Westminster CollegeHigher Education

Finding 2025-001: Questioned Costs – Allowable Costs/Costs Principles (material weakness) Statement of Condition: During our testing of expenditures applied to the Economic Adjustment Assistance Program, we identified that the College charged federal funds to a capital project that had previously been paid for with bond proceeds. The bond proceeds were restricted for use on the same project for which federal funds were awarded. Criteria: In accordance with 2 CFR 200.403(a), costs charged to a federal award must be necessary, reasonable, and allocable to the federal program. Additionally, 2 CFR 200.404(a) states that a cost is reasonable if the cost is generally recognized as ordinary and necessary for the recipient’s operation or the proper and efficient performance of the Federal award. Further, 2 CFR 200.405(a) notes that a cost is allocable to a Federal award or other cost objective if the cost is assignable to that Federal award or other cost objective in accordance with the relative benefits received. In addition, the cost must be incurred specifically for the Federal award. 2 CFR 200.406(a) states that applicable credits refer to transactions that offset or reduce direct costs allocable to a federal award. To the extent that such credits are received by the recipient relate to allowable costs, they must be credited to the federal award either as a cost reduction or cash refund, as appropriate. Effect of Condition: Federal funds were used to reimburse costs that had already been paid with bond proceeds, resulting in unallowable costs being charged to the federal program. Cause of Condition: The College did not have adequate controls in place to ensure that costs charged to the federal program had not already been funded by another source. Questioned Costs: The questioned costs total approximately $1,100,000, representing the federal funds used to pay for the capital project already funded by bond proceeds. Recommendation: We recommend that the College implement and enforce procedures to ensure that all costs charged to federal programs comply with the Cost Principles stated in Subpart E of 2 CFR 200.400.

Finding 2025-002: Policies and Procedures Related to Withdrawals (significant deficiency) Statement of Condition: From our testing sample of ten (10) students, we found five (5) instances where changes in student status due to withdrawal were not reported timely. Criteria: In accordance with 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdrawals, any changes to a student’s enrollment status are required to be reported within thirty (30) days, or within sixty (60) days if a roster file is expected within that time frame. Effect of Condition: We found five (5) instances where changes in student status due to withdrawal were not reported timely. Cause of Condition: The College experienced turnover in the Registrar’s Office during the year, which is the responsible party for initiating this reporting. Recommendation: We recommend the College develop policies and procedures to address this issue.

U.S. Department of Treasury Finding 2023-001: Written Procurement Policy (significant deficiency) Statement of Condition: From our testing sample, we noted one instance where the College did not follow its procurement policy. Criteria: Under Title 2, U.S Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR Parts 200.317 through 200.327, the non-federal entity must have and use documented procurement procedures for the acquisition of property or services required under a federal award or subaward. Cause of Condition: The College entered into an agreement with a third-party prior to the College’s policy inception date of August 13, 2022. Effect of Condition: The College is not in compliance with the Uniform Guidance. Recommendation: We recommend the College ensures it follows its written procurement policy to comply with the requirements of the Uniform Guidance. Management's Response: Management agrees and has ensured all purchases as of the policy inception date are compliant with the College’s written procurement policy.

U.S. Department of Education Finding 2021-001: Higher Education Emergency Relief Fund II (HEERF) Reporting (significant deficiency) Statement of Condition: Per the 2021 Compliance Supplement, the College is required to publicly post student and institutional reports for HEERF to their website in a timely manner. The College did not publicly post the reports for HEERF to their website in a timely manner. Criteria: The 2021 Compliance Supplement requires that institutions publicly post the required reports to the institution's website by the tenth day following the end of each calendar quarter, with the exception of the due date for Q1 2021, which was extended to June 30, 2021. Effect of Condition: As the College did not publicly post the reports for HEERF to their website in a timely manner, the College was not in compliance with the HEERF reporting requirements. Cause of Condition: The delays were due to a lack of clarity/uncertainty with the HEERF reporting requirements. Recommendation: We recommend that the College develop and implement procedures to ensure the reports are posted in a timely manner. Management's Response: Management agrees and has publicly posted the required reports for HEERF to their website.