EIN: 630494681
UEI: ZYE3A72ETCJ5
Audited by: Jackson Thornton Certified Public Accountants & Consultants
Oversight 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 February 10, 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 August 10, 2026 (20 days ago).
What is a management decision? →Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos 84.007, 84.033, 84.038, 84.063, and 84.268. Criteria - Institutions are required to report enrollment information under the Pell grant and the Direct loan program via the National Student Loan Data System (NSLDS). The administration of the Title IV programs depends heavily on the accuracy and timelines of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates reported to NSLDS. Institutions are responsible for accurate reporting. According to 34 CFR 685.309(2), the University is required to notify the Department of Education via the NSLDS if a “student has ceased to be enrolled on at least a half-time basis for the period for which the loan was intended”. Changes to status are required to be reported within 30 days of becoming aware of the status change, or with the next schedule transmission of statuses if the scheduled transmission is within 60 days. Condition - A sample of 40 students were selected from the population of all students who received federal student financial aid during the year ended September 30, 2025. We obtained the student records and tested compliance with federal regulations for the specific loans and grants. For 1 student selected for NSLDS Reporting testing, the student’s status change was not accurately reported to NSLDS. For the same student, the status change effective date was not accurately reported to NSLDS.Cause - The College’s processes of internal controls for reporting student status changes to NSLDS were not adequate. Effect - Student status changes were not accurately reported to NSLDS. Identification of Repeat Finding - Repeat finding of prior year finding 2024-002. Recommendation - We recommend the College revise its processes for reporting student status changes to NSLDS. The College should implement a process to review, update, and verify student enrollment statuses that appear on the Enrollment Reporting roster files. We also recommend that management implement controls to ensure reported changes are correctly reported to the NSLDS. Views of Responsible Officials - Management agrees with the finding. Errors were caused by a coding error within their reporting system. Upon discovery, the errors were promptly reviewed and corrected subsequent to year-end. The necessary adjustments were made to the enrollment data, and the corrected information was
Show full finding ▾Hide full finding ▴Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos 84.007, 84.033, 84.038, 84.063, and 84.268. Criteria - Institutions are required to report enrollment information under the Pell grant and the Direct loan program via the National Student Loan Data System (NSLDS). The administration of the Title IV programs depends heavily on the accuracy and timelines of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates reported to NSLDS. Institutions are responsible for accurate reporting. According to 34 CFR 685.309(2), the University is required to notify the Department of Education via the NSLDS if a “student has ceased to be enrolled on at least a half-time basis for the period for which the loan was intended”. Changes to status are required to be reported within 30 days of becoming aware of the status change, or with the next schedule transmission of statuses if the scheduled transmission is within 60 days. Condition - A sample of 40 students were selected from the population of all students who received federal student financial aid during the year ended September 30, 2025. We obtained the student records and tested compliance with federal regulations for the specific loans and grants. For 1 student selected for NSLDS Reporting testing, the student’s status change was not accurately reported to NSLDS. For the same student, the status change effective date was not accurately reported to NSLDS.Cause - The College’s processes of internal controls for reporting student status changes to NSLDS were not adequate. Effect - Student status changes were not accurately reported to NSLDS. Identification of Repeat Finding - Repeat finding of prior year finding 2024-002. Recommendation - We recommend the College revise its processes for reporting student status changes to NSLDS. The College should implement a process to review, update, and verify student enrollment statuses that appear on the Enrollment Reporting roster files. We also recommend that management implement controls to ensure reported changes are correctly reported to the NSLDS. Views of Responsible Officials - Management agrees with the finding. Errors were caused by a coding error within their reporting system. Upon discovery, the errors were promptly reviewed and corrected subsequent to year-end. The necessary adjustments were made to the enrollment data, and the corrected information was
Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos 84.007, 84.033, 84.038, 84.063, and 84.268. Criteria - Institutions are required to report enrollment information under the Pell grant and the Direct loan program via the National Student Loan Data System (NSLDS). The administration of the Title IV programs depends heavily on the accuracy and timelines of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates reported to NSLDS. Institutions are responsible for accurate reporting. According to 34 CFR 685.309(2), the University is required to notify the Department of Education via the NSLDS if a “student has ceased to be enrolled on at least a half-time basis for the period for which the loan was intended”. Changes to status are required to be reported within 30 days of becoming aware of the status change, or with the next schedule transmission of statuses if the scheduled transmission is within 60 days. Condition - A sample of 40 students were selected from the population of all students who received federal student financial aid during the year ended September 30, 2025. We obtained the student records and tested compliance with federal regulations for the specific loans and grants. For 1 student selected for NSLDS Reporting testing, the student’s status change was not accurately reported to NSLDS. For the same student, the status