LAKE COUNTY COMMUNITY COLLEGE DISTRICTHigher Education

Assistance Listing Number, Federal Agency, and Program Name - 84.007, 84.063, 84.268; U.S. Department of Education; Federal Supplemental Educational Opportunity Grants, Federal Pell Grant Program, Federal Direct Student Loans Federal Award Identification Number and Year - P007A236053, P063P232857, P268K242857; 2024 2025 Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - Yes 2024-002 Criteria - In accordance with 2 CFR 200.303, the College must establish and maintain effective internal control over its federal awards in order to provide reasonable assurance that it is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Specific to these Title IV programs, 34 CFR 668.22 outlines the requirements for institutions to follow when returns of Title IV funds are required, including identifying when calculations are necessary and the time frame in which they are required to be returned. Condition - There was a lack of internal controls in place related to the return of Title IV funds, which lead to two students with returns that were not issued timely and two students with error in return calculations. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - N/A Context - Once return calculations were identified and calculated, there were no controls in place to ensure that the calculations were complete, accurate, or returned in a timely manner. Cause and Effect - A lack of review of the processes to identify students who required a calculation, review the completed calculations for accuracy, or ensure that that all calculated returns were completed could lead to incomplete calculations, inaccurate calculations, or untimely return of funds once they are identified. Recommendation - We recommend that the College implement a review control that would cover each stage of the return process outlined. Views of Responsible Officials and Corrective Action Plan - The College has implemented procedures to verify that academic dates are entered accurately in Banner and confirmed by personnel other than those responsible for calculating and reviewing returns of Title IV funds. This should ensure the related calculations are complete and accurate, and the funds are returned in a timely manner.

Assistance Listing Number, Federal Agency, and Program Name - N/A, Schedule of Expenditures of Federal Awards (SEFA) Reporting Federal Award Identification Number and Year - N/A Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - Uniform Guidance (2 CFR 200.510(b)) requires a schedule of expenditures of federal awards (SEFA) that must provide total federal awards expended for the period covered by the auditee's financial statements. Federal awards expended in accordance with §200.502 should be based on when the underlying activity related to the federal award occurs. Condition - During our review of the schedule of expenditures of federal awards, we noted that certain federal program expenditures were included in the SEFA for the fiscal year ended June 30, 2025 even though the underlying activity occurred in 2024. The College did not have adequate controls in place to ensure the SEFA was prepared to include appropriate expenditures for the Economic Development Cluster in the proper period. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - N/A Context - During our review of the College's SEFA, we noted expenditures of $318,814 that were improperly included within the Economic Development Cluster in 2025. Based on review of underlying expenditures on vendor pay applications, expenditures should have been included on the SEFA in 2024. Cause and Effect - The College did not have adequate processes and internal control structure in place to ensure SEFA expenditures were recorded in the appropriate period. As a result, the SEFA is overstated by $318,814 in 2025. If the SEFA does not accurately reflect federal expenditures for the audit period, this could lead to misinterpretation of compliance requirements and inaccurate reporting to federal agencies. Recommendation - We recommend management implement procedures to ensure the SEFA preparation is based on the timing of the underlying activity rather than payment dates. Views of Responsible Officials and Planned Corrective Actions - The College will establish the proper controls to ensure that the SEFA is prepared based on the timing of the underlying activity rather than payment dates.

Assistance Listing Number, Federal Agency, and Program Name - 84.007, 84.063, 84.268; U.S. Department of Education; Federal Supplemental Educational Opportunity Grants, Federal Pell Grant Program, Federal Direct Student Loans Federal Award Identification Number and Year - P007A236053, P063P232857, P268K242857; 2023-2024 Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - In accordance with 2 CFR 200.303, the College must establish and maintain effective internal control over its federal awards in order to provide reasonable assurance that it is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Specific to these Title IV programs, 34 CFR 668.22 outlines the requirements for insitutions to follow when returns of Title IV funds are required, including identifying when calculations are necessary and the time frame in which they are required to be returned. Condition - There was a lack of internal controls in place related to the return of Title IV funds. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - N/A Context - Once return calculations were identified and calculated, there were no controls in place to ensure that the calculations were complete, accurate, or returned in a timely manner. Cause and Effect - A lack of review of the processes to identify students who required a calculation, the completed calculations for accuracy, or ensure that that all calculated returns were completed could lead to incomplete calculations, inaccurate calculations, or untimely return of funds once they are identified. Recommendation - We recommend that the College implement a review control that would cover each stage of the return process outlined. Views of Responsible Officials and Corrective Action Plan - The College will implement controls related to returns of Title IV funds to ensure the related calculations are complete and accurate and that the funds are returned in a timely manner.

