Finding Text
Assistance Listing Number: 84.425F
Program Name: COVID-19: HEERF – Institutional Portion
Pass Through Identifying Number: N/A
Award Year: 2022-2023
Federal Agency: U.S. Department of Education
Criteria: Non-federal entities are required to establish and maintain effective internal controls over
compliance in accordance with 2 CFR 200.303(a). Management should ensure that internal controls
related to federal and state awards are appropriately designed and operating effectively in order to
comply with 2 CFR 200.305.
Condition: The College did not ensure that internal controls were appropriately designed and
operating in regards to HEERF drawdowns which resulted in the incorrect classification of two
different awards within G-5, an overdraw of funds in the amount of $1.9M and the incorrect
recording of associated grant revenues.
Cause: Turnover at the College had led to unqualified personnel at the management level.
Effect: Journal entries for drawdown of HEERF funds were not approved within Colleague,
drawdown requests were not reviewed and approved prior to submitting within G5 reporting
system. Additionally, bank reconciliations were not reviewed by the CFO/VP of Finance and
Business Operations in order to reconcile payments received from the DOE to grant accounts. It was
determined that controls in place were not operating effectively during the fiscal year.
Questioned costs: N/A
Recommendation: Management must review the roles and responsibilities of accounting personnel
and ensure they have the necessary background and training to properly execute required
accounting functions and adhere to necessary internal control functions. Management should
review the controls in place and assess that such controls are designed appropriately given the
positions in roles within the accounting department.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with the findings
and, as discussed, the College is currently searching for a candidate to fulfill the CFO position with
the appropriate level of training. The College does intend to interview accounting professionals
from the community to determine if appropriate levels are present.
Responsible Party: Dr. Justin Hoggard, Board President and Dixie Lytle, Director of Human Resources
Expected Completion: December 31, 2024
Anticipated Completion: December 31, 2024