change effective date was not accurately reported to NSLDS. Cause - The College’s processes of internal controls for reporting student status changes to NSLDS were not adequate. Effect - Student status changes were not accurately reported to NSLDS. Identification of Repeat Finding - Repeat finding of prior year finding 2024-002. Recommendation - We recommend the College revise its processes for reporting student status changes to NSLDS. The College should implement a process to review, update, and verify student enrollment statuses that appear on the Enrollment Reporting roster files. We also recommend that management implement controls to ensure reported changes are correctly reported to the NSLDS. Views of Responsible Officials - Management agrees with the finding. Errors were caused by a coding error within their reporting system. Upon discovery, the errors were promptly reviewed and corrected subsequent to year-end. The necessary adjustments were made to the enrollment data, and the corrected information was submitted to the appropriate federal and state agencies in compliance with reporting requirements. Corrective Action Plan – A withdrawal process was put in place after this issue was identified as a finding in the prior year’s audit. The Financial Aid Director and Registrar will work closely together and continue to monitor the withdrawal process.
2024-002
FAC accepted this audit on April 4, 2025 — management decision was due October 4, 2025.
Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007, 84.033, 84.063, and 84.268. Criteria - Institutions are required to report enrollment information under the Pell grant and the Direct loan program via the National Student Loan Data System (NSLDS). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates reported to NSLDS. Institutions are responsible for accurate reporting. According to 34 CFR 685.309(2), the College is required to notify the Department of Education via the NSLDS if a “student has ceased to be enrolled on at least a half-time basis for the period for which the loan was intended”. Changes to status are required to be reported within 30 days of becoming aware of the status change, or with the next schedule transmission of statuses if the scheduled transmission is within 60 days. Condition - A sample of students were selected from the population of all students who received federal student financial aid during the year ended September 30, 2024. We obtained the student records and tested compliance with federal regulations for the specific loans and grants. For 7 students selected for Enrollment Reporting testing, the status change to withdrawn was not reported within the 60-day reporting window after the status change was effective. For 2 students selected for Enrollment Reporting testing, the status change was not reported to NSLDS. Cause - The College’s processes of internal controls for reporting student status changes to NSLDS were not adequate. Effect - Student status changes were not reported to NSLDS within the required timeframe. Identification of Repeat Finding - Repeat finding of prior year finding 2023-002. Recommendation - We recommend the College revise its processes for reporting student status changes to NSLDS. The College should implement a process to review, update, and verify student enrollment statuses that appear on the Enrollment Reporting roster files. We also recommend that management implement controls to ensure reported changes are timely and correctly reported to the NSLDS. Views of Responsible Officials - Management agrees with the finding. Errors were caused by a coding error within their reporting system. Upon discovery, the errors were promptly reviewed and corrected subsequent to year end. The necessary adjustments were made to the enrollment data, and the corrected information was submitted to the appropriate federal and state agencies in compliance with reporting requirements.
Show full finding ▾Hide full finding ▴Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007, 84.033, 84.063, and 84.268. Criteria - Institutions are required to report enrollment information under the Pell grant and the Direct loan program via the National Student Loan Data System (NSLDS). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates reported to NSLDS. Institutions are responsible for accurate reporting. According to 34 CFR 685.309(2), the College is required to notify the Department of Education via the NSLDS if a “student has ceased to be enrolled on at least a half-time basis for the period for which the loan was intended”. Changes to status are required to be reported within 30 days of becoming aware of the status change, or with the next schedule transmission of statuses if the scheduled transmission is within 60 days. Condition - A sample of students were selected from the population of all students who received federal student financial aid during the year ended September 30, 2024. We obtained the student records and tested compliance with federal regulations for the specific loans and grants. For 7 students selected for Enrollment Reporting testing, the status change to withdrawn was not reported within the 60-day reporting window after the status change was effective. For 2 students selected for Enrollment Reporting testing, the status change was not reported to NSLDS. Cause - The College’s processes of internal controls for reporting student status changes to NSLDS were not adequate. Effect - Student status changes were not reported to NSLDS within the required timeframe. Identification of Repeat Finding - Repeat finding of prior year finding 2023-002. Recommendation - We recommend the College revise its processes for reporting student status changes to NSLDS. The College should implement a process to review, update, and verify student enrollment statuses that appear on the Enrollment Reporting roster files. We also recommend that management implement controls to ensure reported changes are timely and correctly reported to the NSLDS. Views of Responsible Officials - Management agrees with the finding. Errors were caused by a coding error within their reporting system. Upon discovery, the errors were promptly reviewed and corrected subsequent to year end. The necessary adjustments were made to the enrollment data, and the corrected information was submitted to the appropriate federal and state agencies in compliance with reporting requirements.
