EIN: 446005108
UEI: GWHMFN1JKRX4
Audited by: The Whitlock Company
Oversight agency: 84 [Department of Education]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 3, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by June 3, 2026 (93 days ago).
What is a management decision? →FAC accepted this audit on December 6, 2024 — management decision was due June 6, 2025.
FAC accepted this audit on February 13, 2024 — management decision was due August 13, 2024.
FAC accepted this audit on February 16, 2024 — management decision was due August 16, 2024.
The College does not have documented procurement procedures. Cause: The College has not previously received funds that allowed for institutional spending that would have required documented procurement procedures. Effect: The College used their guiding principles and internal purchasing review policies to guide procurement which does not meet the requirement of 2 CFR 200.318(i) to keep record of the “rationale for the method of procurement.” Questioned Costs: $231,484 . This amount was determined by totaling all the related grant expenditures that required procurement procedures. Criteria: 2 CFR section 200.318 requires that non-federal entities other than states must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. These entities must use their own documented procurement procedures which must reflect applicable state and local laws and regulations as well as the procurement requirements identified in 2 CFR Part 200. Recommendation: Before being awarded additional federal monies available for procurement expenditure, the College should document procurement policies and procedures that meet all compliance requirements in 2 CFR Part 200. Views of responsible personnel and planned corrective actions: The College agrees with this finding while maintaining that the entirety of the questioned costs were for allowable expenditures under HEERF Institutional Aid compliance. Prior to expending federal funds for future procurement expenditures, the College will implement documented procurement procedures. Please refer to corrective action plan on page 13.
Show full finding ▾Hide full finding ▴US Department of Education Education Stabilization Fund Program Name: Higher Education Emergency Relief Fund (HEERF), Institutional Aid Portion Assistance Listing #: 84.425F Finding: 2022 – 001 MATERIAL NONCOMPLIANCE / SIGNIFICANT DEFICIENCY Procurement Condition: The College does not have documented procurement procedures. Cause: The College has not previously received funds that allowed for institutional spending that would have required documented procurement procedures. Effect: The College used their guiding principles and internal purchasing review policies to guide procurement which does not meet the requirement of 2 CFR 200.318(i) to keep record of the “rationale for the method of procurement.” Questioned Costs: $231,484 . This amount was determined by totaling all the related grant expenditures that required procurement procedures. Criteria: 2 CFR section 200.318 requires that non-federal entities other than states must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. These entities must use their own documented procurement procedures which must reflect applicable state and local laws and regulations as well as the procurement requirements identified in 2 CFR Part 200. Recommendation: Before being awarded additional federal monies available for procurement expenditure, the College should document procurement policies and procedures that meet all compliance requirements in 2 CFR Part 200. Views of responsible personnel and planned corrective actions: The College agrees with this finding while maintaining that the entirety of the questioned costs were for allowable expenditures under HEERF Institutional Aid compliance. Prior to expending federal funds for future procurement expenditures, the College will implement documented procurement procedures. Please refer to corrective action plan on page 13.
Planned Corrective Action: We will expand our existing purchasing procedures into a fully documented procurement policy that meets the standards set out in 2 CFR Part 200. Name of Contact Person: Rachel Watson, Business Office Director/Controller, watson.rachel@occ.edu Anticipated completion date: June 30, 2024
The College posted the required quarterly reports to their website more than 10 days after quarter-end. Q3 2021, $0 in emergency financial aid grants awarded; posted 34 days after quarter-end Q4 2021, $0 in emergency financial aid grants awarded; posted 11 days after quarter-end Q1 2022, $0 in emergency financial aid grants awarded; posted 11 days after quarter-end Cause: Personnel less familiar with federal reporting compliance requirements reviewed and completed Higher Education Emergency Relief Fund’s website posting requirements. Effect: Zero change reports were posted to the College’s website after the allowable 10 days after quarter-end. Criteria: Under the May 13, 2021 Notice of Public Posting Requirement of Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees by the Education Department of the Office of Postsecondary Education in the US Department of Education, institutions receiving HEERF funds must promptly and timely post specific information on the institution’s primary website. This information must appear in a format and location that is easily accessible to the public. It must be updated no later than 10 days after the end of each calendar quarter. The Department is exercising this reporting authority under 2 CFR 200.328 and 2 CFR 200.329. Recommendation: The College should implement reporting procedures specific to each federal award and based on those awards specific reporting compliance requirements. Views of responsible personnel and planned corrective actions: The College agrees with this finding. The College will review existing reporting procedures and ensure appropriate adjustments are made for each federal award based on those awards’ specific reporting compliance requirements. Please refer to corrective action plan on page 13.