Assistance Listing Number, Federal Agency, and Program Name - 84.007, 84.033; U.S. Department of Education; Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Work-Study Program (FWS) Federal Award Identification Number and Year - P007A236053, P033A236053; 2023-2024 Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - In accordance with 2 CFR 200.303, the College must establish and maintain effective internal controls over its federal awards in order to provide reasonable assurance that it is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Specific to these Title IV programs, 34 CFR 675.19(b)(3) (FWS) and 34 CFR 676.19(b)(3) (FSEOG) outline the requirement for institutions to submit a Fiscal Operations Report (FISAP). Condition - There was a lack of internal controls in place related to the review of the FISAP that was submitted by the College in September 2023. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - N/A Context - Once the FISAP was prepared, there was no control in place ensure that the information included in the report was accurate. Cause and Effect - A lack of review of the completed report prior to submission could lead to inaccurate information being reported to the U.S. Department of Education. Recommendation - We recommend that the College implement a level of review of the report prior to submission. Views of Responsible Officials and Planned Corrective Actions - The College will establish the proper controls to ensure that the information included in the FISAP is accurate, including implementing an additional level of review of the report.

Assistance Listing Number, Federal Agency, and Program Name - 84.007, 84.033, 84.063, 84.268; U.S. Department of Education; Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans Federal Award Identification Number and Year - P007A236053, P033A236053, P063P232857, P268K242857; 2023-2024 Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - In accordance with 2 CFR 200.302(b)(6), the College must establish written procedures to implement the requirements of 200.305 (federal payment), which outlines cash management requirements. Condition - As the College does not have a written cash management policy related to federal payments/awards, there was a lack of internal controls in place to ensure that this compliance requirement is met. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - N/A Context - The College does not have a written cash management policy related to federal payments/awards. Cause and Effect - As there is no control established to ensure this written policy is in place, the College is not in compliance with 2 CFR 200.302(b)(6). Recommendation - We recommend that the College establish a written cash management policy related to federal payments/awards and that controls are implemented to ensure that it is updated as necessary. Views of Responsible Officials and Planned Corrective Actions - In accordance with 2 CFR 200.302(b)(6), the College will establish a written cash management policy, including written procedures related to federal payments/awards, in order to implement the requirements of 200.305.

Assistance Listing Number, Federal Agency, and Program Name - 84.425, U.S. Department of Education, Education Stabilization Fund Federal Award Identification Number and Year - P425E203325, 2020; P425F202751, 2020; P425M200930, 2020 Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-001 Criteria - The College must minimize the time elapsed between the transfer of funds from the United States Treasury to the College and the disbursement of those funds, as outlined in 2 CFR Section 200.305(b). Condition - The College drew down the full amount of each award prior to the funds being disbursed to students or used for allowable expenditures, including lost revenue. Questioned Costs - There were no questioned costs identified. Context - In November 2021, the College drew down $5,882,052 for the student aid portion and $5,622,717 for the institutional aid portion. In July 2022, the College drew down $929,887 for the Strengthening Institutions Program (SIP). In each case, the College did not spend the funds within the required time frame following the cash management rules under 2 CFR Section 200.305(b). Cause and Effect - The College was not aware that cash management requirements under the Uniform Guidance applied to these programs, which resulted in an excess of funds drawndown. Recommendation - We recommend the College implement a process to minimize the time elapsed between the transfer of funds from the United States Treasury to the College and the disbursement of those funds. Views of Responsible Officials and Corrective Action Plan - There is no more HEERF or federal stimulus funding to be drawn down moving forward. However, if there is in the future,the College will follow the three-day drawdown rules for cash disbursements.