Student exceptions were caused by a coding error within the Banner reporting system. Upon discovery, the errors were promptly reviewed and corrected subsequent to year end. The necessary adjustments were made to the enrollment data, and the corrected information was submitted to the appropriate federal and state agencies in compliance with reporting requirements. The Financial Aid Director and Registrar will work closely together to continue to monitor the withdrawal process put in place after the finding was identified in the 2023 fiscal year.
Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007, 84.033, 84.063, and 84.268. Criteria - When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)). Condition - A sample of 40 students were selected from a population of all students that were withdrawn, dropped, on a leave of absence, never began attendance or terminated during the audit period to ascertain if returns of Title IV funds were properly calculated and timely processed. For 1 student selected for Return to Title IV testing, it was identified that the College incorrectly calculated the Return to Title IV (R2T4) funding due to inaccuracies in the institutional charges applied to the R2T4 calculation. The College did not use the correct institutional charges in its R2T4 calculation, which resulted in overcalculating the return of funds by the institution and undercalculating the return of funds by the student that needed to be returned to the U.S. Department of Education (ED). For 2 students selected for Return to Title IV testing, the College did not properly allocate the returned funds between the College and the student. As a result, the student’s portion of the returned funds was either over- or under-reported, impacting both the student’s financial aid account and the College’s compliance with federal requirements. For 1 student selected for Return to Title IV testing, the College used incorrect enrollment start and end dates, which resulted in the failure to properly complete an R2T4 calculation. Because the calculation was not performed when required, the College did not determine the amount of Title IV funds to be returned for students who withdrew, as mandated by the U.S. Department of Education. Cause - The errors were due to inadequate internal controls over the R2T4 process. The institution's processes for tracking enrollment dates, calculating institutional amounts, and allocating funds did not include sufficient verification steps to ensure accuracy. Effect - Overpayments or underpayments of R2T4 reimbursements to students and the Department of Education. Recommendation - We recommend the College Conduct periodic audits of the R2T4 process to ensure ongoing compliance with federal requirements and to identify potential errors before they impact students or the institution. We also recommend that management strengthens internal controls to ensure that the correct institutional amounts, enrollment dates, and other relevant data are used in the R2T4 process. This should include system checks or automated tools to flag discrepancies. Views of Responsible Officials - Management agrees with the finding.
Show full finding ▾Hide full finding ▴Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007, 84.033, 84.063, and 84.268. Criteria - When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)). Condition - A sample of 40 students were selected from a population of all students that were withdrawn, dropped, on a leave of absence, never began attendance or terminated during the audit period to ascertain if returns of Title IV funds were properly calculated and timely processed. For 1 student selected for Return to Title IV testing, it was identified that the College incorrectly calculated the Return to Title IV (R2T4) funding due to inaccuracies in the institutional charges applied to the R2T4 calculation. The College did not use the correct institutional charges in its R2T4 calculation, which resulted in overcalculating the return of funds by the institution and undercalculating the return of funds by the student that needed to be returned to the U.S. Department of Education (ED). For 2 students selected for Return to Title IV testing, the College did not properly allocate the returned funds between the College and the student. As a result, the student’s portion of the returned funds was either over- or under-reported, impacting both the student’s financial aid account and the College’s compliance with federal requirements. For 1 student selected for Return to Title IV testing, the College used incorrect enrollment start and end dates, which resulted in the failure to properly complete an R2T4 calculation. Because the calculation was not performed when required, the College did not determine the amount of Title IV funds to be returned for students who withdrew, as mandated by the U.S. Department of Education. Cause - The errors were due to inadequate internal controls over the R2T4 process. The institution's processes for tracking enrollment dates, calculating institutional amounts, and allocating funds did not include sufficient verification steps to ensure accuracy. Effect - Overpayments or underpayments of R2T4 reimbursements to students and the Department of Education. Recommendation - We recommend the College Conduct periodic audits of the R2T4 process to ensure ongoing compliance with federal requirements and to identify potential errors before they impact students or the institution. We also recommend that management strengthens internal controls to ensure that the correct institutional amounts, enrollment dates, and other relevant data are used in the R2T4 process. This should include system checks or automated tools to flag discrepancies. Views of Responsible Officials - Management agrees with the finding.
