MOHAWK VALLEY COMMUNITY COLLEGE

2025-001 Bank Reconciliations Criteria: Monthly bank reconciliations being performed timely play a key role in ensuring the accuracy of financial information and to minimize the risk of misstatement or misappropriation. Condition: Bank reconciliations for August 2025 were not yet completed as of our audit fieldwork and they were not provided to us to review until February/March 2026 after the SUNY Annual Report was filed. Additionally, the following was noted:  GCard receipts are recorded in the bank statement however there is a carrying balance that has not been recorded in BANNER. These unrecorded amounts in BANNER have been growing and are being tracked, however, they were not appropriately included on the bank reconciliations.  The General Expense Checking reconciliation had an outstanding check listing that contained checks that had been previously voided in BANNER. Effect or Potential Effect: If bank reconciliations are not being performed timely, there is a risk that errors or fraudulent activity would not be detected timely. Additionally, monthly internal financial statements could be inaccurate and contain misstatements without this key control being performed timely on a monthly basis. Context and Cause: There was turnover in a newly hired accountant position that bank reconciliations had been assigned to as the position was only occupied for a few months. Turnover, training of new staff, and leaves of absences in business office positions has contributed to the difficulties in completing bank reconciliations timely. Recommendation: We recommend the College review and improve their procedures over completing bank reconciliations timely. Procedures should include implementing an independent review process and allowing the Controller to be reviewing the completed bank reconciliations as opposed to preparing them. 50 MOHAWK VALLEY COMMUNITY COLLEGE SCHEDULE OF FINDINGS AND QUESTIONED COSTS - FEDERAL COMPLIANCE REQUIREMENTS For the Year Ended August 31, 2025 Management Response: Current Business Office staff have been catching up on performing bank reconciliations and investigating reconciling items, including obtaining reports so that GCard receipts can be investigated. Clear deadlines have been established and formally communicated to Business Office staff and specific individuals have been assigned ownership of each account reconciliation with a formal review and approval process implemented to ensure accuracy and completeness. Management will perform periodic spot checks to ensure ongoing compliance with reconciliation procedures and timeliness. Management will provide period updates to the Audit & Finance Committee regarding the status and timeliness of bank reconciliations. Any delays or issues will be communicated to the Committee and, as appropriate, to the Board of Directors to ensure transparency and allow for governance monitoring and oversight. Findings and Questioned Costs – Major Federal Award Programs Audit None.

2021-01 Return of Title IV calculation Compliance Requirement: Reporting U.S. Department of Education Assistance Listing Number #84.007, 84.033, 84.038, 84.063 and 84.268 ? Student Financial Assistance Programs Cluster Condition: During our test of Title IV refunds, the following was noted: 1) Timely post-withdrawal disbursement or return of unearned Title IV funds was not met in accordance with regulations for four students who unofficially withdrew. 2) For the unofficial withdrawals in the Spring 2021 semester, the College processed certain R2T4 calculations by applying the midpoint methodology while others were processed using the last date of attendance records. No records were maintained to document the change in methodology. 3) One student withdrew and the College processed the R2T4 calculation resulting in $1,088 in Pell award due to the student as a post withdrawal disbursement. However, no posting of the post withdrawal disbursement was made on the student account nor was any activity processed in the COD website regarding the post withdrawal award due to the student. Criteria: For items under #1 above, timeliness for post-withdrawal and return of unearned Title IV funds should be adhered to in accordance with the regulations. For #2 above, the R2T4 calculations should be processed in such a manner where consistent methodology is applied and if necessary to apply a different, but permissible methodology, proper documentation should be noted and retained. For item under #3 above, students who are eligible for a post withdrawal award should have those funds available to them by posting the amount on the students account and updating records in the COD website for the eligible award disbursement. Cause: Unknown. 49 Effect or Potential Effect: The College is more at risk of not complying with reporting requirements regarding timeliness, and detecting transactions that were not posted properly even though the R2T4 calculation was done. Also, even though both methods are permissible under regulations, the application of inconsistent methodologies for the same population/semester in processing R2T4 calculations without providing documentation as to why one method was applied versus the other, will result in inconsistent treatment of the population. Known Questioned Costs: None noted. Context: Official and unofficial withdrawal population for the Fall 2020 and Spring 2021 semesters. Repeat Finding: No Recommendation: It is recommended that timeliness in processing R2T4 calculations should be adhered to. The College should apply a consistent methodology to the same population and if a need exists to switch the methodology, proper documentation should be retained as support. In addition, we recommend that corrective procedures be established in order to prevent and or detect situations where required postings to a student account and reporting to COD was not made for a post withdrawal that was due to the student. Views of Responsible Officials: We will develop a timeline to ensure timeliness for post-withdrawal and return of unearned Title IV funds for future semesters. We will also ensure that one methodology will be used in any given semester when processing R2T4 calculations. The decision as to which methodology to use will be documented. 2021-02 Reporting Under Federal Funding Accountability and Transparency Act (FFATA) Compliance Requirement: Reporting U.S. Department of Labor Assistance Listing Number #17.270 ? Reentry Employment Opportunities Assistance Listing Number #17.274 -Youthbuild Assistance Listing Number #17.287- Job Corps Experimental Projects and Technical Assistance Condition: During our test of FFATA submissions we tested 4 grants and noted the following: Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 4 0 2 2 0 Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $731,050 $0 $406,572 $379,370 $0 Criteria: First-tier awards that are subject to reporting under the Transparency Act based on (a) the date of the award and (b) the amount of the obligating action for subawards including modifications. If a subaward is subject to reporting, the College is required to enter the award information in the FSRS portal. Information entered should be supported by source documents such as signed subaward agreements and if applicable modifications or amendments. The action needs to be reported in FSRS portal no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made. Cause: Unknown. Effect or Potential Effect: Noncompliance with FFATA reporting including timeliness and accuracy of information submitted. Known Questioned Costs: None noted. Context: First-tier subawards. Repeat Finding: No 50 Recommendation: It is recommended that timeliness and accuracy in submitting the FFATA reporting should be adhered to. Specifically, if a department receives a direct federal grant award and in turn makes first-tier subawards, the person responsible for the grant administration should be alerted to the triggering events that could result in a need for the FFATA reporting. This includes any amendments to the sub award agreement. It is important that the individual submitting the FFATA reporting is using information from the actual signed subaward agreement or amendment in completing the submission and not budgeted amounts. Therefore, by being vigilant to the triggering events for reporting and using correct data in submissions, the College will meet the FFATA reporting requirements. Views of Responsible Officials: We will develop a process whereas departments who receive a direct federal grant award and anticipates making first-tier subawards will alert the Director of Compliance. The responsible person within the grantee department will work with the Director of Compliance to establish a reporting calendar to ensure compliance with reporting deadlines. Further, the Director of Compliance will review amounts to be reported with the responsible person prior to submission to ensure proper amounts are reported.

