EIN: 630507477
UEI: WTDAUMTURGC5
Data as of August 26, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 16, 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 July 16, 2026 (42 days ago).
What is a management decision? →We selected a sample of 25 non-payroll disbursements and 25 payroll disbursements charged to the grant. There were 44 pay checks tested in the sample of 25; of those 44, nine exceptions were noted. In four instances, there was no documented approved pay rate and in five instances, there was no approval for salary to be charged to the grant number and documentation showed unrestricted, a different account or offer letter had no Title III documentation. Cause: The College did not obtain proper approval by the Director of the program, expenses did not fit into the grant budget line items, approved pay rates were not properly documented as approved Title III expenses for the proper grant period. Effect: The College’s grant disbursements were not properly approved. Questioned Costs: $14,731 Recommendation: We recommend the College strengthen its policies and procedures surrounding payroll and non-payroll grant disbursements to ensure controls are functioning and compliant withfederal regulations. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Show full finding ▾Hide full finding ▴Finding 2025-002 – Allowable Costs and Period of Performance (Significant Deficiency and Noncompliance)- (Partial repeat finding) Information on the Federal Program: U.S. Department of Education, Higher Education – Institutional Aid (Title III), Assistance Listing No. 84.031 Criteria: 2 CFR Part 200 Subpart E establishes cost principles to apply in determining costs under federal awards. Non-federal entities are also required to establish controls over the disbursement process to ensure compliance with allowable cost requirements. In addition, a non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and non-federal entities are also required to establish controls over the disbursement process to ensure compliance with period of performance requirements. [2 CFR sections 200.308, 200.309, and 200.403(h)]. Condition: We selected a sample of 25 non-payroll disbursements and 25 payroll disbursements charged to the grant. There were 44 pay checks tested in the sample of 25; of those 44, nine exceptions were noted. In four instances, there was no documented approved pay rate and in five instances, there was no approval for salary to be charged to the grant number and documentation showed unrestricted, a different account or offer letter had no Title III documentation. Cause: The College did not obtain proper approval by the Director of the program, expenses did not fit into the grant budget line items, approved pay rates were not properly documented as approved Title III expenses for the proper grant period. Effect: The College’s grant disbursements were not properly approved. Questioned Costs: $14,731 Recommendation: We recommend the College strengthen its policies and procedures surrounding payroll and non-payroll grant disbursements to ensure controls are functioning and compliant withfederal regulations. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2025 – 002- Allowable Costs & Period of Performance (Significant Deficiency and Noncompliance) Management’s Response: Management concurs with the above finding, and the Fiscal Service Office will implement corrective action before September 2026. Management acknowledges the process gap as indicated and noted in the above findings. To strengthen policies and procedures surrounding grant disbursements and ensure expenses are properly approved and allowable under the specific grant budget, the Fiscal Service Office along with the Human Resources Department will implement a process to properly document, review, and approve all allowable grant pay rates and salaries.
2024-007
We selected two annual reports submitted during the year to test for controls and compliance. No documentation of review or approval of the reports was available. In addition, amounts reported on one report did not tie to underlying financial support. Cause: The College did not retain documentation of a review and approval of the reports submitted. The College did not submit an accurate report. Effect: The College did not have appropriate review and approval processes in place or documentation. Questioned Costs: None reported Recommendation: We recommend the College strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Show full finding ▾Hide full finding ▴Finding 2025-003 – Reporting (Significant Deficiency and Noncompliance)- (Repeat finding) Information on the Federal Program: U.S. Department of Education, Higher Education – Institutional Aid, Assistance Listing No. 84.031 Criteria: 2 CFR Part 200.328 and 329 establish reporting requirements for non-federal entities that include timely and accurate reporting. Non-federal entities are also required to establish controls over the reporting process to ensure compliance with reporting requirements. Condition: We selected two annual reports submitted during the year to test for controls and compliance. No documentation of review or approval of the reports was available. In addition, amounts reported on one report did not tie to underlying financial support. Cause: The College did not retain documentation of a review and approval of the reports submitted. The College did not submit an accurate report. Effect: The College did not have appropriate review and approval processes in place or documentation. Questioned Costs: None reported Recommendation: We recommend the College strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2025 – 003 - Reporting (Significant Deficiency and Noncompliance) Management’s Response: Management concurs with the above finding, and the Fiscal Service Office will implement corrective action before September 2026. Management acknowledges the process gap as indicated and noted in the above findings. To enhance the effectiveness of internal controls and ensure that all Title III reports are accurate, properly reviewed, and approved prior to submission, the Fiscal Service office will require management to review and sign off as confirmation of approval prior to submission.
