EIN: 466002586
UEI: MZALJJHTAB63
Audited by: EIDE BAILLY LLP
Cognizant agency: 84 [Department of Education]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 30, 2026. 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 September 30, 2026 (29 days from today).
What is a management decision? →During testing over credit balances, one student did not receive the refund on a timely basis. Cause: The student was awarded aid at an off time in the semester, and the refund was not provided within the 14-day window. Effect: The students were not given the refund in a timely manner. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 60 students who received Title IV disbursements out of 1,903 students who received aid. Repeat Finding from Prior Year(s): Yes. Recommendation: We recommend disbursements made be reviewed to ensure that the refunds are being provided to students on a timely basis. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2025-002 Department of Education Student Financial Aid Cluster Federal Financial Assistance Listing 84.268 – Federal Direct Student Loans, 84.063 - Federal Pell Grant Program, 84.007 – FSEOG Program 2024-2025 Award Year Special Tests and Provision – Disbursements to or on Behalf of Students Significant Deficiency in Internal Controls over Compliance Criteria: When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, food and housing, and other authorized charges assessed the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. Also, as allowed under 34 CFR 668.164(c)(3), a school may pay prior award year charges up to $200. If over $200, student authorization is required to apply the payments to a prior-year balance. Condition: During testing over credit balances, one student did not receive the refund on a timely basis. Cause: The student was awarded aid at an off time in the semester, and the refund was not provided within the 14-day window. Effect: The students were not given the refund in a timely manner. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 60 students who received Title IV disbursements out of 1,903 students who received aid. Repeat Finding from Prior Year(s): Yes. Recommendation: We recommend disbursements made be reviewed to ensure that the refunds are being provided to students on a timely basis. Views of Responsible Officials: Management agrees with the finding.
Identifying Number: 2025-002: U.S. Department of Education: Federal Direct Student Loans – 84.268; Federal Pell Grant Program – 84.007 Finding: During testing over credit balances, it was noted that one student did not receive the refund on a timely basis. Corrective Action Taken or Planned: All scheduled disbursements will be reviewed to ensure they are provided on a timely basis and are applied correctly to prior award years. Business Office procedures and processing will be reviewed to ensure that credit balances are processed within the regulatory timeframe. New staff have been trained to monitor dates for compliance and have implemented checks with the Financial Aid Office. Contact person: Micah Hansen, Director of Financial Aid and Christine Goldsmith, Vice President - Finance Status of finding – The above corrective actions will be implemented beginning January 1, 2026.
2024-006
We identified through our testing over enrollment reporting one instance of a student’s program begin date incorrectly reported to NSLDS. Cause: An error in entry of the date was made in the system which is used to report to NSLDS, so the date was incorrectly reported. Effect: The error in reporting resulted in incorrect program start date for the student. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 60 students with a change in status out of approximately 820 students with a change in status were selected for testing of enrollment reporting requirements. Repeat Finding from Prior Year(s): Yes. Recommendation: We recommend the financial aid and registrar’s offices review controls over information being entered into the software for dates and other academic information that is required to be reported to ensure that status changes and other academic information are certified within 60 days of the effective date. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2025-003 Department of Education Student Financial Aid Cluster Federal Financial Assistance Listing 84.268 – Federal Direct Student Loans 2024-2025 Award Year Special Tests and Provision – NSLDS Reporting Significant Deficiency in Internal Controls over Compliance Criteria: 34 CFR section 685.309 sets forth the criteria for administrative and fiscal control and fund accounting requirements for schools participating in the Direct Loan Program in regard to enrollment reporting requirements. Condition: We identified through our testing over enrollment reporting one instance of a student’s program begin date incorrectly reported to NSLDS. Cause: An error in entry of the date was made in the system which is used to report to NSLDS, so the date was incorrectly reported. Effect: The error in reporting resulted in incorrect program start date for the student. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 60 students with a change in status out of approximately 820 students with a change in status were selected for testing of enrollment reporting requirements. Repeat Finding from Prior Year(s): Yes. Recommendation: We recommend the financial aid and registrar’s offices review controls over information being entered into the software for dates and other academic information that is required to be reported to ensure that status changes and other academic information are certified within 60 days of the effective date. Views of Responsible Officials: Management agrees with the finding.
Identifying Number: 2025-003: U.S. Department of Education: Federal Direct Student Loans – 84.268 Finding: During testing over enrollment reporting, one instance was identified where a student’s program begin date was incorrectly reported to NDSLDS. Corrective Action Taken or Planned: There were several instances of dates submitted through the National Student Clearinghouse to NSLDS where dates were not aligning to submissions. In all but one case, those dates were confirmed to be matching the NSC submission and were not found to be erroneous. The one date is suspected to be due to a program change and those students with changes will be monitored by the Registrar and the Financial Aid Office. Contact person: Micah Hansen, Director of Financial Aid Status of finding – The above corrective actions will be implemented beginning January 1, 2026.
2024-007
FAC accepted this audit on March 27, 2025 — management decision was due September 27, 2025.
Two errors were noted related to period of performance: 1) the lost revenue calculation was completed in October 2023, which was after the June 30, 2023, period of performance date; and 2) the School District also spent money on expenses for the program in November 2023 and January 2024, which was after the 120-day liquidation period. Cause: The School did not apply for a no cost extension to be able to obligate the funding after June 30, 2023. For error #1, the School District was waiting to claim lost revenue until all expenses under the program were incurred to be able to use any remaining funding available. For error #2, the School District believed that the purchase orders that were outstanding after the 120-day liquidation period would be allowed to be paid when items purchased were received. Effect: The School received grant funding on allowable costs which were paid for or obligated after the period of performance and liquidation period ended. Questioned Costs: $539,358 specific to lost revenue and $179,409 for expenses paid for in November 2023 and January 2024. Context/Sampling: All lost revenue calculation reports were tested. We tested 40 out of 410 total expenses from the program for other expenses. Total questioned costs for expenses was obtained from general ledger detail for expenses paid after October 26, 2023. Repeat Finding from Prior Year(s): No Recommendation: We recommend a tracking schedule monitored by multiple people be maintained with all required spending deadlines to ensure that funding is spent in the required timeframe. We also recommend review of the grant agreements and grant funding information to ensure that knowledge of the requirements is known by multiple people to ensure requirements are met. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Education Education Stabilization Fund: Higher Education Emergency Relief Find (HEERF) Federal Financial Assistance Listing 84.425F Institutional Portion Award Number P425F202657, Award Years 2020 and 2021 Period of Performance Material Weakness in Internal Controls over Compliance and Material Non-Compliance Criteria: In the CRRSSA and ARP Certification and Agreement, all institutions were given one calendar year from the date of the Grant Award Notification to complete period of performance which was subsequently extended to June 30, 2023. Department of Education provided guidance in Frequently Asked Questions #51 specific to period of performance noting, “institutions now have 120 calendar days to liquidate all financial obligations incurred under the award after the period of performance.” The 2024 compliance supplement also notes specific to lost revenue, “For lost revenue, the obligation occurs on the date the institution completes its estimate of its amount of lost revenue after the estimation period.” Condition: Two errors were noted related to period of performance: 1) the lost revenue calculation was completed in October 2023, which was after the June 30, 2023, period of performance date; and 2) the School District also spent money on expenses for the program in November 2023 and January 2024, which was after the 120-day liquidation period. Cause: The School did not apply for a no cost extension to be able to obligate the funding after June 30, 2023. For error #1, the School District was waiting to claim lost revenue until all expenses under the program were incurred to be able to use any remaining funding available. For error #2, the School District believed that the purchase orders that were outstanding after the 120-day liquidation period would be allowed to be paid when items purchased were received. Effect: The School received grant funding on allowable costs which were paid for or obligated after the period of performance and liquidation period ended. Questioned Costs: $539,358 specific to lost revenue and $179,409 for expenses paid for in November 2023 and January 2024. Context/Sampling: All lost revenue calculation reports were tested. We tested 40 out of 410 total expenses from the program for other expenses. Total questioned costs for expenses was obtained from general ledger detail for expenses paid after October 26, 2023. Repeat Finding from Prior Year(s): No Recommendation: We recommend a tracking schedule monitored by multiple people be maintained with all required spending deadlines to ensure that funding is spent in the required timeframe. We also recommend review of the grant agreements and grant funding information to ensure that knowledge of the requirements is known by multiple people to ensure requirements are met. Views of Responsible Officials: Management agrees with the finding.