Show full finding ▾Hide full finding ▴US Department of Education Education Stabilization Fund Program Name: Higher Education Emergency Relief Fund (HEERF), Student Aid Portion Assistance Listing #: 84.425E Finding: 2022 – 002 Reporting Condition: The College posted the required quarterly reports to their website more than 10 days after quarter-end. Q3 2021, $0 in emergency financial aid grants awarded; posted 34 days after quarter-end Q4 2021, $0 in emergency financial aid grants awarded; posted 11 days after quarter-end Q1 2022, $0 in emergency financial aid grants awarded; posted 11 days after quarter-end Cause: Personnel less familiar with federal reporting compliance requirements reviewed and completed Higher Education Emergency Relief Fund’s website posting requirements. Effect: Zero change reports were posted to the College’s website after the allowable 10 days after quarter-end. Criteria: Under the May 13, 2021 Notice of Public Posting Requirement of Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees by the Education Department of the Office of Postsecondary Education in the US Department of Education, institutions receiving HEERF funds must promptly and timely post specific information on the institution’s primary website. This information must appear in a format and location that is easily accessible to the public. It must be updated no later than 10 days after the end of each calendar quarter. The Department is exercising this reporting authority under 2 CFR 200.328 and 2 CFR 200.329. Recommendation: The College should implement reporting procedures specific to each federal award and based on those awards specific reporting compliance requirements. Views of responsible personnel and planned corrective actions: The College agrees with this finding. The College will review existing reporting procedures and ensure appropriate adjustments are made for each federal award based on those awards’ specific reporting compliance requirements. Please refer to corrective action plan on page 13.
Planned Corrective Action: We will review existing reporting procedures and ensure appropriate adjustments are made for any new federal awards’ specific reporting compliance requirements or when any existing federal awards’ specific reporting requirements are updated. Name of Contact Person: Rachel Watson, Business Office Director/Controller, watson.rachel@occ.edu Anticipated completion date: Immediate implementation of corrective action, only applicable when new funds are awarded or existing federal awards’ reporting requirements change.
FAC accepted this audit on October 26, 2022 — management decision was due April 26, 2023.
The College does not have documented procurement procedures. Cause: The College has not previously received funds that allowed for institutional spending that would have required documented procurement procedures. Effect: The College used their guiding principles and internal purchasing review policies to guide procurement which does not meet the requirement of 2 CFR 200.318(i) to keep record of the “rationale for the method of procurement.” Questioned Costs: $231,484 . This amount was determined by totaling all the related grant expenditures that required procurement procedures. Criteria: 2 CFR section 200.318 requires that non-federal entities other than states must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. These entities must use their own documented procurement procedures which must reflect applicable state and local laws and regulations as well as the procurement requirements identified in 2 CFR Part 200. Recommendation: Before being awarded additional federal monies available for procurement expenditure, the College should document procurement policies and procedures that meet all compliance requirements in 2 CFR Part 200. Views of responsible personnel and planned corrective actions: The College agrees with this finding while maintaining that the entirety of the questioned costs were for allowable expenditures under HEERF Institutional Aid compliance. Prior to expending federal funds for future procurement expenditures, the College will implement documented procurement procedures. Please refer to corrective action plan on page 13.
Show full finding ▾Hide full finding ▴US Department of Education Education Stabilization Fund Program Name: Higher Education Emergency Relief Fund (HEERF), Institutional Aid Portion Assistance Listing #: 84.425F Finding: 2022 – 001 MATERIAL NONCOMPLIANCE / SIGNIFICANT DEFICIENCY Procurement Condition: The College does not have documented procurement procedures. Cause: The College has not previously received funds that allowed for institutional spending that would have required documented procurement procedures. Effect: The College used their guiding principles and internal purchasing review policies to guide procurement which does not meet the requirement of 2 CFR 200.318(i) to keep record of the “rationale for the method of procurement.” Questioned Costs: $231,484 . This amount was determined by totaling all the related grant expenditures that required procurement procedures. Criteria: 2 CFR section 200.318 requires that non-federal entities other than states must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. These entities must use their own documented procurement procedures which must reflect applicable state and local laws and regulations as well as the procurement requirements identified in 2 CFR Part 200. Recommendation: Before being awarded additional federal monies available for procurement expenditure, the College should document procurement policies and procedures that meet all compliance requirements in 2 CFR Part 200. Views of responsible personnel and planned corrective actions: The College agrees with this finding while maintaining that the entirety of the questioned costs were for allowable expenditures under HEERF Institutional Aid compliance. Prior to expending federal funds for future procurement expenditures, the College will implement documented procurement procedures. Please refer to corrective action plan on page 13.