2020-01 Return of Title IV calculation Compliance Requirement: Reporting U.S. Department of Education CFDA #84.007, 84.033, 84.038, 84.063 and 84.268 ? Student Financial Assistance Programs Cluster Condition: During our test of Title IV refunds, the following was noted: 1) one student who officially withdrew in the Spring 2020 semester but for whom the return of Title IV calculation was not completed; 2) one student for whom the return of Title IV calculation was done accurately but posting to the student account was inaccurate by $45 and 3) students who withdrew after March 13, 2020 fall under the CARES Act R2T4 waiver. However, no R2T4 calculation was done for the population of students who unofficially withdrew and no reporting was made to the Department of Education as required. Criteria: For items under #1 and #2 above, R2T4 calculations should be processed in such a manner that captures completeness of the populations and are completed accurately. For item under #3 above, CARES Act regulations require certain reporting. Therefore, it is necessary for institutions to perform R2T4 calculation for each student covered by the CARES Act R2T4 waiver and submit the required information. Cause: For item under #1 above, it was noted that the process of receiving information regarding an official withdrawal has changed due to a remote working environment and an email attachment with the information was missed by the recipient. For item under #2 ? a manual posting error occurred. For item under #3 ? This was a new requirement due to the pandemic. (Continued) 50 MOHAWK VALLEY COMMUNITY COLLEGE SCHEDULE OF FINDINGS AND QUESTIONED COSTS - FEDERAL COMPLIANCE REQUIREMENTS For the Year Ended August 31, 2020 (Continued) Effect or Potential Effect: The College is more at risk of not capturing a complete population for the R2T4 calculations, inaccurate R2T4 calculation or posting and noncompliance with the reporting requirements. Known Questioned Costs: None noted. Context: Official and unofficial withdrawal population for the Fall 2019 and Spring 2020 semesters. Repeat Finding: No Recommendation: It is recommended that a listing that is generated from the Registrars office of all the students who officially withdrew be reviewed independently by an individual who is not charged with the responsibility of performing the R2T4 calculations for completeness of the population. Evidence of the review should be retained. In addition, a secondary review of the R2T4 calculations is strongly recommended as it will allow for detection or prevention of potential errors. If resources do not allow for 100% review, then a statistical sample should be drawn from the population. This secondary review should be documented and evidence retained. In addition, College should comply with the reporting requirements for each student covered by the CARES Act R2T4 waiver.

2019-01 Federal Uniform Guidance Policies and Procedures Condition: The College currently has effective procedural controls in place over the management of Federal awards as concluded through the testing of grant expenditures. However, key changes under the Uniform Guidance expanded the rules regarding the documentation of internal controls over Federal Awards to require that they be documented in writing in the College?s policies and that management should evaluate and document the results of ongoing monitoring to identify internal control issues. The written internal controls should specifically address each of the applicable twelve (12) compliance requirements of the Federal award programs. Criteria: On December 26, 2014 the Office of Management and Budget?s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, more commonly referred to as the ?Uniform Guidance,? became effective for all Federal awards, whether the funds are provided directly from a Federal agency or passed-through another state or local agency. Cause: Unknown Effect or Potential Effect: The College is more at risk of noncompliance with Federal Grant regulations related to Uniform Administrative Requirements by not having fully documented procedural controls in place.Known Questioned Costs: None noted. Context: The College manages multiple federal programs in a single year. Repeat Finding: No Recommendation: The College should document policies and procedures in accordance with the new Uniform Guidance. This should include monitoring procedures to ensure that internal controls over compliance for the various programs are working effectively. Management?s Response: The College will develop policies and procedures for the new Uniform Guidance. Policies and procedures will be documented and monitored to ensure internal controls over compliance are working effectively

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