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Finding Number: 2022-002 Prior Year Finding: No Federal Agency: U.S. Department of Education Federal Program: COVID-19 ? HEERF Institutional Portion Assistance Listing: 84.425F Award Period: P425F203655 (6/2/2020 ? 2/28/2022) Compliance Requirement: Reporting ? Quarterly Public Reporting ? Institutional Portion Type of Finding Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Compliance ? Recipients of Education Stabilization Fund-Higher Education Emergency Relief Fund (HEERF) must complete the following special reporting components: 1) Public reporting on the (a)(1) Student Aid Portion; 2) Public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) Annual report. Quarterly Public Reporting-Institutional Portion: The CARES, CRRSAA, and ARP institutional quarterly portion reporting requirements involve publicly posting completed forms on the institution?s website. The forms 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. A new, separate form must be posted covering aggregate amounts spent for HEERF I, HEERF II, and HEERF III funds each quarterly reporting period, concluding after an institution has expended and liquidated all (a)(1) Institutional Portion, (a)(2), and (a)(3) funds and checks the ?final report? box. IHEs must post this quarterly report form no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, July 10). Control ? Per 2 CFR section 200.303(a), a 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 comply 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/Context: Two of two quarterly reports selected for testing were not submitted within ten days after the end of the quarter. The report for the quarter ending 9/30/2021 was due no later than 10/10/2021 but it was filed on 10/15/2021. The report for the quarter ending 12/31/2021 was due no later than 1/10/2022 but it was filed on 1/19/2022. Questioned Costs: Undetermined Cause: The College did not have effective procedures and controls in place to ensure it filed quarterly reports in a timely manner. Effect: The College was not in compliance with HEERF special reporting requirements. Recommendation: The College should review and enhance internal controls and procedures to ensure that the quarterly reports are submitted timely and that it posts required information timely on its website in a format and location that is easily accessible to the public. Views of Responsible Officials: The finance department is in the process of enhancing business processes and strengthening internal controls to ensure timely posting of the quarterly reports on the College?s website. The Accounting Director is doing a review of each accountant?s grant responsibilities in order to reallocate grant responsibilities to balance the workload. Since FY 2019 there has been a 40% increase in grant funds. The Accounting Director will work more closely with the grant accountants and provide more grant reporting oversight. The Director will create a detailed grant reporting database to monitor the reporting deadlines of each grant. On a monthly basis, the Director will review grant reporting deadlines with each grant accountant to ensure that reports are timely filed/posted. If needed, workload will be reallocated to accommodate tight reporting requirements, or a request for extension of time to file/post will be made to the grantor.