Finding 404734 (2023-012)

Significant Deficiency
Requirement
B
Questioned Costs
$1
Year
2023
Accepted
2024-06-29
Audit: 311103
Organization: College Unbound (RI)

AI Summary

  • Core Issue: The College did not provide adequate documentation for one expenditure, raising concerns about its allowability under federal guidelines.
  • Impacted Requirements: Costs must be documented, incurred during the approved budget period, and meet necessary criteria for federal awards.
  • Recommended Follow-Up: The College should establish internal controls to ensure reimbursement requests are submitted only for paid invoices.

Finding Text

Finding number: 2023-012 Federal agency: U.S. Department of Treasury Programs: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance listing #: 21.027 Award year: 2023 Compliance requirement: Allowable Costs Criteria According to 2 CFR 200.403 Factors affecting allowability of costs: Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (g) Be adequately documented. See also §§ 200.300 through 200.309 of this part. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3). Condition The Federal Government requires that costs must be adequately documented and must be incurred during the approved budget period. During our testing, we noted the College failed to provide a copy of check or ACH payment information for 1 expenditure, out of a sample of 5. As a result, the College was unable to provide the proof of payment to support the expenditure is an allowable cost. Our sample was not, and was not intended to be, statistically valid. Cause The College failed to have the proper internal controls in place to keep the proof of payment to support the expenditure that was reimbursed from the federal award. Effect The invoice that was reimbursed from the federal award may not be an allowable cost. Questioned Costs $1,655 Identification as a Repeat Finding, if applicable Not applicable. Recommendation The College should implement internal control procedures to verify that reimbursement requests are only submitted for invoices that have been paid. View of Responsible Officials The College agrees with the finding.

Corrective Action Plan

Finding number: 2023-012 Federal agency: U.S. Department of Treasury Programs: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance listing #: 21.027 Award year: 2023 Compliance requirement: Allowable Costs Corrective Action Plan: College Unbound has increased its administrative capacity and has implemented internal controls to properly track, account for and report on grant expenditures. CU hired the Vice President for Student and Institutional Sustainability in 2023 and subsequently a Controller and Bursar were hired in October 2023 to support the growing needs of the college. The Chief Development Officer, Program Staff and the Financial Team including the VP, Bursar, Financial Aid, and Controller have developed routines and procedures to ensure we are using grant funds as intended and have proper documentation. We are in the process of developing procurement protocols to align with federal grant expectations. Timeline for Implementation of Corrective Action Plan: Currently updating procedures to ensure compliance for FY25. Contact Person: Diana Perdomo, Vice President for Institutional and Student Sustainability/CFO

Categories

Questioned Costs Allowable Costs / Cost Principles

Other Findings in this Audit

  • 404720 2023-002
    Significant Deficiency Repeat
  • 404721 2023-003
    Significant Deficiency
  • 404722 2023-004
    Material Weakness Repeat
  • 404723 2023-004
    Material Weakness Repeat
  • 404724 2023-005
    Significant Deficiency
  • 404725 2023-006
    Material Weakness Repeat
  • 404726 2023-006
    Material Weakness Repeat
  • 404727 2023-007
    Significant Deficiency Repeat
  • 404728 2023-007
    Significant Deficiency Repeat
  • 404729 2023-008
    Material Weakness Repeat
  • 404730 2023-009
    Significant Deficiency
  • 404731 2023-010
    Significant Deficiency
  • 404732 2023-011
    Significant Deficiency Repeat
  • 404733 2023-011
    Significant Deficiency Repeat
  • 981162 2023-002
    Significant Deficiency Repeat
  • 981163 2023-003
    Significant Deficiency
  • 981164 2023-004
    Material Weakness Repeat
  • 981165 2023-004
    Material Weakness Repeat
  • 981166 2023-005
    Significant Deficiency
  • 981167 2023-006
    Material Weakness Repeat
  • 981168 2023-006
    Material Weakness Repeat
  • 981169 2023-007
    Significant Deficiency Repeat
  • 981170 2023-007
    Significant Deficiency Repeat
  • 981171 2023-008
    Material Weakness Repeat
  • 981172 2023-009
    Significant Deficiency
  • 981173 2023-010
    Significant Deficiency
  • 981174 2023-011
    Significant Deficiency Repeat
  • 981175 2023-011
    Significant Deficiency Repeat
  • 981176 2023-012
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $1.23M
84.063 Federal Pell Grant Program $1.04M
21.027 Coronavirus State and Local Fiscal Recovery Funds $809,807
84.116 Fund for the Improvement of Postsecondary Education $543,306
84.425 Education Stabilization Fund $324,547
84.007 Federal Supplemental Educational Opportunity Grants $12,170
84.033 Federal Work-Study Program $9,982