– 84.425F Finding: Two errors were noted related to period of performance: 1) the lost revenue calculation was completed in October 2023, which was after the June 30, 2023 period of performance date; and 2) the District also spent money on expenses for the program in November 2023 and January 2024, which was after the 120-day liquidation period. Corrective Action Taken or Planned: The School will create and maintain a funding schedule according to the grant agreements. The schedule will be reviewed by various finance staff members for timing of grant reimbursements and deadlines. Contact person: Mike Stephens, Director of Accounting Status of finding – The above corrective actions will be implemented beginning April 1, 2025.
During testing over the requirements, we noted that, in 28 of 40 expenses tested, reimbursement was received for expenses for items that were never purchased. The total for these 28 items was $10,682. Additional review noted a total of $132,071 for total funding received but not spent. Cause: The School District used outstanding purchase obligations to request reimbursement at the end of the liquidation period, but did not spend all of the money. Effect: The School received reimbursement for items that were never purchased. Questioned Costs: $132,071 Context/Sampling: A nonstatistical sample of 60 expenses submitted for reimbursement out of 410 total expenses. Repeat Finding from Prior Year(s): No. Recommendation: We recommend a review be completed to ensure that all reimbursements have proper expenses to back up the request submitted. We also recommend that, if new funding is received, a committee be set up by the School District to be able to review expenses and ensure that funding is spent on proper items and requests for reimbursement are only made once expenses have been paid. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2024-003 Department of Education Education Stabilization Fund: Higher Education Emergency Relief Find (HEERF) Federal Financial Assistance Listing 84.425F Institutional Portion Award Number P425F202657, Award Years 2020 and 2021 Activities Allowed or Unallowed and Allowable Costs/Cost Principles Material Weakness in Internal Controls over Compliance and Material Non-Compliance Criteria: The CARES Act, CRRSSA and the American Rescue Plan Act (ARP) sets forth the criteria for allowable costs and activities. Condition: During testing over the requirements, we noted that, in 28 of 40 expenses tested, reimbursement was received for expenses for items that were never purchased. The total for these 28 items was $10,682. Additional review noted a total of $132,071 for total funding received but not spent. Cause: The School District used outstanding purchase obligations to request reimbursement at the end of the liquidation period, but did not spend all of the money. Effect: The School received reimbursement for items that were never purchased. Questioned Costs: $132,071 Context/Sampling: A nonstatistical sample of 60 expenses submitted for reimbursement out of 410 total expenses. Repeat Finding from Prior Year(s): No. Recommendation: We recommend a review be completed to ensure that all reimbursements have proper expenses to back up the request submitted. We also recommend that, if new funding is received, a committee be set up by the School District to be able to review expenses and ensure that funding is spent on proper items and requests for reimbursement are only made once expenses have been paid. Views of Responsible Officials: Management agrees with the finding.
Identifying Number: 2024-003: U.S. Department of Education: Education Stabilization Fund: Institutional Portion – 84.425F Finding: The District used outstanding purchase order obligations to request reimbursement at the end of the liquidation period, but did not spend all of the outstanding purchase orders; therefore, receiving reimbursement for items that were never purchased. Corrective Action Taken or Planned: The School will designate finance staff to review reimbursements to ensure they have proper expenses as backup. A further review by the School District will help to ensure that funding is spent on items and requests for reimbursement only after expenses have been paid. Contact person: Mike Stephen, Director of Accounting Status of finding – The above corrective actions will be implemented beginning April 1, 2025.
During testing over the requirement, it was noted that the amount drawn on October 25, 2023, was not spent until November 2023, January 2024, or was never spent. Cause: The School District was at the end of the 120-day liquidation period of performance so drew all remaining available funding based on open purchase orders. Effect: The School District received, but did not disburse, the funds within the allowed three-day timeframe. Questioned Costs: $311,480 Context/Sampling: A nonstatistical sample of two draw requests out of five total draw requests were tested. Of the $311,480 received, $179,409 was spent in November 2023 and April 2024 (also reported under period of performance) and $132,071 was never spent (also reported under allowable costs). Repeat Finding from Prior Year(s): No. Recommendation: We recommend that reimbursement requests be submitted at the time of or after payments for the expenses are made to ensure that timing of the reimbursement is received at the same time or after payments are made. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2024-004 Department of Education Education Stabilization Fund: Higher Education Emergency Relief Find (HEERF) Federal Financial Assistance Listing 84.425F Institutional Portion Award Number P425F202657, Award Years 2020 and 2021 Cash Management Material Weakness in Internal Controls over Compliance and Material Non-Compliance Criteria: For CRRSSA HEERF II and ARP HEERF III, the certification and agreements indicate the institutional aid portion of funding should be disbursed within three calendar days from the drawdown from G5. Condition: During testing over the requirement, it was noted that the amount drawn on October 25, 2023, was not spent until November 2023, January 2024, or was never spent. Cause: The School District was at the end of the 120-day liquidation period of performance so drew all remaining available funding based on open purchase orders. Effect: The School District received, but did not disburse, the funds within the allowed three-day timeframe. Questioned Costs: $311,480 Context/Sampling: A nonstatistical sample of two draw requests out of five total draw requests were tested. Of the $311,480 received, $179,409 was spent in November 2023 and April 2024 (also reported under period of performance) and $132,071 was never spent (also reported under allowable costs). Repeat Finding from Prior Year(s): No. Recommendation: We recommend that reimbursement requests be submitted at the time of or after payments for the expenses are made to ensure that timing of the reimbursement is received at the same time or after payments are made. Views of Responsible Officials: Management agrees with the finding.
Identifying Number: 2024-004: U.S. Department of Education: Education Stabilization Fund: Institutional Portion – 84.425F Finding: Due to receiving reimbursement on outstanding purchase orders that were paid months later, or not at all, the District received, but did not disburse, the funds within the allowed three-day timeframe. Corrective Action Taken or Planned: Reimbursement requests will be submitted on a timely basis and after payments for the expenses are made. This will help ensure that reimbursement is received at the same time or after payment has been made. Contact person: Mike Stephens, Director of Accounting Status of finding – The above corrective actions will be implemented beginning April 1, 2025.
There was no review of quarterly or annual HEERF reports prior to their submission. Cause: Inadequate controls implemented to ensure compliance with HEERF reporting requirements. Effect: Reports could be submitted with incorrect information. Questioned Costs: None. Context/Sampling: The one required quarterly report for the September 2023 quarter was tested and the annual report for calendar year 2024 was tested. Repeat Finding from Prior Year(s): Yes. Recommendation: We recommend there is a separate, documented reviewer of the reports prior to their submission. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2024-005 Department of Education Education Stabilization Fund: Higher Education Emergency Relief Find (HEERF) Federal Financial Assistance Listing 84.425F Institutional Portion Award Number P425F202657, Award Years 2020 and 2021 Reporting Significant Deficiency in Internal Controls over Compliance Criteria: CRRSSA section 314 (e) and CARES Act 18004 (e) sets forth the criteria for reporting requirements. Condition: There was no review of quarterly or annual HEERF reports prior to their submission. Cause: Inadequate controls implemented to ensure compliance with HEERF reporting requirements. Effect: Reports could be submitted with incorrect information. Questioned Costs: None. Context/Sampling: The one required quarterly report for the September 2023 quarter was tested and the annual report for calendar year 2024 was tested. Repeat Finding from Prior Year(s): Yes. Recommendation: We recommend there is a separate, documented reviewer of the reports prior to their submission. Views of Responsible Officials: Management agrees with the finding.
