Finding 600838 (2022-001)

Significant Deficiency Repeat Finding
Requirement
L
Questioned Costs
-
Year
2022
Accepted
2022-11-15
Audit: 22802
Organization: The Reed Institute (OR)
Auditor: Kpmg LLP

AI Summary

  • Core Issue: The College failed to implement adequate internal controls for timely reporting of HEERF student aid, leading to potential non-compliance with federal requirements.
  • Impacted Requirements: Quarterly public reporting under Section 18004(e) of the CARES Act and 2 CFR 200.303(a) for effective internal control over federal awards.
  • Recommended Follow-Up: Strengthen internal controls by formalizing the review process and documenting the dates of report uploads to ensure compliance and timely submissions.

Finding Text

Federal program and specific federal award identification Federal program: COVID-19-Education Stabilization Fund-Higher Education Emergency Relief Fund (HEERF) Assistance listing number: 84.425E ? Student Aid Portion Federal Agency: United States Department of Education Pass-through entity: None Grant ID number: P425E202283 Federal Award Year ended: June 30, 2022 Criteria or specific requirement Quarterly Public Reporting for Student Aid Portion (Assistance Listings 84.425E) Section 18004(e) of the CARES Act requires each institution that received funds under Section 18004 to ?submit a report to the Secretary, at such time and in such manner as the Secretary may require.? For the year ended June 30, 2022, institutions were required to post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. 2 CFR 200.303(a) requires that non-Federal entities receiving Federal awards establish and maintain effective internal control over the Federal award to provide reasonable assurance that they are managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition found For one of the four quarters inspected (Q1 - 2022), the College did not have the required control procedures to ensure the HEERF student aid portion reporting was reviewed and posted to the College?s website timely. The College did not document when student aid reporting was reviewed and posted to the College?s website, so we are unable to determine the timeliness of the submission. Cause The College did not have adequate internal controls in place related to reporting requirements for the HEERF program student award portion. Possible effect Federal oversight agencies, including the Department of Education, depend on accurate reports to measure program results and institutional compliance with federal requirements. By failing to have an appropriately designed and implemented review control over the HEERF student aid portion reporting in place, the College could have material non-compliance with the requirements of the HEERF Certification and agreement. Identification of questioned costs and how they were computed None. Whether the sampling was a statistically valid sample The sample was not intended to be, and was not, a statistically valid sample. Identification of whether the audit finding is a repeat of a finding in the immediately prior audit and, if so, the applicable prior year finding number Yes. Finding 2021-001. Finding 2022-001 had already occurred when finding 2021-001 was identified. Recommendations The College should strengthen its internal controls over HEERF reporting requirements for the Student Aid portion of the grant by developing and documenting a formalized review process, including documentation of the date reporting was uploaded to the College?s website, for the student award reporting. Views of responsible officials The following corrective measures have been implemented: The Director of Financial Aid requests the amounts and number of students who received HEERF funding from the Business Office at the end of each quarter and reviews, confirms, and documents the date of request and review. A log of the website updates is maintained to document timely submission of data. The website was revamped to include all necessary reporting requirements including the number of eligible students for CRSSA HEERF II and ARP HEERF III. This updated process was implemented upon identification of the prior year finding, which occurred after the first quarterly report for fiscal year 2022 was posted."

Categories

Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Subrecipient Monitoring

Other Findings in this Audit

  • 24396 2022-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $5.18M
84.268 Federal Direct Student Loans $4.94M
84.038 Perkins $1.41M
84.425 Education Stabilization Fund $1.10M
84.063 Federal Pell Grant Program $869,158
47.075 Social, Behavioral, and Economic Sciences $350,186
84.007 Federal Supplemental Educational Opportunity Grants $209,939
93.279 Drug Abuse and Addiction Research Programs $201,272
84.033 Federal Work-Study Program $192,130
47.070 Computer and Information Science and Engineering $179,365
93.859 Biomedical Research and Research Training $168,862
93.867 Vision Research $51,644
15.808 U.s. Geological Survey_ Research and Data Collection $38,677
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $22,247
93.RD Environmental Health Research Programs $20,000
15.633 Landowner Incentive Program $13,036
45.163 Promotion of the Humanities_professional Development $6,987
47.050 Geosciences $2,632
47.049 Mathematical and Physical Sciences $360