Finding Text
Criteria or Specific Requirement: Compliance ? Per Federal Register Notice of Public Posting Requirement of Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees dated 5/13/21, institutions are required to submit (in a time and manner required by the Secretary) a report to the Secretary describing the use of funds distributed from the HEERF. The Department further requires institutions to post all quarterly reports to their website in a publicly accessible location. Internal Control ? Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-Federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Various errors were noted in reports either due to inaccurate or missing information, timeliness of reporting, and record retention requirements. Questioned Costs: None Context: Out of 4 quarterly student reports, 2 quarterly institutional reports, and 1 annual report selected for testing, the following reporting errors were identified: Type of Report Time Period for Reporting Specific Condition(s) Related to Inaccurate or Missing Information Quarterly Student June 2021 Missing required elements #1 and #4. Quarterly Student March 2022 Missing required elements #1 and #4. Quarterly Institutional September 2021 Improperly reported zero expenditures for the quarter. Related to Timeliness of Reporting Quarterly Student June 2021 Report not posted timely (Due 10 days after quarter-end, posted 8/26/21) Quarterly Student March 2022 Report not posted timely (Due 10 days after quarter-end, posted 4/11/22) Quarterly Institutional September 2021 Report not posted timely (Due 10 days after quarter-end, posted 10/19/21) Annual Report Annual Report not submitted timely (Due 5/6/22, submitted 5/11/22) Related to Other Conditions Quarterly Student September 2021 Quarterly report missing from website Quarterly Student December 2021 Quarterly report missing from website Cause: The College did not have appropriate controls in place to ensure documentation was maintained and retention requirements were met. Effect: The institution is not meeting the reporting and information-sharing requirements determined by the Department of Education. As a result, the institution may be subject to additional enforcement actions by the Department of Education including a delay in funding for additional HEERF programs and possibly being determined ineligible for other program funding. Repeat Finding: Yes, prior year finding 2021-001. Recommendation: We recommend the College review the reporting requirements and implement procedures to ensure that all required reports are issued/posted in an accurate and timely manner. Views of Responsible Officials: There is no disagreement with the audit finding.