Identifying Number: 2024-005: U.S. Department of Education: Education Stabilization Fund: Institutional Portion – 84.425F Finding: There was no review of quarterly or annual HEERF reports prior to their submission. Corrective Action Taken or Planned: The School will train finance office staff in preparation and filing of grant reports. This will allow various staff members to review reports prior to submission. Contact person: Mike Stephens, Director of Accounting Status of finding – The above corrective actions will be implemented beginning April 1, 2025.
2023-002
During testing over credit balances, 1) one student did not receive the refund on a timely basis; and 2) two students had amounts applied to a prior-year balance over $200. Cause: The student was awarded aid at an off time in the semester, and the refund was not provided within the 14-day window. Also, turnover in staffing in the fall 2023 allowed disbursements to be applied to students prioryear accounts receivable balances relating to tuition and fees or other charges. Effect: The students were not given the refund in a timely manner or given the proper refund related to the current award period. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 61 students who received Title IV disbursements out of 1,491 students who received aid. Repeat Finding from Prior Year(s): No. Recommendation: We recommend disbursements made be reviewed to ensure that the refunds are being provided to students on a timely basis. We also recommend controls be put into place to ensure that, if a student has a balance over $200 from a prior award year, those accounts are reviewed to ensure that currentyear aid is not applied to prior-year balances. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2024-006 Department of Education Student Financial Aid Cluster Federal Financial Assistance Listing 84.268 – Federal Direct Student Loans 2023-2024 Award Year Special Tests and Provision – Disbursements to or on Behalf of Students Significant Deficiency in Internal Controls over Compliance and Noncompliance Criteria: When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, food and housing, and other authorized charges assessed the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. Also, as allowed under 34 CFR 668.164(c)(3), a school may pay prior award year charges up to $200. If over $200, student authorization is required to apply the payments to a prior-year balance. Condition: During testing over credit balances, 1) one student did not receive the refund on a timely basis; and 2) two students had amounts applied to a prior-year balance over $200. Cause: The student was awarded aid at an off time in the semester, and the refund was not provided within the 14-day window. Also, turnover in staffing in the fall 2023 allowed disbursements to be applied to students prioryear accounts receivable balances relating to tuition and fees or other charges. Effect: The students were not given the refund in a timely manner or given the proper refund related to the current award period. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 61 students who received Title IV disbursements out of 1,491 students who received aid. Repeat Finding from Prior Year(s): No. Recommendation: We recommend disbursements made be reviewed to ensure that the refunds are being provided to students on a timely basis. We also recommend controls be put into place to ensure that, if a student has a balance over $200 from a prior award year, those accounts are reviewed to ensure that currentyear aid is not applied to prior-year balances. Views of Responsible Officials: Management agrees with the finding.
Identifying Number: 2024-006: U.S. Department of Education: Federal Direct Student Loans – 84.268 Finding: During testing over credit balances, it was noted that: 1) one student did not receive the refund on a timely basis; and 2) two students had amounts applied to a prior-year balance over $200. Corrective Action Taken or Planned: All scheduled disbursements will be reviewed to ensure they are provided on a timely basis and are applied correctly to prior award years. Business Office procedures and processing will be reviewed to ensure that credit balances are processed within the regulatory timeframe. Contact person: Megan Fischer, Vice President for Enrollment Management Status of finding – The above corrective actions will be implemented beginning April 1, 2025.
The following instances were identified through our testing over enrollment reporting: • 16 instances in which the student’s status change was certified outside the 60-day reporting requirement. Cause: For the students with certification dates outside of the required 60-day timeframe, information files were not provided timely to the third-party provider to submit to NSLDS for reporting. The late reporting was specific to the July 2023 and December 2023 graduation dates. Effect: The errors in reporting resulted in reporting dates outside of the required reporting timeframe which could impact the timing of required loan payments to be made. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 60 students with a change in status out of approximately 693 students with a change in status were selected for testing of enrollment reporting requirements. Repeat Finding from Prior Year(s): Yes. Recommendation: We recommend the financial aid and registrar’s offices review controls over information being entered into the software for dates and other academic information that is required to be reported to ensure that status changes and other academic information are certified within 60 days of the effective date. We also recommend that a monitoring system be put in place to track status changes and reporting of those status changes that can be monitored by financial aid or the registrar’s offices. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2024-007 Department of Education Student Financial Aid Cluster Federal Financial Assistance Listing 84.268 – Federal Direct Student Loans 2023-2024 Award Year Special Tests and Provision – Enrollment Reporting Significant Deficiency in Internal Controls over Compliance and Non-Compliance Criteria: 34 CFR section 685.309 sets forth the criteria for administrative and fiscal control and fund accounting requirements for schools participating in the Direct Loan Program in regard to enrollment reporting requirements. Condition: The following instances were identified through our testing over enrollment reporting: • 16 instances in which the student’s status change was certified outside the 60-day reporting requirement. Cause: For the students with certification dates outside of the required 60-day timeframe, information files were not provided timely to the third-party provider to submit to NSLDS for reporting. The late reporting was specific to the July 2023 and December 2023 graduation dates. Effect: The errors in reporting resulted in reporting dates outside of the required reporting timeframe which could impact the timing of required loan payments to be made. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 60 students with a change in status out of approximately 693 students with a change in status were selected for testing of enrollment reporting requirements. Repeat Finding from Prior Year(s): Yes. Recommendation: We recommend the financial aid and registrar’s offices review controls over information being entered into the software for dates and other academic information that is required to be reported to ensure that status changes and other academic information are certified within 60 days of the effective date. We also recommend that a monitoring system be put in place to track status changes and reporting of those status changes that can be monitored by financial aid or the registrar’s offices. Views of Responsible Officials: Management agrees with the finding.
Identifying Number: 2024-007: U.S. Department of Education: Federal Direct Student Loans – 84.268 Finding: During testing of enrollment reporting, it was noted that there were 16 instances in which the student’s status change was certified outside the 60-day reporting requirement. Corrective Action Taken or Planned: We learned that the current process for the submission to the National Student Clearinghouse is not pulling all students that it should be. We are now pulling additional reports to identify those students being missed and are manually reporting them to the Clearinghouse. Contact person: Megan Fischer, Vice President for Enrollment Management Status of finding – The above corrective actions will be implemented beginning January 1, 2025.
2023-005
FAC accepted this audit on April 1, 2024 — management decision was due October 1, 2024.