The different conditions mentioned pertain to two students. There were errors in calculation which have been corrected by the financial aid office and the cause noted to prevent future occurrences. Since the college does not require repayment from students for amounts returned in an R2T4 calculation, it is positive to note that the students were not financially affected by the errors. 54
FAC accepted this audit on April 4, 2024 — management decision was due October 4, 2024.
Identification of the Federal Program - Higher Education Emergency Relief Fund (HEERF) - Assistance Listing Numbers 84.425E, 84.425F, and 84.425M Criteria - The Coronavirus Aid, Relief, and Economic Security (CARES) Act Section 18004(e), the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) Section Act 314(e), and the American Rescue Plan (ARP) Section 2003 requires an institution receiving funds under HEERF I, HEERF II, and HEERF III to submit a report to the secretary, at such time in such a manner as the secretary may require. Per the instructions for the Quarterly Budget and Expenditure Reporting for all HEERF I, II, and III Grant Funds, an institution must specify the amount of expended HEERF I, II, and III funds for each funding category. 2 CFR 200.303, Internal Controls, requires that recipients establish and maintain effective internal control over Federal awards that provides reasonable assurance that the recipient is managing Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. Condition - There was a lack of monitoring and appropriate review by the College of the Quarterly Budget and Expenditure Reporting for all HEERF I, II, and III Grant Funds. Effect - For the reporting period ended December 31, 2022, institutional expenditures of $71,280 were excluded from the report. Cause - The incorrect reporting is attributed to a lack of monitoring and appropriate review of the report by the College. Recommendation - The College should implement policies and procedures to monitor and review all reports. Views of Responsible Officials - The College agrees with the finding. The College will implement additional review procedures over grant reporting. The College will also revise and submit a corrected report.
Show full finding ▾Hide full finding ▴Identification of the Federal Program - Higher Education Emergency Relief Fund (HEERF) - Assistance Listing Numbers 84.425E, 84.425F, and 84.425M Criteria - The Coronavirus Aid, Relief, and Economic Security (CARES) Act Section 18004(e), the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) Section Act 314(e), and the American Rescue Plan (ARP) Section 2003 requires an institution receiving funds under HEERF I, HEERF II, and HEERF III to submit a report to the secretary, at such time in such a manner as the secretary may require. Per the instructions for the Quarterly Budget and Expenditure Reporting for all HEERF I, II, and III Grant Funds, an institution must specify the amount of expended HEERF I, II, and III funds for each funding category. 2 CFR 200.303, Internal Controls, requires that recipients establish and maintain effective internal control over Federal awards that provides reasonable assurance that the recipient is managing Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. Condition - There was a lack of monitoring and appropriate review by the College of the Quarterly Budget and Expenditure Reporting for all HEERF I, II, and III Grant Funds. Effect - For the reporting period ended December 31, 2022, institutional expenditures of $71,280 were excluded from the report. Cause - The incorrect reporting is attributed to a lack of monitoring and appropriate review of the report by the College. Recommendation - The College should implement policies and procedures to monitor and review all reports. Views of Responsible Officials - The College agrees with the finding. The College will implement additional review procedures over grant reporting. The College will also revise and submit a corrected report.
Dealing with multiple HEERF grants was challenging because each grant required recording in a separate restricted fund. The college omitted one of these funds from the December 2022 quarterly HEERF report. The accountant for restricted grants did not realize a $71,280 purchase order was paid before the end of the quarter, resulting in inaccurate reporting for the quarter. For future reports, the accountant for restricted grants will review all open purchase orders for payment to ensure that paid expenses are correctly included on the published report.
Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007, 84.033, 84.063, and 84.268 Criteria - Institutions are required to report enrollment information under the Pell grant and the Direct Loan program via the National Student Loan Data System (NSLDS). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates reported to NSLDS. Institutions are responsible for accurate reporting. According to 34 CFR 685.309(2), the College is required to notify the Department of Education via the NSLDS if a “student has ceased to be enrolled on at least a half-time basis for the period for which the loan was intended”. Changes to status are required to be reported within 30 days of becoming aware of the status change, or with the next schedule transmission of statuses if the scheduled transmission is within 60 days. Condition - A sample of students were selected from the population of all students who received federal student financial aid during the year ended September 30, 2023. We obtained the student records and tested compliance with federal regulations for the specific loans and grants. For 1 student selected for Enrollment Reporting testing, the withdrawal date per the NSLDS enrollment detail did not agree to the withdrawal date per the College’s records. For 17 students selected for Enrollment Reporting testing, the status change to withdrawn was not reported within the 60 day reporting window after the status change was effective. For 5 students selected for Enrollment Reporting testing, the student’s withdrawal was not reported to NSLDS. Cause - The College’s processes of internal controls for reporting enrollment information and timely reporting of student status changes to NSLDS were not adequate. Effect - Enrollment reporting to NSLDS did not include accurate information. Student status changes were not reported to NSLDS within the required timeframe. Recommendation - We recommend the College revise its processes for reporting enrollment information and to timely report student status changes to NSLDS. The College should implement a process to review, update, and verify student enrollment statuses that appear on the Enrollment Reporting roster files. We also recommend that management implement controls to ensure reported changes are timely reported to the NSLDS. Views of Responsible Officials - Management agrees with the finding.
Show full finding ▾Hide full finding ▴Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007, 84.033, 84.063, and 84.268 Criteria - Institutions are required to report enrollment information under the Pell grant and the Direct Loan program via the National Student Loan Data System (NSLDS). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates reported to NSLDS. Institutions are responsible for accurate reporting. According to 34 CFR 685.309(2), the College is required to notify the Department of Education via the NSLDS if a “student has ceased to be enrolled on at least a half-time basis for the period for which the loan was intended”. Changes to status are required to be reported within 30 days of becoming aware of the status change, or with the next schedule transmission of statuses if the scheduled transmission is within 60 days. Condition - A sample of students were selected from the population of all students who received federal student financial aid during the year ended September 30, 2023. We obtained the student records and tested compliance with federal regulations for the specific loans and grants. For 1 student selected for Enrollment Reporting testing, the withdrawal date per the NSLDS enrollment detail did not agree to the withdrawal date per the College’s records. For 17 students selected for Enrollment Reporting testing, the status change to withdrawn was not reported within the 60 day reporting window after the status change was effective. For 5 students selected for Enrollment Reporting testing, the student’s withdrawal was not reported to NSLDS. Cause - The College’s processes of internal controls for reporting enrollment information and timely reporting of student status changes to NSLDS were not adequate. Effect - Enrollment reporting to NSLDS did not include accurate information. Student status changes were not reported to NSLDS within the required timeframe. Recommendation - We recommend the College revise its processes for reporting enrollment information and to timely report student status changes to NSLDS. The College should implement a process to review, update, and verify student enrollment statuses that appear on the Enrollment Reporting roster files. We also recommend that management implement controls to ensure reported changes are timely reported to the NSLDS. Views of Responsible Officials - Management agrees with the finding.
The Student Financial Aid department will address the circumstances of the finding by working with the institution’s primary contact at the National Student Clearinghouse before Fall 2024. They will review and establish a scheduled transmission of reporting to meet the standards of The Department of Education Title IV programs. The Financial Aid Director and Registrar will work closely together to revise the unofficial withdrawal process before Fall 2024. The new process should ensure unofficial withdrawals are reported promptly, with accurate data, and within the roster file, based on the 50% midpoint of the semester instead of the last date of attendance. Testing will be conducted randomly during Fall 2024 to ensure the accuracy of the new process and the information reported in each roster file.
FAC accepted this audit on June 28, 2023 — management decision was due December 28, 2023.