2024-009
We tested a sample of 25 withdrawn students. In one instance, the change in status was not reported within the required 60-day time frame. Cause: When the College uploads data to the Clearinghouse, international students are omitted. These students are identified by a specific attribute automatically added to their record when they apply to the College. This student initially submitted an international student application, however, the student is not an international student and the status was updated, but the international student attribute was not removed. As a result, the student was excluded from the Clearinghouse upload for the Fall 2024 term. Effect: The College did not report the student enrollment status change in a timely manner. Questioned Costs: None Recommendation: We recommend the College strengthen its policies and procedures related to enrollment reporting requirements to comply with the regulations. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Show full finding ▾Hide full finding ▴Finding 2025-004 – Special Tests and Provisions – Enrollment Reporting (Significant Deficiency and Noncompliance)- ((Repeat finding) Information on the Federal Program: U.S. Department of Education Student Financial Assistance Cluster Criteria: The NSLDS Enrollment Reporting Guide provides requirements and guidance for reporting enrollment details under the Pell grant and other programs. Institutions must update the Enrollment Reporting Roster for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date and submit the changes electronically through the batch method or the National Student Loan Data System (NSLDS) website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. These changes include reductions or increases in attendance levels, withdrawals, graduations or approved leaves-of-absence.Condition: We tested a sample of 25 withdrawn students. In one instance, the change in status was not reported within the required 60-day time frame. Cause: When the College uploads data to the Clearinghouse, international students are omitted. These students are identified by a specific attribute automatically added to their record when they apply to the College. This student initially submitted an international student application, however, the student is not an international student and the status was updated, but the international student attribute was not removed. As a result, the student was excluded from the Clearinghouse upload for the Fall 2024 term. Effect: The College did not report the student enrollment status change in a timely manner. Questioned Costs: None Recommendation: We recommend the College strengthen its policies and procedures related to enrollment reporting requirements to comply with the regulations. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2025 – 004 - Special Tests and Provisions- Enrollment Reporting (Significant Deficiency and Noncompliance) Management’s Response: Management concurs with the above finding, and the Fiscal Service Office will implement corrective action before September 2026. Management acknowledges the process gap as indicated and noted in the above findings. The Director of Admissions and Records has stated that students who have a student attribute in Banner of INTL will no longer be excluded from the National Student Clearinghouse enrollment reporting upload so as to prevent any reporting issues due to human error when processing admissions applications.
2024-012
FAC accepted this audit on January 20, 2025 — management decision was due July 20, 2025.
We selected a sample of 25 non-payroll disbursements and 25 payroll disbursements charged to the grant. Of the 25 non-payroll, 4 were missing an approval by the Director of Title III Programs and 4 costs were not in the applicable budgets. In addition, 2 were charged to a fund code for a grant period that ended September 30, 2023. There were 44 pay checks tested in the sample of 25; of those 44, 31 exceptions were noted as having an issue around the approved pay rate documentation. In 9 instances, there was no documented approved pay rate, only support provided was a local salary schedule for multiple positions for 6 of the exceptions. In 15 instances, there was no approval for salary to be charged to the grant number and documentation showed unrestricted, a different account or offer letter had no Title III documentation. In 7 instances, the approved pay rate did not agree to actual paycheck report. Cause: The College did not obtain proper approval by the Director of the program, expenses did not fit into the grant budget line items, approved pay rates were not properly documented and the College continued to use funds after the grant period ended based on verbal instruction. Effect: The College’s grant disbursements were not properly approved. Questioned Costs: $35,461 Recommendation: We recommend the College strengthen its policies and procedures surrounding payroll and non-payroll grant disbursements to ensure controls are functioning and compliant with federal regulations Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Show full finding ▾Hide full finding ▴Finding 2024-007 – Allowable Costs & Period of Performance (Material Weakness and Noncompliance) Information on the Federal Program: U.S. Department of Education, Higher Education- Institutional Aid (Title III), Assistance Listing No. 84.031 Criteria: 2 CFR Part 200 Subpart E establishes cost principles to apply in determining costs under federal awards. Non-federal entities are also required to establish controls over the disbursement process to ensure compliance with allowable cost requirements. In addition, a non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308, 200.309, and 200.403(h)). Condition: We selected a sample of 25 non-payroll disbursements and 25 payroll disbursements charged to the grant. Of the 25 non-payroll, 4 were missing an approval by the Director of Title III Programs and 4 costs were not in the applicable budgets. In addition, 2 were charged to a fund code for a grant period that ended September 30, 2023. There were 44 pay checks tested in the sample of 25; of those 44, 31 exceptions were noted as having an issue around the approved pay rate documentation. In 9 instances, there was no documented approved pay rate, only support provided was a local salary schedule for multiple positions for 6 of the exceptions. In 15 instances, there was no approval for salary to be charged to the grant number and documentation showed unrestricted, a different account or offer letter had no Title III documentation. In 7 instances, the approved pay rate did not agree to actual paycheck report. Cause: The College did not obtain proper approval by the Director of the program, expenses did not fit into the grant budget line items, approved pay rates were not properly documented and the College continued to use funds after the grant period ended based on verbal instruction. Effect: The College’s grant disbursements were not properly approved. Questioned Costs: $35,461 Recommendation: We recommend the College strengthen its policies and procedures surrounding payroll and non-payroll grant disbursements to ensure controls are functioning and compliant with federal regulations Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Management's Response: Management concurs with the above finding and will ensure that human resources, fiscal services and Title Ill all have proper approvals, budgets and written authorization of anything that deviates from the approved budget. The corrective action will be implemented immediately and completed by June 2025.