Three of the four required quarterly reports were not uploaded to the School District’s website timely. The quarterly reports were required to be uploaded to the website 10 days after quarter end and all quarterly reports were posted on June 28, 2023. Furthermore, there was no review of quarterly or annual HEERF reports prior to their submission. Cause: Inadequate controls implemented to ensure compliance with HEERF reporting requirements. Effect: The errors in reporting resulted in reporting dates outside of the required reporting timeframe. Questioned Costs: None. Context/Sampling: All quarterly reports that were required to be completed were tested. Repeat Finding from Prior Year(s): Yes, Finding 2022-002. Recommendation: We recommend that a tracking schedule is made by Southeast Technical College which is monitored to ensure the requirements, including deadlines, for reporting are met in the timeframe allowed under the grant agreements, and that there is a separate documented reviewer of the reports prior to their submission. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2023-002 Department of Education Education Stabilization Fund: Higher Education Emergency Relief Find (HEERF) Federal Financial Assistance Listing 84.425F Institutional Portion Award Number P425F202657, Award Years 2020 and 2021 Reporting Material Weakness in Internal Controls over Compliance and Non-Compliance Criteria: CRRSSA section 314 (e) and CARES Act 18004 (e) sets forth the criteria for reporting requirements. Condition: Three of the four required quarterly reports were not uploaded to the School District’s website timely. The quarterly reports were required to be uploaded to the website 10 days after quarter end and all quarterly reports were posted on June 28, 2023. Furthermore, there was no review of quarterly or annual HEERF reports prior to their submission. Cause: Inadequate controls implemented to ensure compliance with HEERF reporting requirements. Effect: The errors in reporting resulted in reporting dates outside of the required reporting timeframe. Questioned Costs: None. Context/Sampling: All quarterly reports that were required to be completed were tested. Repeat Finding from Prior Year(s): Yes, Finding 2022-002. Recommendation: We recommend that a tracking schedule is made by Southeast Technical College which is monitored to ensure the requirements, including deadlines, for reporting are met in the timeframe allowed under the grant agreements, and that there is a separate documented reviewer of the reports prior to their submission. Views of Responsible Officials: Management agrees with the finding.
Identifying Number: 2023-002: U.S. Department of Education: Education Stabilization Fund: Student Aid Portion – 84.425E; Institutional Portion – 84.425F Finding: Three of the four required quarterly reports were not posted to the District’s website in a timely manner. In addition, there was no review of quarterly or annual HEERF reports prior to their submission. Corrective Action Taken or Planned: STC will implement a master calendar that will establish and publish deadlines for reporting requirements prior to their respective submission dates. Additionally, STC will explore training staff and delegating responsibility for report preparation to other Finance and Operation positions to allow the Vice President – Finance and Operations to provide oversight and guidance in report preparation and to review reports prior to submission. Contact person: Rich Kluin, Vice President – Finance and Operations, Southeast Technical College Status of finding – The above corrective actions will be implemented beginning July 1, 2024.
2022-002
During testing over the eligibility requirements, the following deficiency was noted: • 1 student of 61 students tested was not awarded the correct amount of subsidized loan and unsubsidized loan. Cause: The School District did not factor in the Build Dakota Scholarship in the assistance calculation to determine the amount of loans the student was eligible for. Effect: Student was overawarded the amount of aid they were eligible for. Questioned Costs: Direct Subsidized Loans: $2,233 over-awarded; Direct Unsubsidized Loans: $1,980 overawarded. Context/Sampling: A nonstatistical sample of 61 students who received Title IV disbursements out of 1,496 students who received aid. The total aid tested in sample was Direct Loans of $255,578. Repeat Finding from Prior Year(s): No. Recommendation: We recommend a review be completed when students are eligible for the Build Dakota Scholarship to determine if the student will be eligible for need and non-need based assistance. Views of Responsible Officials: Management agrees with the finding. Build Dakota funding is processed outside of the Financial Aid Office and over-award was missed in timing of loan awarding. Estimated funds will be added to and monitored in the PowerFAIDS system for additional compliance monitoring.
Show full finding ▾Hide full finding ▴2023-003 Department of Education Student Financial Aid Cluster CFDA # 84.268 – Federal Direct Student Loans 2022-2023 Award Year Eligibility – Calculation of the Amount of Subsidized and Unsubsidized Direct Loan Assistance Awarded Significant Deficiency in Internal Controls over Compliance and Noncompliance Criteria: 34 CFR section 685 provides the applicable criteria and guidance on awards under the Federal Direct Student Loans Program. Condition: During testing over the eligibility requirements, the following deficiency was noted: • 1 student of 61 students tested was not awarded the correct amount of subsidized loan and unsubsidized loan. Cause: The School District did not factor in the Build Dakota Scholarship in the assistance calculation to determine the amount of loans the student was eligible for. Effect: Student was overawarded the amount of aid they were eligible for. Questioned Costs: Direct Subsidized Loans: $2,233 over-awarded; Direct Unsubsidized Loans: $1,980 overawarded. Context/Sampling: A nonstatistical sample of 61 students who received Title IV disbursements out of 1,496 students who received aid. The total aid tested in sample was Direct Loans of $255,578. Repeat Finding from Prior Year(s): No. Recommendation: We recommend a review be completed when students are eligible for the Build Dakota Scholarship to determine if the student will be eligible for need and non-need based assistance. Views of Responsible Officials: Management agrees with the finding. Build Dakota funding is processed outside of the Financial Aid Office and over-award was missed in timing of loan awarding. Estimated funds will be added to and monitored in the PowerFAIDS system for additional compliance monitoring.
Identifying Number: 2023-003: U.S. Department of Education: Student Financial Aid Cluster – 84.268, Federal Direct Student Loans Finding: For one student out of 61 students tested, an incorrect amount of subsidized and unsubsidized loan was awarded. Corrective Action Taken or Planned: STC Financial Aid Office will request a list of Build Dakota students and estimated scholarship amounts at the beginning of the academic year. This information will be added into the student’s financial aid packaging formula to review for potential changes needed in federal aid awards. Once the Business Office has completed applying Build Dakota funds for the term, the information will be shared with the Financial Aid Office to make adjustments to the original estimates used. Contact person: Micah Hansen, Director of Financial Aid, Southeast Technical College Status of finding – The above corrective actions will be implemented beginning July 1, 2024.
During testing over disbursement notifications, one student did not receive the notification on a timely basis. Cause: The student was awarded aid at an off time in the semester, and the notification was not provided until the beginning of the semester. Effect: The student was not given the proper notification to decline the award they were receiving. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 61 students who received Title IV disbursements out of 1,496 students who received aid. Repeat Finding from Prior Year(s): No. Recommendation: We recommend disbursements made be reviewed to ensure that the notifications are being provided to students on a timely basis to let the student determine if they want to decline or amend the award. Views of Responsible Officials: Management agrees with the finding. The Financial Aid Office uses system automation for compliance with notification to students. Additional match of record numbers to notification numbers has been added.
Show full finding ▾Hide full finding ▴2023-004 Department of Education Student Financial Aid Cluster CFDA # 84.268 – Federal Direct Student Loans 2022-2023 Award Year Special Tests and Provision – Disbursements to or on Behalf of Students Significant Deficiency in Internal Controls over Compliance and Noncompliance Criteria: 34 CFR section 668.165 (a) (1) provides the applicable criteria and guidance the School District must comply with to notify students of the amount and type of Title IV funds they are expected to receive, and how and when those disbursements will be made. . Condition: During testing over disbursement notifications, one student did not receive the notification on a timely basis. Cause: The student was awarded aid at an off time in the semester, and the notification was not provided until the beginning of the semester. Effect: The student was not given the proper notification to decline the award they were receiving. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 61 students who received Title IV disbursements out of 1,496 students who received aid. Repeat Finding from Prior Year(s): No. Recommendation: We recommend disbursements made be reviewed to ensure that the notifications are being provided to students on a timely basis to let the student determine if they want to decline or amend the award. Views of Responsible Officials: Management agrees with the finding. The Financial Aid Office uses system automation for compliance with notification to students. Additional match of record numbers to notification numbers has been added.