FAC accepted this audit on March 30, 2022 — management decision was due September 30, 2022.
FAC accepted this audit on June 21, 2021 — management decision was due December 21, 2021.
Reference Number: 2020-001 Compliance Requirement: Procurement and Suspension/Debarment Type of Finding: Internal Control/Compliance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance CFDA Number and Title): 84.425F ? HEERF Institutional Portion Federal Awarding Agency: U.S. Department of Education Federal Award Number: P425F202467 Pass-through Entity: None Pass-through Award Number: None Questioned Costs: $29,064.85 HEERF Institutional Portion funds were used to pay $29,064.85, to an employment agency, for temporary workers without obtaining required bids. Finding The U. S. Code of Federal Regulations Title 2, Part 200.318, of the Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states that non-Federal entities must use its own documented procurement procedures which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified within that section. The Code of Alabama 1975, Section 41-16-50(a) states, "With the exception of contracts for public works whose competitive bidding requirements are governed exclusively by Title 39, all expenditure of funds of whatever nature for labor, services, work, or for the purchase of materials, equipment, supplies, or other personal property involving fifteen thousand dollars ($15,000) or more... shall be made under contractual agreement entered into by free and open competitive bidding, on sealed bids, to the lowest responsible bidder." Due to a lack of properly implemented internal controls and the need to put individuals in place in a timely manner during the COVID-19 pandemic to monitor entrances, the College failed to bid a contract for temporary workers. During the fiscal year, the College paid $29,064.85, to a staffing agency without competitive bidding. Recommendation The College should implement internal controls to ensure compliance with the Uniform Guidance, Section 200.318 and the Code of Alabama 1975, Section 41-16-50(a).
Show full finding ▾Hide full finding ▴Reference Number: 2020-001 Compliance Requirement: Procurement and Suspension/Debarment Type of Finding: Internal Control/Compliance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance CFDA Number and Title): 84.425F ? HEERF Institutional Portion Federal Awarding Agency: U.S. Department of Education Federal Award Number: P425F202467 Pass-through Entity: None Pass-through Award Number: None Questioned Costs: $29,064.85 HEERF Institutional Portion funds were used to pay $29,064.85, to an employment agency, for temporary workers without obtaining required bids. Finding The U. S. Code of Federal Regulations Title 2, Part 200.318, of the Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states that non-Federal entities must use its own documented procurement procedures which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified within that section. The Code of Alabama 1975, Section 41-16-50(a) states, "With the exception of contracts for public works whose competitive bidding requirements are governed exclusively by Title 39, all expenditure of funds of whatever nature for labor, services, work, or for the purchase of materials, equipment, supplies, or other personal property involving fifteen thousand dollars ($15,000) or more... shall be made under contractual agreement entered into by free and open competitive bidding, on sealed bids, to the lowest responsible bidder." Due to a lack of properly implemented internal controls and the need to put individuals in place in a timely manner during the COVID-19 pandemic to monitor entrances, the College failed to bid a contract for temporary workers. During the fiscal year, the College paid $29,064.85, to a staffing agency without competitive bidding. Recommendation The College should implement internal controls to ensure compliance with the Uniform Guidance, Section 200.318 and the Code of Alabama 1975, Section 41-16-50(a).
Corrective Action planned: In summer semester 2020, the College had to secure part-time workers in order to comply with the System Office approved Covid-19 plan to reopen the College. The job of the workers was to secure the doors to buildings and distribute wrist bands to qualified entrants. The College utilized a temporary employment agency that it had used previously for securing additional workers. The College also placed an advertisement to hire these temporary workers directly, but could not fill all needed positions. Unfortunately, this occurred in the midst of a system-wide transition to a new software system. While the College?s purchasing agent routinely monitors the vendor expenditure report for totals exceeding $15,000, she had not been trained on the new software system until the allowed fiscal year limit had been exceeded. Training is now complete and the vendor expenditure report from the new software is reviewed periodically by the purchasing agent. The College will follow State bid law requirements in the future.
FAC accepted this audit on May 6, 2020 — management decision was due November 6, 2020.
FAC accepted this audit on April 28, 2019 — management decision was due October 28, 2019.
FAC accepted this audit on March 22, 2018 — management decision was due September 22, 2018.
FAC accepted this audit on April 16, 2017 — management decision was due October 16, 2017.
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