Finding Text
Federal agency: Department of Education Federal program title: Educational Stabilization Fund Assistance Listing Numbers: 84.425E ? Higher Education Emergency Relief Fund (HEERF) Student Portion 84.425F ? Higher Education Emergency Relief Fund (HEERF) Institutional Portion Award Period: July 1, 2021, to June 30, 2022 Type of Finding: Other Matters Finding related to Compliance within Uniform Guidance and Significant Deficiency in Internal Controls over Compliance. Criteria or specific requirement: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. There are three components to reporting for HEERF: 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) the annual report. Condition: During our testing of HEERF reporting requirements at Flagler College, we noted: 1) Non-Compliant Institutional Reporting a. One of the two institutional reports selected for testing was not posted on the College?s website. 2) Non-Compliant Annual Reporting a. Total institutional expenditures in the annual report did not agree to supporting documentation. 3) Internal Control a. The review and approval control could not be traced to supporting records during testing for any report submitted. Questioned costs known: None. Context: There were 3 separate reporting requirements tested as part of the HEERF Program. Each of the reports had a unique number tested for both internal control and compliance. 1) Public reporting on the (a)(1) Student Aid Portion. a. Both reports tested (two of two) were noncompliant for internal control purposes. 2) Public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable. a. One of the reports tested was noncompliant for compliance requirements. b. Both reports tested (Two of two) were noncompliant for internal control purpose. 3) The Annual Report a. The one report tested was noncompliant for compliance and internal control purpose. Cause: The policies and procedures of the College did not ensure that grant reporting requirements were timely and accurately met. Effect: Non-compliance with federal regulations which could lead to untimely and incorrect reporting. Repeat Finding: Yes, 2021-002. Recommendation: We recommend that the College review their reporting policies and procedures to ensure accurate and timely reporting. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.