Finding Text
FINDING 2022-001 ? Reporting: Significant Deficiency Over Internal Controls Over Compliance "See Schedule of Findings and Questioned Costs for chart/table" Criteria: According to an electronic announcement (?EA?) by U.S. Department of Higher Education (?ED?) on May 6, 2020, ED required institutions that received a Higher Education Emergency Relief Fund (?HEERF?) 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after award, and update that information every 45 days thereafter (by posting a new report). On August 31, 2020, ED revised the EA with 85 FR 53802, which decreased the frequency of subsequent reporting from every 45 days to every calendar quarter. Additionally, 2 CFR 200.303 requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure the timely posting of special reports to their website. Condition/Context: Southern California Institute of Architecture (?SCI-Arc?) did not publicly post a special report on a timely basis. SCI-Arc is required to prepare and publicly post a special report (Section 18004(a)(1) Student Aid Portion Quarterly Public Reporting) with certain information describing the use of funds distributed from the HEERF on their website no later than 30 days after receiving the award. SCI-Arc was required to publicly post the initial report to its website by April 10, 2022; however, SCI-Arc did not post this report to the website until May 3, 2022. Cause: In discussing these conditions with SCI-Arc management, the delay in publicly posting the special report to SCI-Arc?s website was due to an oversight by the management team of the published deadline during quarter one of 2022. Effect: Failure to publicly post special reports to SCI-Arc?s website on a timely basis does not allow the public to access timely information on how SCI-Arc used the funds received from the HEERF. Repeat Finding: This is not a repeat finding. Recommendation: We recommend SCI-Arc implement procedures to ensure special reports are posted to SCI-Arc?s website in a timely manner. Views of responsible officials: The school?s management agrees with the finding and has implemented procedure whereby the CFO will send calendar reminders to the Financial Aid Manager and other parties involved to set a reminder of submission deadlines for each quarterly report and set an internal deadline prior to such due date. Due dates are specified by OMB Control Number 1840-0849; the reporting deadline for quarterly reports is 10 days after each reporting period. In addition to the calendar invitation above, once the report is uploaded, the uploader will send a follow-up email to all parties involved to confirm that the upload to the website has occurred. If the uploader has not posted the report to the website within two business days of receipt, the Financial Aid Manager will follow-up with the uploader to ensure the posting happens before the reporting deadline.