Finding 516387 (2024-006)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2024-12-20
Audit: 334325
Organization: Clatsop Community College (OR)

AI Summary

  • Core Issue: The College failed to provide the required URL for the contract and cost information to the Department of Education, violating compliance standards for Tier One arrangements.
  • Impacted Requirements: Non-compliance with 34 CFR 668.164(e) and (f) regarding disclosure requirements for agreements with third-party servicers.
  • Recommended Follow-Up: Implement procedures to ensure compliance with all requirements of Tier One arrangements and prevent future violations.

Finding Text

Criteria or specific requirement: An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent, to issue a check payment to the student or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. Additional guidance on Tier One and Tier Two arrangements can be found in Dear Colleague Letter GEN-22-14; Volume 4, Chapter 2 of the FSA Handbook; and the Cash Management Q&A. These schools must take affirmative steps, by way of contractual arrangements with the third-party servicer as necessary, to ensure that requirements for these arrangements are met with respect to all accounts offered pursuant to the arrangement (34 CFR 668.164(e)(2)(x) and (f)(4)(ix)). In addition, per Uniform Guidance 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. Condition: The College did not provide the URL for the contract or cost information to the Department of Education. Questioned Costs: None Context: The College did not meet the compliance requirement to report the URL for the contract and cost information to the Department of Education. Cause: The College did not have proper procedures in place to ensure that all requirements were being met. Effect: The College is not in compliance with disclosure requirements of a Tier One arrangement with a third-party servicer. Repeat Finding: Yes, Prior year finding 2023-006. Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for a third-party servicer are being met. Views of responsible officials: There is no disagreement with the audit finding.

Categories

Cash Management Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 516371 2024-001
    Significant Deficiency
  • 516372 2024-002
    Significant Deficiency Repeat
  • 516373 2024-002
    Significant Deficiency Repeat
  • 516374 2024-003
    Material Weakness
  • 516375 2024-003
    Material Weakness
  • 516376 2024-003
    Material Weakness
  • 516377 2024-003
    Material Weakness
  • 516378 2024-004
    Material Weakness Repeat
  • 516379 2024-004
    Material Weakness Repeat
  • 516380 2024-004
    Material Weakness Repeat
  • 516381 2024-004
    Material Weakness Repeat
  • 516382 2024-005
    Material Weakness Repeat
  • 516383 2024-005
    Material Weakness Repeat
  • 516384 2024-005
    Material Weakness Repeat
  • 516385 2024-005
    Material Weakness Repeat
  • 516386 2024-006
    Significant Deficiency Repeat
  • 516388 2024-006
    Significant Deficiency Repeat
  • 1092813 2024-001
    Significant Deficiency
  • 1092814 2024-002
    Significant Deficiency Repeat
  • 1092815 2024-002
    Significant Deficiency Repeat
  • 1092816 2024-003
    Material Weakness
  • 1092817 2024-003
    Material Weakness
  • 1092818 2024-003
    Material Weakness
  • 1092819 2024-003
    Material Weakness
  • 1092820 2024-004
    Material Weakness Repeat
  • 1092821 2024-004
    Material Weakness Repeat
  • 1092822 2024-004
    Material Weakness Repeat
  • 1092823 2024-004
    Material Weakness Repeat
  • 1092824 2024-005
    Material Weakness Repeat
  • 1092825 2024-005
    Material Weakness Repeat
  • 1092826 2024-005
    Material Weakness Repeat
  • 1092827 2024-005
    Material Weakness Repeat
  • 1092828 2024-006
    Significant Deficiency Repeat
  • 1092829 2024-006
    Significant Deficiency Repeat
  • 1092830 2024-006
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $1.16M
84.268 Federal Direct Student Loans $469,816
84.044 Trio—talent Search $378,332
84.047 Trio—upward Bound $361,025
84.042 Trio--Student Support Services $350,960
84.048 Career and Technical Education—basic Grants to States $267,573
84.002 Adult Education—basic Grants to States $185,324
21.027 Covid-19 Coronavirus State & Local Recovery Funds $129,709
84.007 Federal Supplemental Educational Opportunity Grants $106,461
84.425 Covid-19 Arp Esser---Ccl Navigator $104,281
59.037 Small Business Development Centers $93,084
84.033 Federal Work-Study Program $92,209