Planned Corrective Action: We will expand our existing purchasing procedures into a fully documented procurement policy that meets the standards set out in 2 CFR Part 200. Name of Contact Person: Rachel Watson, Business Office Director/Controller, watson.rachel@occ.edu Anticipated completion date: June 30, 2024
The College posted the required quarterly reports to their website more than 10 days after quarter-end. Q3 2021, $0 in emergency financial aid grants awarded; posted 34 days after quarter-end Q4 2021, $0 in emergency financial aid grants awarded; posted 11 days after quarter-end Q1 2022, $0 in emergency financial aid grants awarded; posted 11 days after quarter-end Cause: Personnel less familiar with federal reporting compliance requirements reviewed and completed Higher Education Emergency Relief Fund’s website posting requirements. Effect: Zero change reports were posted to the College’s website after the allowable 10 days after quarter-end. Criteria: Under the May 13, 2021 Notice of Public Posting Requirement of Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees by the Education Department of the Office of Postsecondary Education in the US Department of Education, institutions receiving HEERF funds must promptly and timely post specific information on the institution’s primary website. This information must appear in a format and location that is easily accessible to the public. It must be updated no later than 10 days after the end of each calendar quarter. The Department is exercising this reporting authority under 2 CFR 200.328 and 2 CFR 200.329. Recommendation: The College should implement reporting procedures specific to each federal award and based on those awards specific reporting compliance requirements. Views of responsible personnel and planned corrective actions: The College agrees with this finding. The College will review existing reporting procedures and ensure appropriate adjustments are made for each federal award based on those awards’ specific reporting compliance requirements. Please refer to corrective action plan on page 13.
Show full finding ▾Hide full finding ▴US Department of Education Education Stabilization Fund Program Name: Higher Education Emergency Relief Fund (HEERF), Student Aid Portion Assistance Listing #: 84.425E Finding: 2022 – 002 Reporting Condition: The College posted the required quarterly reports to their website more than 10 days after quarter-end. Q3 2021, $0 in emergency financial aid grants awarded; posted 34 days after quarter-end Q4 2021, $0 in emergency financial aid grants awarded; posted 11 days after quarter-end Q1 2022, $0 in emergency financial aid grants awarded; posted 11 days after quarter-end Cause: Personnel less familiar with federal reporting compliance requirements reviewed and completed Higher Education Emergency Relief Fund’s website posting requirements. Effect: Zero change reports were posted to the College’s website after the allowable 10 days after quarter-end. Criteria: Under the May 13, 2021 Notice of Public Posting Requirement of Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees by the Education Department of the Office of Postsecondary Education in the US Department of Education, institutions receiving HEERF funds must promptly and timely post specific information on the institution’s primary website. This information must appear in a format and location that is easily accessible to the public. It must be updated no later than 10 days after the end of each calendar quarter. The Department is exercising this reporting authority under 2 CFR 200.328 and 2 CFR 200.329. Recommendation: The College should implement reporting procedures specific to each federal award and based on those awards specific reporting compliance requirements. Views of responsible personnel and planned corrective actions: The College agrees with this finding. The College will review existing reporting procedures and ensure appropriate adjustments are made for each federal award based on those awards’ specific reporting compliance requirements. Please refer to corrective action plan on page 13.
Planned Corrective Action: We will review existing reporting procedures and ensure appropriate adjustments are made for any new federal awards’ specific reporting compliance requirements or when any existing federal awards’ specific reporting requirements are updated. Name of Contact Person: Rachel Watson, Business Office Director/Controller, watson.rachel@occ.edu Anticipated completion date: Immediate implementation of corrective action, only applicable when new funds are awarded or existing federal awards’ reporting requirements change.
FAC accepted this audit on October 31, 2021 — management decision was due May 1, 2022.
FAC accepted this audit on November 4, 2020 — management decision was due May 4, 2021.
FAC accepted this audit on November 17, 2019 — management decision was due May 17, 2020.
FAC accepted this audit on October 21, 2018 — management decision was due April 21, 2019.
FAC accepted this audit on November 30, 2017 — management decision was due May 30, 2018.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on November 6, 2016 — management decision was due May 6, 2017.
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