Identifying Number: 2023-004: U.S. Department of Education: Student Financial Aid Cluster – 84.268, Federal Direct Student Loans Finding: During testing of disbursement notifications, one student did not receive the notification in a timely manner. Corrective Action Taken or Planned: STC Financial Aid Office will continue to monitor disbursements and work to create a report of notifications sent or errors so that notifications are not missed. Contact person: Micah Hansen, Director of Financial Aid, Southeast Technical College Status of finding – The above corrective actions will be implemented beginning July 1, 2024.
The following instances were identified through our testing over enrollment reporting; • 7 instances in which student’s status change was certified outside the 60-day reporting requirement. • 7 instances in which student’s status change was not reported within 60 days to National Student Loan Data System (NSLDS) nor included in reporting National Student Clearinghouse (NSC). • 2 instances in which student’s program start date reported in NSLDS did not agree with student records. Cause: For the students with certification dates outside of the required 60-day timeframe, information files were not provided timely to the third-party provider to submit to NSLDS for reporting. Errors and failure to report information was caused by entry errors by the various departments. Effect: The errors in reporting resulted in reporting dates outside of the required reporting timeframe or other information to be reported incorrectly. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 60 students with a change in status out of approximately 933 students with a change in status were selected for testing of enrollment reporting requirements. Repeat Finding from Prior Year(s): No. Recommendation: We recommend the financial aid and registrar’s offices review controls over information being entered into the software for dates and other academic information that is required to be reported to ensure that status changes and other academic information are certified within 60 days of the effective date. We also recommend that a monitoring system be put in place to track status changes and reporting of those status changes that can be monitored by financial aid or the registrar’s offices. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2023-005 Department of Education Student Financial Aid Cluster CFDA # 84.268 – Federal Direct Student Loans 2022-2023 Award Year Special Tests and Provision – Enrollment Reporting Material Weakness in Internal Controls over Compliance and Non-Compliance Criteria: 34 CFR section 685.309 sets forth the criteria for administrative and fiscal control and fund accounting requirements for schools participating in the Direct Loan Program in regard to enrollment reporting requirements . Condition: The following instances were identified through our testing over enrollment reporting; • 7 instances in which student’s status change was certified outside the 60-day reporting requirement. • 7 instances in which student’s status change was not reported within 60 days to National Student Loan Data System (NSLDS) nor included in reporting National Student Clearinghouse (NSC). • 2 instances in which student’s program start date reported in NSLDS did not agree with student records. Cause: For the students with certification dates outside of the required 60-day timeframe, information files were not provided timely to the third-party provider to submit to NSLDS for reporting. Errors and failure to report information was caused by entry errors by the various departments. Effect: The errors in reporting resulted in reporting dates outside of the required reporting timeframe or other information to be reported incorrectly. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 60 students with a change in status out of approximately 933 students with a change in status were selected for testing of enrollment reporting requirements. Repeat Finding from Prior Year(s): No. Recommendation: We recommend the financial aid and registrar’s offices review controls over information being entered into the software for dates and other academic information that is required to be reported to ensure that status changes and other academic information are certified within 60 days of the effective date. We also recommend that a monitoring system be put in place to track status changes and reporting of those status changes that can be monitored by financial aid or the registrar’s offices. Views of Responsible Officials: Management agrees with the finding.
Identifying Number: 2023-005: U.S. Department of Education: Student Financial Aid Cluster – 84.268, Federal Direct Student Loans Finding: The following instances were identified during testing of enrollment reporting: 7 instances in which a student’s status change was certified outside the 60-day reporting requirement, 7 instances in which a student’s status change was not reported within 60 days to the National Student Loan Data System (NSLDS) nor included in reporting to the National Student Clearinghouse (NSC), and 2 instances in which a student’s program start date reported in NSLDS did not agree with student records. Corrective Action Taken or Planned: The STC Financial Aid Office and Registrar will work to develop a process to review errors in the three systems that are involved in enrollment status reporting and identify any solutions. A common folder for submittal rosters will be shared between the offices so that they may also be reviewed for accuracy. National Student Clearinghouse issue notifications will also be kept on file for future reference. Contact person: Rich Kluin, Vice President – Finance and Operations, Southeast Technical College Status of finding – The above corrective actions will be implemented beginning July 1, 2024.
FAC accepted this audit on March 28, 2023 — management decision was due September 28, 2023.
The required quarterly public reports were not posted to the School District?s website for the institutional portion or the student aid portion. Cause: Inadequate controls implemented to ensure compliance with HEERF reporting requirements. Effect: The errors in reporting resulted in reporting dates outside of the required reporting timeframe. Questioned Costs: None. Context/Sampling: All quarterly reports that were required to be completed were tested. Repeat Finding from Prior Year(s): Yes, Finding 2021-002. Recommendation: We recommend that a tracking schedule is made by Southeast Technical College which is monitored to ensure the requirements, including deadlines, for reporting are met in the timeframe allowed under the grant agreements. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2022-002 Department of Education Education Stabilization Fund: Higher Education Emergency Relief Find (HEERF) Federal Financial Assistance Listing 84.425E Student Aid Portion Award Number P425E204074, Award Years 2020 and 2021 Federal Financial Assistance Listing 84.425F Institutional Portion Award Number P425F202657, Award Years 2020 and 2021 Reporting Material Weakness in Internal Controls over Compliance and Material Non-Compliance Criteria: CRRSSA section 314 (e) and CARES Act 18004 (e), sets forth the criteria for reporting requirements. Condition: The required quarterly public reports were not posted to the School District?s website for the institutional portion or the student aid portion. Cause: Inadequate controls implemented to ensure compliance with HEERF reporting requirements. Effect: The errors in reporting resulted in reporting dates outside of the required reporting timeframe. Questioned Costs: None. Context/Sampling: All quarterly reports that were required to be completed were tested. Repeat Finding from Prior Year(s): Yes, Finding 2021-002. Recommendation: We recommend that a tracking schedule is made by Southeast Technical College which is monitored to ensure the requirements, including deadlines, for reporting are met in the timeframe allowed under the grant agreements. Views of Responsible Officials: Management agrees with the finding.
Identifying Number: 2022-002: U.S. Department of Education: Education Stabilization Fund: Student Aid Portion ? 84.425E; Institutional Portion ? 84.425F Finding: The required quarterly public reports were not posted to the District?s website for the student aid portion or the institutional portion. Corrective Action Taken or Planned: This relates to the reporting requirements of funds received under the Coronavirus Aid, Relief, and Economic Security Act (CARES), the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSA), and the American Rescue Plan (ARP) legislation, more commonly referred to as Higher Education Emergency Relief Funds I, II, and III. The legislation included reporting requirements for both the Institutional portion and Student Aid portions of the federal awards. Institutional reports are to be filed with the US Department of Education (USDOE) on forms prescribed by the Department indicating expenditures in eligible categories for the covered quarter. A standardized reporting document was not established for the Student Aid Distributions; however, distribution amounts, determination methodologies, and eligibility requirements are to be reported in a conspicuous location on the Institute of Higher Education?s website. Institutional reports have been completed. The required expenditure information was reported on the quarterly report associated with the actual draw down of the federal funds from the USDOE grants management system (G5) and not when the actual expenditures were incurred. The basis for reporting the expenditures in this manner was derived from an incorrect interpretation of a Technical Assistance Webinar related to Quarterly Reporting requirements and guidance contained in correspondence received from the USDOE Program Contact. The Student Aid portion of the federal award has been distributed in multiple awards corresponding to specific periods of student enrollment (i.e., Spring 2020, Fall 2020, Spring 2021, Fall 2021, Spring 2022). Reporting for the Spring 2020 and Fall 2020 distribution periods have been posted to Southeast Technical College?s website for the Spring/Fall 2020 distribution. Additional corrective actions will include the College compiling the Student Award information for the remaining distributions for publication on the website as required under the various HEERF guidelines and legislation. Reporting deadlines will be confirmed and posted to staff calendars to ensure timely review and filing of all reports. Future reports will be posted on a timely basis following supervisory review by the Vice President of Finance and Operations, Southeast Technical College. Contact person: Rich Kluin, Vice President ? Finance and Operations, Southeast Technical College Status of finding ? The above corrective actions will be implemented beginning April 1, 2023.
