Finding 372674 (2023-003)

Criteria On May 13, 2021, ED published an additional notice for student aid public reporting under CRRSAA and ARP, which requires that institutions 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 (September 30, and December 31, March 31, June 30). In addition, the U.S. Department of Education requires an annual report for HEERF grantees which is due no later than March 24, 2023. Title 2 U.S. Code of Federal Regulations Part 200 (2CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 303(a) states, 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 statues, 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). Condition During our testwork over the quarterly and annual reports for the student aid portion, KPMG noted the following: • The September 30, 2022 and December 31, 2022 quarterly student aid portion reports were incorrectly prepared as the College reported the student and institutional portion award grant amounts on the incorrect lines within the report. • There was no evidence that the quarterly or annual reports were reviewed by an appropriate responsible official at the College before the reports were posted on the College’s website or submitted to the U.S. Department of Education. Cause The condition resulted from an insufficient review of the reports by responsible officials prior to the reports being posted to the College’s website or being submitted to the U.S. Department of Education. Possible Asserted Effect Failure to implement sufficient internal controls to ensure the accuracy and timely filing of these quarterly and annual reports in accordance with federal regulations resulted in the College program being noncompliant with federal statues, regulations and the terms and conditions of the federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding was a Repeat Finding This is not a repeat finding. Recommendation We recommend that the College enhance its process and controls over required federal reports to ensure, where applicable, the following: 1) Adequate support is maintained to document that the reports are prepared and reviewed by an appropriate individual at the College prior to posting the information to the College’s website. 2) Ensure appropriate segregation of duties between the preparer and reviewer of such reports. 3) Ensure that the reports are accurately prepared prior to being filed with the U.S. Department of Education.