2023-005 – Inadequate Policies and Procedures (Significant Deficiency in Internal Controls over Compliance)
Recommendation: We recommend the College establish the required written procedures for federal monies and have them available to all personnel who work with federal programs.
Action Taken: The 2022-2023 fiscal year was entirely encompassed by the separation Memorandum of Understanding (MOU) of March 2022 and then the final release settlement in December 2023.
It is important to note that Southeast New Mexico College was a newly established independent community college, having formally separated from New Mexico State University (NMSU) as of April 2022. During this transition period, many administrative processes, including federal grant compliance procedures, were in the process of being developed, transitioned, and implemented independently from NMSU systems. As a result, certain policies, procedures, and documentation processes were not yet fully established or operational at the time of the audit.
Unfortunately, due to the untimely receipt of the completed audit report, the College did not have the opportunity to review and begin addressing several of the findings until well after the end of the audit period. While the College is committed to corrective action, the delayed delivery of the audit limited the ability to implement corrective measures earlier. The College is working proactively to ensure that these issues are resolved going forward.
Corrective Action Taken / Planned:
• Policy Development
o The institution will develop comprehensive written policies and procedures to address compliance requirements related to 2 CFR 200, Subparts D and E of the Uniform Guidance and approved by institutional leadership by July 31, 2025.
• Policy Review and Approval
o Draft policies will be reviewed by VP of Business and Finance and approved by institutional leadership by August 31, 2025.
• Training
o Relevant personnel will be trained on the new policies and procedures to ensure consistent understanding and compliance.
• Implementation
o The institution will fully implement the new procedures by August 31, 2025, and will ensure all departments involved with federal awards are following them.
• Ongoing Review:
o Policies and procedures will be reviewed annually, and updates will be made as necessary to ensure continued compliance with federal regulations.
Due Date of Completion: August 31, 2025
Responsible Official: Carolyn Kasdorf, Vice President for Business and Finance (or appropriate official), Karla Volpi, Dean of Business and Finance, Rebecca Silva, Director of Finance, Lisa Ryan, Restricted Funds Manager