2021-002
For one vendor paid with HEERF funding and one vendor paid from CNC funding, there was no documentation to support that the School District had verified that the vendors were not suspended or debarred prior to purchases. Cause: Vendors are not being checked for suspension and debarment consistently prior to covered transactions when large purchases are made through the School District?s voucher process rather than the purchase order process. Effect: These errors could result in payment to suspended or debarred vendors. Questioned Costs: None. Context/Sampling: For HEERF, one of the 3 tested vendors did not have documented suspension and debarment verification with a total population of 4 vendors. For the Child Nutrition Cluster testing, one of the 7 tested vendors did not have documented suspension and debarment verification with a total population of 55 vendors. Repeat Finding from Prior Year(s): Yes, Finding 2021-005. Recommendation: We recommend that all purchases with amounts expected to go over $25,000 be vetted through the School District?s purchase order process to ensure proper procurement, suspension, and debarment policies are adequately followed for covered transactions. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2022-003 Department of Education Education Stabilization Fund: Higher Education Emergency Relief Find (HEERF) Federal Financial Assistance Listing 84.425F Institutional Portion Award Number P425F202657, Award Years 2020 and 2021 Department Of Agriculture Passed Through the South Dakota Department of Education Child Nutrition Cluster (CNC) Federal Financial Assistance Listing 10.553 School Breakfast Program (SBP) Federal Financial Assistance Listing 10.555 National School Lunch Program (NSLP) Federal Financial Assistance Listing 10.559 Summer Food Service Program For Children (SFSP) 2021-2022 Award Year Procurement, Suspension and Debarment Significant Deficiency in Internal Controls over Compliance and Non-Compliance Criteria: 2 CFR section 200.214, sets forth the criteria for suspension and debarment requirements. Condition: For one vendor paid with HEERF funding and one vendor paid from CNC funding, there was no documentation to support that the School District had verified that the vendors were not suspended or debarred prior to purchases. Cause: Vendors are not being checked for suspension and debarment consistently prior to covered transactions when large purchases are made through the School District?s voucher process rather than the purchase order process. Effect: These errors could result in payment to suspended or debarred vendors. Questioned Costs: None. Context/Sampling: For HEERF, one of the 3 tested vendors did not have documented suspension and debarment verification with a total population of 4 vendors. For the Child Nutrition Cluster testing, one of the 7 tested vendors did not have documented suspension and debarment verification with a total population of 55 vendors. Repeat Finding from Prior Year(s): Yes, Finding 2021-005. Recommendation: We recommend that all purchases with amounts expected to go over $25,000 be vetted through the School District?s purchase order process to ensure proper procurement, suspension, and debarment policies are adequately followed for covered transactions. Views of Responsible Officials: Management agrees with the finding.
Identifying Number: 2022-003: U.S. Department of Education: Education Stabilization Fund: Student Aid Portion ? 84.425E (HEERF); U.S. Department of Agriculture: Child Nutrition Cluster ? 10.553, 10.555, and 10.559 (CNC) Finding: For one vendor paid with HEERF funding and one vendor paid from CNC funding, there was no documentation to support that the District had verified that the vendors were not suspended or debarred prior to purchases. Corrective Action Taken or Planned: This relates to the Entity Exclusion (Suspension/Debarment) list maintained on the federal SAM.GOV website. Access to the website and specifically the Entity search functions is limited to authorized/registered users. The corrective action plan for HEERF will include the designation of a Southeast Technical College employee with SAM.GOV access that will be the initial point of contact for vendor exclusion information for all Southeast Technical College employees. Additionally, the designated employee will periodically download, and post debarment lists to the Southeast Technical College internal website (myTech) that will be available to all employees purchasing goods/services that would be charged to federal programs. Additional corrective actions will include a review of existing Southeast Technical College procurement policies contained within Section D: Fiscal Management. Policies will be reviewed/revised to expand and reflect current federal procurement requirements under 2CRF200. Revised policies, debarment lists, and training will be provided to all employees on a periodic and ongoing basis. For the Child Nutrition Cluster, this particular vendor was not expected to go over $25,000 and was used for emergency purchases that did not go over $25,000 until the last purchase in June, 2022. It was recommended that all purchases with amounts expected to go over $25,000 be vetted through the District?s purchase order process. Since this vendor was not expected to go over $25,000, it did not go through the purchase order process. The District will continue to use the purchase order process for vendors expected to go over $25,000 to ensure debarment requirements are being followed. Contact person: HEERF: Rich Kluin, Vice President ? Finance and Operations, Southeast Technical College. CNC: Gay Anderson, Child Nutrition Supervisor. Status of finding ? HEERF procedures will continue to be followed. The CNC procedures will continue to be followed.
2021-005
For one vendor paid with HEERF funding, the the School District did not maintain documentation to support they obtained sufficient quotes for purchase of software. Cause: Purchases are not consistently going through the procurement process per the School District?s procurement policy or Uniform Guidance when large purchases are made through the School District?s voucher process rather than the purchase order process. Effect: As a result, the School District is not in compliance with 2 CRF section 200.318 procurement requirements. Questioned Costs: None. Context/Sampling: One of the 3 tested vendors did not have necessary documentation to support whether proper procurement policies were followed. The population for vendors meeting requirements for procurement was 7. Repeat Finding from Prior Year(s): Yes, Finding 2021-004. Recommendation: We recommend that all large purchases are vetted through the School District?s purchase order process to ensure proper procurement, suspension, and debarment policies are adequately followed for covered transations. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2022-004 Department of Education Education Stabilization Fund: Higher Education Emergency Relief Find (HEERF) Federal Financial Assistance Listing 84.425F Institutional Portion Award Number P425F202657, Award Years 2020 and 2021 Procurement, Suspension and Debarment Significant Deficiency in Internal Controls over Compliance and Non-Compliance Criteria: 2 CFR section 200.318, sets forth the criteria for procurement requirements. Condition: For one vendor paid with HEERF funding, the the School District did not maintain documentation to support they obtained sufficient quotes for purchase of software. Cause: Purchases are not consistently going through the procurement process per the School District?s procurement policy or Uniform Guidance when large purchases are made through the School District?s voucher process rather than the purchase order process. Effect: As a result, the School District is not in compliance with 2 CRF section 200.318 procurement requirements. Questioned Costs: None. Context/Sampling: One of the 3 tested vendors did not have necessary documentation to support whether proper procurement policies were followed. The population for vendors meeting requirements for procurement was 7. Repeat Finding from Prior Year(s): Yes, Finding 2021-004. Recommendation: We recommend that all large purchases are vetted through the School District?s purchase order process to ensure proper procurement, suspension, and debarment policies are adequately followed for covered transations. Views of Responsible Officials: Management agrees with the finding.
Identifying Number: 2022-004: U.S. Department of Education: Education Stabilization Fund: Institutional Portion ? 84.425F (HEERF) Finding: For one vendor paid with HEERF funding, the District did not maintain documentation to support they obtained sufficient quotes for purchase of software. Corrective Action Taken or Planned: STC will utilize and vet purchases in excess of $25,000 through the District?s purchase order process. Utilization of this process will ensure that quotes are obtained prior to purchase commitments. Contact person: Rich Kluin, Vice President ? Finance and Operations, Southeast Technical College Status of finding ? The corrective action will be implemented on April 1, 2023.
