Finding Text
2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Significant Deficiency
in Internal Controls over Compliance
Department of Education
Federal Assistance Listing Number: 84.425E
Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Student Aid Portion
Criteria – In accordance with the Funding Certification and Agreement for the Emergency Financial Aid Grants to
Students institutions must have a documented plan to distribute funds to students.
Condition/context – A sample of 18 disbursements to students out of a population of 113 disbursements to
students was selected. A documented plan for distribution of funds to students was requested, however the
College did not have a documented plan that clearly outlined the plan for disbursement. Additionally, we were
unable to obtain clear documentation of the rationale for approval of award amounts for students selected.
Our sample was not, and was not intended to be, statistically valid.
Questioned costs – None.
Cause/effect – The College did not have the controls in place to formerly approve a plan for distribution of funds
that was documented and circulated to the College. The lack of a documented plan for distribution of funds to
students increases the risk that funds were inappropriately disbursed to students at the wrong amounts. In
addition, it increases the risk that the disbursements were not equitable across the student population.
Repeat finding – No
Recommendation – We recommend the College adopt a policy that is formally approved and retained indicating
how HEERF student aid portion funds were to be distributed to students.
Views of responsible officials and planned corrective actions –
Responsible Individuals: Dr. Lorelle Davies, Chief Financial Officer
Michael N. Espinoza, Vice President of Student ServicesCorrective Action Plan: HEERF procedures and processes were adopted and provided to the auditors during the
audit process. Three independent outreach efforts were implemented to contact, support, and release funding to
students. Limited staffing and a sense of urgency in emergency disbursements contribute less than perfect
execution. Documentation was provided for all sample disbursements with a few instances of missing
documentation. The Rubric for disbursement through Student Services based on a Pell and enrollment need
evaluation was not available to auditors. The college can reproduce criteria to support disbursement. All HEERF
funding was distributed to students that met eligibility requirements within the June 30, 2023, disbursement
deadline. Ongoing efforts include the following:
The college will continue to archive and document all disbursement records.
Continued implementation of processes and procedures for all aid disbursement to prevent future
instances.
Anticipated Completion Date: Completed June 30, 2023