Assistance Listing Number, Federal Agency, and Program Name - 84.425, U.S. Department of Education, Education Stabilization Fund Federal Award Identification Number and Year - P425E203325, P425F202751 - 2021 Pass-through Entity - N/A Finding Type: Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - The College must minimize the time elapsing between the transfer of funds from the United States Treasury to the University and the disbursement of those funds, as outlined in 2 CFR Section 200.305(b). Condition - The College drew down an estimated amount for student and institutional portion prior to the funds being disbursed to students or used for allowable expenditures. Questioned Costs - There were no questioned costs identified. Identification of How Questioned Costs Were Computed - N/A Context - In November 2021, the College drew down $5,882,052 for the Student Aid portion and $5,622,717 for the Institutional Aid portion, but it did not spend the funds within the required time following cash management rules under 2 CFR Section 200.305(b). Cause and Effect - The College was not aware that cash management requirements under Uniform Guidance applied to these programs, which resulted in an excess of funds drawn down. Recommendation - We recommend the College implement a process to ensure that minimizes the time elapsed between the transfer of funds from the United States Treasury to the College and the disbursement of those funds. Views of Responsible Officials and Corrective Action Plan - The College reviewed its cash management policies and corrected accounting procedures are in effect December 22, 2022. Please note that the College was unaware of this requirement; in that regard, it should be recognized that College financial executives consistently and frequently met with their Ohio community college peers, including Ohio Attorney General Office staff, to understand and interpret the evolution of federal rules and guidelines for these federally designated institutional and student awards.

Assistance Listing Number, Federal Agency, and Program Name - 84.425, U.S. Department of Education, Education Stabalization Fund Federal Award Identification Number and Year - P425E203325 - Various Pass-through Entity - N/A Finding Type: Significant Deficiency Repeat Finding - No Criteria - 2 CFR 200.302(a) indicates that a non-federal entity's financial management system includes records documenting compliance with Federal statutes, regulations must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. 2 CFR 200.303(a) requires non-federal entities to 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. And 2 CFR 200.334 requires that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Condition - The College did not retain underlying support related to the student emergency grants information reported by the College on the annual and quarterly reporting. Questioned Costs - There were no questioned costs identified. Identification of How Questioned Costs Were Computed - N/A Context: The quarterly student reports were posted to the College's website for each quarter in fiscal year 2022 and the annual report covering the period from January 1, 2021 through December 31, 2021 was submitted to the Department of Education. However, the College did not maintain the supporting documents for the information reported. Cause and Effect - The College's processes and controls were not designed effectively in order to ensure appropriate record retention related to reporting completed throughout the year. The failure to establish an effective internal control led to the inabiltiy to provide supporting documentation for key information reported during the year. Recommendation - We recommend the College retains underlying supporting records used to substantiate reporting for the timeframe required by the regulations, as stated above. Views of Responsible Officials and Corrective Action Plan - Support used for reporting will be retained for all future reports moving forward including the fourth quarter 2022 report and the 2022 annual report.

Assistance Listing Number, Federal Agency, and Program Name - 84.425, U.S. Department of Education, Education Stabalization Fund Federal Award Identification Number and Year - P425E203325, Various Pass-through Entity - N/A Finding Type: Significant Deficiency Repeat Finding - No Criteria - Expenditures are required to be reported on the Schedule of Expenditures of Federal Awards (SEFA) according to the basis of accounting followed by the nonfederal entity, per 2 CFR 200.502(a) and in accordance with the cost principles that the program is subject to (2 CFR 200, Subpart E). Condition - The College reported $593,703 of expenditures on the SEFA for disbursements to students that occurred prior to July 1, 2021. This treatment is not in accordance with the accrual basis of accounting following generally accepted accounting principles (GAAP), which is the basis of accounting for the College's SEFA. Questioned Costs - There were no questioned costs identified. Identification of How Questioned Costs Were Computed - Although the expenditures identified were not reported in the appropriate period for the purposes of the SEFA, based on audit procedures performed, they were still within the period of performance for the award. Context - Amounts that were disbursed to students in June 2021 as emergency grants under the Student Portion of the award for summer term were incorrectly not captured on the June 30, 2021 SEFA. These amounts were reported on the June 30, 2022 SEFA. Because they were not captured in the appropriate period, the College concluded to report them on the 2022 SEFA in order to ensure that the expenditures were subject to audit. Cause and Effect - Instead of the College accumulating the total expenditures by disbursement date, management accumulated the total expenditures by academic term. This resulted in a certain expenditures being reported on the SEFA in the incorrect period. Recommendation - We recommend that the College establish controls to ensure appropriate cutoff for SEFA reporting purposes. Views of Responsible Officials and Corrective Action Plan - The College will review its practices for SEFA reporting and in the future follow U.S. GAAP and the uniform guidance.