2021-004
FAC accepted this audit on April 3, 2022 — management decision was due October 3, 2022.
Southeast Technical College did not timely post the required Quarterly Public Reporting for Institutional Portion reports or the Quarterly Public Reporting for Student Aid Portion reports. Cause: Inadequate review controls were implemented to ensure compliance with the Education Stabilization Fund reporting requirements. Effect: Failure to comply with federal reporting standards could ultimately result in ineligibility for Southeast Technical College to receive federal funds if failure to comply was determined to be severe. Questioned Costs: None. Repeat finding: No. Context: Eight of the nine tested reports were not posted or were not posted timely. Recommendation: Review controls should be established for Education Stabilization Fund reporting requirements to ensure compliance with the related federal award agreements. Views of responsible officials: We agree with the finding and recommendation.
Show full finding ▾Hide full finding ▴Finding 2021-002: U.S. Department of Education: Education Stabilization Fund: Student Aid Portion ?84.425E; Institutional Portion ?84.425F Criteria: Education Stabilization Fund, U.S Department of Education, and the related subsequently issued reporting guidance require certain prescribed information be included in the timely filing of an annual report, as well as the timely filing of quarterly reports for both the Student Aid Portion and Institutional Portions of the award. Condition: Southeast Technical College did not timely post the required Quarterly Public Reporting for Institutional Portion reports or the Quarterly Public Reporting for Student Aid Portion reports. Cause: Inadequate review controls were implemented to ensure compliance with the Education Stabilization Fund reporting requirements. Effect: Failure to comply with federal reporting standards could ultimately result in ineligibility for Southeast Technical College to receive federal funds if failure to comply was determined to be severe. Questioned Costs: None. Repeat finding: No. Context: Eight of the nine tested reports were not posted or were not posted timely. Recommendation: Review controls should be established for Education Stabilization Fund reporting requirements to ensure compliance with the related federal award agreements. Views of responsible officials: We agree with the finding and recommendation.
Identifying Number: 2021-002: U.S. Department of Education: Education Stabilization Fund: Student Aid Portion ? 84.425E; Institutional Portion ? 84.425F Finding: Southeast Technical College did not timely post the required Quarterly Public Reporting for Student Aid Portion reports or the Quarterly Public Reporting for Institutional Portion reports. Corrective Action Taken or Planned: This relates to the reporting requirements of funds received under the Coronavirus Aid, Relief, and Economic Security Act (CARES), the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSA), and the American Rescue Plan (ARP) legislation, more commonly referred to as Higher Education Emergency Relief Funds I, II, and III. The legislation included reporting requirements for both the Institutional portion and Student Aid portions of the federal awards. Institutional reports are to be filed with the US Department of Education (USDOE) on forms prescribed by the Department indicating expenditures in eligible categories for the covered quarter. A standardized reporting document was not established for the Student Aid Distributions; however, distribution amounts, determination methodologies, and eligibility requirements are to be reported in a conspicuous location on the Institute of Higher Education?s website. Institutional reports have been completed. Required expenditure information was reported on the quarterly report associated with the actual draw down of the federal funds from the USDOE grants management system (G5) and not when the actual expenditures were incurred. The basis for reporting the expenditures in this manner was derived from an incorrect interpretation of a Technical Assistance Webinar related to Quarterly Reporting requirements and guidance contained in correspondence received from the USDOE Program Contact. The Student Aid portion of the federal award has been distributed in multiple awards corresponding to specific periods of student enrollment (i.e., Spring 2020, Fall 2020, Spring 2021, Fall 2021). Reporting for the Spring 2020 and Fall 2020 distribution periods have been posted to Southeast Technical College?s website for the Spring/Fall 2020 distribution. Additional corrective actions will include the College compiling the Student Award information for the remaining distributions for publication on the website as required under the various HEERF guidelines and legislation. Reporting deadlines will be confirmed and posted to staff calendars to ensure timely review and filing of all reports. Future reports will be posted on a timely basis following supervisory review by the Vice President of Finance and Operations, Southeast Technical College. Contact person: Rich Kluin, Vice President ? Finance and Operations, Southeast Technical College Status of finding ? The above corrective actions will be implemented beginning April 1, 2022.
Payroll charges for one of the 12 tested employees charged to the ESSER Program were not supported by the required payroll documentation for amounts charged to federal awards, such as semi-annual certifications or monthly personnel activity reports. Cause: The District?s policies and procedures to obtain the required payroll documentation, such as semi-annual certification or personnel activity reports, from all employees whose time is charged to federal awards are not being consistently followed or enforced. Effect: As a result of insufficient payroll documentation from this employee, it is possible that the employee?s costs could be improperly charged and reimbursed by the award. Failure to comply with federal requirements could ultimately result in ineligibility to receive federal grant funds or amounts to be disallowed for the ESSER Program. Questioned Costs: Questioned costs of $4,290 were noted from a sample of ESSER payroll expenditures totaling $43,231. The estimated amount of likely questioned costs is $43,806, based on the payroll expense for the employee that did not have the required payroll documentation available for the periods tested. The total population of the ESSER payroll expenditures was $2,044,821, and the total population of the ESSER Program expenditures is $4,234,634. Repeat finding: No. Recommendation: Procedures should be implemented and enforced to ensure that the required payroll documentation, such as semi-annual certifications or personnel activity reports, is obtained from all employees working on a single cost objective and employees working on multiple cost objectives that are charged to federal awards. Views of responsible officials: We agree with the finding and recommendation.
Show full finding ▾Hide full finding ▴Finding 2021-003: U.S. Department of Education, passed through the S.D. Department of Education: Education Stabilization Fund: ESSER - 84.425D Criteria: 2 CFR 200.430 (i) requires that personnel services charged to a federal award must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated. In addition, the Uniform Guidance requires that the documentation must reasonably reflect the total activity for which the employee is compensated and support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one federal award. Condition: Payroll charges for one of the 12 tested employees charged to the ESSER Program were not supported by the required payroll documentation for amounts charged to federal awards, such as semi-annual certifications or monthly personnel activity reports. Cause: The District?s policies and procedures to obtain the required payroll documentation, such as semi-annual certification or personnel activity reports, from all employees whose time is charged to federal awards are not being consistently followed or enforced. Effect: As a result of insufficient payroll documentation from this employee, it is possible that the employee?s costs could be improperly charged and reimbursed by the award. Failure to comply with federal requirements could ultimately result in ineligibility to receive federal grant funds or amounts to be disallowed for the ESSER Program. Questioned Costs: Questioned costs of $4,290 were noted from a sample of ESSER payroll expenditures totaling $43,231. The estimated amount of likely questioned costs is $43,806, based on the payroll expense for the employee that did not have the required payroll documentation available for the periods tested. The total population of the ESSER payroll expenditures was $2,044,821, and the total population of the ESSER Program expenditures is $4,234,634. Repeat finding: No. Recommendation: Procedures should be implemented and enforced to ensure that the required payroll documentation, such as semi-annual certifications or personnel activity reports, is obtained from all employees working on a single cost objective and employees working on multiple cost objectives that are charged to federal awards. Views of responsible officials: We agree with the finding and recommendation.
Identifying Number: 2021-003: U.S. Department of Education, passed through the S.D. Department of Education: Education Stabilization Fund: ESSER ? 84.425D Finding: Payroll charges for one of the 12 tested employees charged to the ESSER Program were not supported by the required payroll documentation for amounts charged to federal awards, such as semi-annual certifications or monthly personnel activity reports. Corrective Action Taken or Planned: The identified employee began the 2020-21 school year as a substitute nurse paid hourly with ESSER funds through a timesheet. This employee was hired with ESSER funds as a float nurse shortly after the beginning of the school year. This change was missed when considering time and effort documentation. The Sioux Falls School District will continue to implement and enforce procedures to ensure that the required payroll documentation is obtained from all employees working on a single cost objective and multiple cost objectives that are charged to federal awards. Contact person: Dr. Kirk Zeeck, Director ? Federal Programs and World Language Status of finding ? The above corrective action was implemented immediately upon notification.
