2023-006 – Payroll (Material Weakness in Internal Controls over Compliance/Material Noncompliance)
Recommendation: We recommend the College develop and implement adequate policies and procedures to ensure charging of expenses for allowability are based off approved amounts.
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 and Procedure Development
o The institution will revise or develop written policies and procedures to ensure compliance with 2 CFR §200.430. The revised procedures will include:
Detailed requirements for supporting documentation for payroll costs.
Clear guidance on time and effort reporting
Procedures for periodic payroll reconciliation between payroll records and grant charges.
• Staff Training
o Training will be provided for payroll, grants accounting, and department personnel involved in charging payroll costs to federal awards to ensure understanding and compliance with the new procedures.
• Payroll Reconciliation
o A process will be established to reconcile payroll charges to the grant with actual payroll records at least quarterly, with reviews and approvals documented.
• Effort Certification
o Employees whose salaries are charged to federal grants will be required to complete effort certifications, which will be reviewed and retained per federal guidelines.
• Monitoring and Review
o Grant accounting and payroll offices will implement an annual review to ensure continued compliance and address any gaps or errors identified.
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, Lisa Ryan, Restricted Funds Manager, Steven Gonzales, Payroll Manager