Finding Text
Information of Federal Program:
Migrant Education (Title I) Program – CFDA No. 84.011(A)
Criteria: 2 CFR Part 200 requires the College to have the following internal controls in place
in order to determine allowability under federal awards; 1) Be necessary and reasonable for
the performance of the federal award and be allocable thereto under the principles in 2 CFR
Part 200, Subpart E. 2) Conform to any limitations or exclusions set forth in 2 CFR Part
200, Subpart E or in the federal award as to types or amount of cost items. 3) Be consistent
with policies and procedures that apply uniformly to both federally financed and other
activities of the non-federal entity. 4) Be accorded consistent treatment. A cost may not be
assigned to a federal award as a direct cost if any other cost incurred for the same purpose
in like circumstances has been allocated to the federal award as an indirect cost. 5) Be
determined in accordance with generally accepted accounting principles (GAAP), except for
state and local government and Indian tribes only as otherwise provided for in 2 CFR Part
200. 6) Not be included as a cost or used to meet cost-sharing or matching requirements of
any other federally financed program in either the correct or a prior period. 7) Be
adequately documented.
Condition: During our testing of expenses of the College, we selected forty (40) expenses
charged to Migrant Education (Title I) Program. During this testing, it was noted the College
issued payments without proper prior approval being kept on file and without regard to
College policy. Fifteen (15) of forty (40) expenses selected for testing were missing prior
approval.
Cause: The College did not have proper procedures in place regarding obtaining prior
approval and authorization for disbursements.
Effect or Potential Effect: The breakdown of internal controls in the area could adversely affect
the recording, processing and reporting of financial data, as well as creating an opportunity
for fraud to occur.
Questioned Costs: None Context: Disbursements were made by the College without proper internally required
approval and authorization.
Repeat Finding: No
Recommendation: Policies and procedures should be implemented prohibiting issuance of
payments without prior approval and authorization. All payments should be issued in
compliance with the College’s grants policy manual.
Views of responsible officials and planned corrective action: Management is in agreement
and will implement a Corrective Action Plan, see pages 72-75 of the current year audit.