For one expenditure transaction selected for testing, procurement documentation was not available to support that the required number of quotes were obtained, as required by Uniform Guidance ?200.318 and ?200.320 and the District?s procurement policy. Cause: The District?s policies and procedures to document the business rationale of procurements are not being consistently followed or enforced. Effect: As a result of not maintaining complete documentation for procurement of this contract, the District is not in compliance with the District?s procurement policy or Uniform Guidance ?200.318 and ?200.320. Questioned Costs: None. Repeat Finding: No. Context: One of the 16 transactions tested did not meet the procurement requirements, as documentation was not available to support that three quotes from competitors had been obtained per the small purchase acquisition requirements. Recommendation: Procurement controls should be enhanced to ensure adequate supporting documentation is obtained and maintained in accordance with Uniform Guidance and the District?s procurement policy. Views of responsible officials: We agree with the finding and recommendation
Show full finding ▾Hide full finding ▴Finding 2021-004: U.S. Department of Education: Education Stabilization Fund: Institutional Portion ?84.425F Criteria: Uniform Guidance ?200.318 states ?The non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law? The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.? Uniform Guidance ? 200.320 (b) states that "Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources.? The District?s procurement policy states ?For purchases of $1,000 or more per item, but less than the amount required by statute for competitive bidding, the purchasing supervisor, or designee, shall obtain competitive quotations from at least three vendors unless there are not three vendors who can supply the product or service.? Condition: For one expenditure transaction selected for testing, procurement documentation was not available to support that the required number of quotes were obtained, as required by Uniform Guidance ?200.318 and ?200.320 and the District?s procurement policy. Cause: The District?s policies and procedures to document the business rationale of procurements are not being consistently followed or enforced. Effect: As a result of not maintaining complete documentation for procurement of this contract, the District is not in compliance with the District?s procurement policy or Uniform Guidance ?200.318 and ?200.320. Questioned Costs: None. Repeat Finding: No. Context: One of the 16 transactions tested did not meet the procurement requirements, as documentation was not available to support that three quotes from competitors had been obtained per the small purchase acquisition requirements. Recommendation: Procurement controls should be enhanced to ensure adequate supporting documentation is obtained and maintained in accordance with Uniform Guidance and the District?s procurement policy. Views of responsible officials: We agree with the finding and recommendation
Identifying Number: 2021-004: U.S. Department of Education: Education Stabilization Fund: Institutional Portion ? 84.425F Finding: For one expenditure transaction selected for testing, procurement documentation was not available to support that the required number of quotes was obtained, as required by Uniform Guidance and the District?s procurement policy. Corrective Action Taken or Planned: This relates to a contracted purchase of software the Student Success Collaborative software platform provided by EAB Global, Inc. Contract 21-012 was approved by the Sioux Falls School Board on May 26, 2021. Southeast Technical College operates in a decentralized purchasing environment with administrative review and approval being conducted at the departmental level with limited system-level review by staff experienced in federal acquisition under the Uniform Guidance in 2CFR200. The corrective action plan will include the acquisition of a database license and training resources focused on managing Federal Grants for colleges. Existing District procurement policies will be reviewed, revised, and updated to reflect current requirements under the Uniform Guidance. Compliance trainings will be conducted on a regular and ongoing basis for all staff involved in procurement activities that are funded from local and/or federal sources. Contact person: Rich Kluin, Vice President ? Finance and Operations, Southeast Technical College Status of finding ? The above corrective action will be implemented beginning April 1, 2022 and will be ongoing throughout the fiscal year.
For three vendors with expenditures charged to the Education Stabilization Fund program, documentation was not available to support that the District had verified that these vendors were not suspended or debarred. Cause: The District?s controls and policies that require documentation of the procedures performed to verify that vendors are not suspended or debarred are not consistently enforced or followed. Effect: As a result of not maintaining documentation to support that vendor suspension and debarment verification procedures had been completed, the District could have utilized suspended or debarred vendors, which would result in noncompliance with the requirements of 2 CFR Section 180.215. Questioned Costs: None. Repeat Finding: No. Context: For the three Education Stabilization Fund vendors subject to suspension and debarment requirements, there was no documentation available to support that a verification had been completed to confirm that the vendors were not suspended or debarred. Recommendation: Procurement controls should be enhanced to ensure that adequate documentation is maintained to verify that vendors with expenditures charged to federal awards are not suspended or debarred. Views of responsible officials: We agree with the finding and recommendation.
Show full finding ▾Hide full finding ▴Finding 2021-005: U.S. Department of Education: Education Stabilization Fund: Institutional Portion ?84.425F Criteria: Non Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR Section 180.215. Condition: For three vendors with expenditures charged to the Education Stabilization Fund program, documentation was not available to support that the District had verified that these vendors were not suspended or debarred. Cause: The District?s controls and policies that require documentation of the procedures performed to verify that vendors are not suspended or debarred are not consistently enforced or followed. Effect: As a result of not maintaining documentation to support that vendor suspension and debarment verification procedures had been completed, the District could have utilized suspended or debarred vendors, which would result in noncompliance with the requirements of 2 CFR Section 180.215. Questioned Costs: None. Repeat Finding: No. Context: For the three Education Stabilization Fund vendors subject to suspension and debarment requirements, there was no documentation available to support that a verification had been completed to confirm that the vendors were not suspended or debarred. Recommendation: Procurement controls should be enhanced to ensure that adequate documentation is maintained to verify that vendors with expenditures charged to federal awards are not suspended or debarred. Views of responsible officials: We agree with the finding and recommendation.
Identifying Number: 2021-005: U.S. Department of Education: Education Stabilization Fund: Institutional Portion ? 84.425F Finding: For three vendors with expenditures charged to the Education Stabilization Fund program, documentation was not available to support that the District had verified that these vendors were not suspended or debarred. Corrective Action Taken or Planned: This relates to the Entity Exclusion (Suspension/Debarment) list maintained on the federal SAM.GOV website. Access to the website and specifically the Entity search functions is limited to authorized/registered users. The corrective action plan will include the designation of a Southeast Technical College employee with SAM.GOV access that will be the initial point of contact for vendor exclusion information for all Southeast Technical College employees. Additionally, the designated employee will periodically download, and post debarment lists to the Southeast Technical College internal website (myTech) that will be available to all employees purchasing goods/services that would be charged to federal programs. Additional corrective actions will include a review of existing Southeast Technical College procurement policies contained within Section D: Fiscal Management. Policies will be reviewed/revised to expand and reflect current federal procurement requirements under 2CRF200. Revised policies, debarment lists, and training will be provided to all employees on a periodic and ongoing basis. Contact person: Rich Kluin, Vice President ? Finance and Operations, Southeast Technical College Status of finding ? The above corrective action will be implemented beginning April 1, 2022 and will be ongoing throughout the fiscal year.
FAC accepted this audit on January 17, 2021 — management decision was due July 17, 2021.
FAC accepted this audit on February 18, 2020 — management decision was due August 18, 2020.
FAC accepted this audit on January 16, 2019 — management decision was due July 16, 2019.
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FAC accepted this audit on December 18, 2017 — management decision was due June 18, 2018.
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FAC accepted this audit on December 20, 2016 — management decision was due June 20, 2017.
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