subrecipient. 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 recipient or 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 Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Salaries charged to the program were incurred prior to the funding period stipulated in the grant awards. Cause: The College lacks adequate internal controls over compliance with applicable federal regulations relating to period of performance. Effect or potential effect: The College is in noncompliance with applicable period of performance requirements. Questioned costs: $8,351 Context: We identified 333 transactions recorded during the beginning of the period of performance totaling $349,375. We tested 40 transactions totaling $55,185. The samples were statistically valid. Of 40 transactions tested, 19 (or 48%) transactions were incurred prior to the period of performance. Details of samples with noncompliance are as follows: Identification as a repeat finding, if applicable: 2023-007 Recommendation: College management should improve internal control policies and strengthen controls to comply with applicable period of performance requirements. Specifically, review should be performed to ensure all costs charged to the program are incurred within the funding period stipulated in the grant awards. Views of responsible officials: The College agrees with the finding and provides details in its Corrective Action Plan.

Corrective Action Plan

The College acknowledges the repeated finding and recognizes the need to strengthen internal controls to ensure that expenditures charged to federal programs are incurred within the approved period of performance. During FY2025–FY2026, the College continued implementing corrective measures, including the use of an upgraded cloud-based filing system to improve documentation, monitoring, and verification of grant funding periods. The College has also continued strengthening coordination among the Business Office, Human Resources, and program personnel to ensure that payroll expenditures are properly reviewed and aligned with the applicable grant award periods. Additionally, the College continues to improve its review procedures to ensure that payroll costs are charged based on the actual period in which services were performed rather than the payment date. The College will also review the identified questioned costs and determine whether any adjustments or additional corrective actions are necessary. These ongoing efforts are intended to strengthen compliance with federal period of performance requirements and prevent recurrence of similar findings in future audits.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 1241786 2024-005
    Material Weakness Repeat
  • 1241787 2024-006
    Material Weakness Repeat
  • 1241789 2024-008
    Material Weakness Repeat
  • 1241790 2024-009
    Material Weakness Repeat
  • 1241791 2024-010
    Material Weakness Repeat
  • 1241792 2024-011
    Material Weakness Repeat
  • 1241793 2024-012
    Material Weakness Repeat
  • 1241794 2024-013
    Material Weakness Repeat
  • 1241795 2024-014
    Material Weakness Repeat
  • 1241796 2024-015
    Material Weakness Repeat
  • 1241797 2024-016
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $7.42M
15.875 ECONOMIC, SOCIAL, AND POLITICAL DEVELOPMENT OF THE TERRITORIES $2.20M
11.028 CONNECTING MINORITY COMMUNITIES PILOT PROGRAM $721,598
84.047 TRIO UPWARD BOUND $237,825
10.308 RESIDENT INSTRUCTION, AGRICULTURE, AND FOOD SCIENCE FACILITIES AND EQUIPMENT GRANTS $26,277
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $12,552
84.425 EDUCATION STABILIZATION FUND $2,100