We selected 5 drawdowns for reimbursement made during the year for testing. For 4 drawdowns, there was no documentation of a review of the calculation of the amount to draw or approval to draw down the funds. Cause: The College did not have a review and approval process in place for 9 months of the fiscal year. Effect: The College’s grant reimbursements were not properly approved. Questioned Costs: None reported Recommendation: We recommend the College strengthen its policies and procedures over cash management to ensure controls are properly implemented and working effectively. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Show full finding ▾Hide full finding ▴Finding 2024-008 – Cash Management (Material Weakness and Noncompliance) Information on the Federal Program: U.S. Department of Education, Higher Education- Institutional Aid, Assistance Listing No. 84.031Criteria: 2 CFR Part 200.305 establishes the methods of receiving payment from the federal agency. The College uses the reimbursement method to receive Title III funds. The non-federal entity is also required to design and implement internal controls over the cash management process. Condition: We selected 5 drawdowns for reimbursement made during the year for testing. For 4 drawdowns, there was no documentation of a review of the calculation of the amount to draw or approval to draw down the funds. Cause: The College did not have a review and approval process in place for 9 months of the fiscal year. Effect: The College’s grant reimbursements were not properly approved. Questioned Costs: None reported Recommendation: We recommend the College strengthen its policies and procedures over cash management to ensure controls are properly implemented and working effectively. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Management's Response: Management concurs with the above finding and implementation of proper approval and documentation was completed in July 2024. All required documentation will be attached to each drawdown receipt.
We selected 2 annual reports submitted during the year to test for controls and compliance. No documentation of review or approval of the reports was available. Cause: The College did not retain documentation of a review and approval of Title III reports submitted. Effect: The College did not have appropriate documentation. Questioned Costs: None reported Recommendation: We recommend the College strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Show full finding ▾Hide full finding ▴Finding 2024-009 – Reporting (Significant Deficiency and Noncompliance) Information on the Federal Program: U.S. Department of Education, Higher Education- Institutional Aid, Assistance Listing No. 84.031 Criteria: 2 CFR Part 200.328 & 329 establish reporting requirements for non-federal entities that include timely and accurate reporting. Non-federal entities are also required to establish controls over the reporting process to ensure compliance with reporting requirements. Condition: We selected 2 annual reports submitted during the year to test for controls and compliance. No documentation of review or approval of the reports was available. Cause: The College did not retain documentation of a review and approval of Title III reports submitted. Effect: The College did not have appropriate documentation. Questioned Costs: None reported Recommendation: We recommend the College strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Management's Response: Management concurs with the above finding and all documentation for annual reports will be held and kept as required moving forward. This will be implemented with the 2025 annual report.
We selected 7 vendors for procurement testing. Of those 7, it was noted that one vendor was paid over the micro-purchase threshold and therefore should have obtained price or rate quotes. Cause: The College did not obtain price or rate quotes for this vendor that had provided services for several years. Effect: The College did not have appropriate documentation. Questioned Costs: $24,250 Recommendation: We recommend the College strengthen its policies and procedures over procurement to ensure vendors in the small purchase category are properly procured. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Show full finding ▾Hide full finding ▴Finding 2024-010 – Procurement (Significant Deficiency and Noncompliance) Information on the Federal Program: U.S. Department of Education, Higher Education- Institutional Aid, Assistance Listing No. 84.031 Criteria: 2 CFR 200.317-327 establishes procurement standards for non-federal entities. This includes different requirements based on the amount of purchases made from the vendor during the year. Condition: We selected 7 vendors for procurement testing. Of those 7, it was noted that one vendor was paid over the micro-purchase threshold and therefore should have obtained price or rate quotes. Cause: The College did not obtain price or rate quotes for this vendor that had provided services for several years. Effect: The College did not have appropriate documentation. Questioned Costs: $24,250 Recommendation: We recommend the College strengthen its policies and procedures over procurement to ensure vendors in the small purchase category are properly procured. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Management's Response: Management concurs with the above finding and will ensure that the restricted accountant and purchasing agent receive further training on federal grant purchasing requirements to ensure all purchasing rules are met. Additional approval levels will also be put in place to safeguard required federal purchasing limits. Implementation will be completed by June 2025.
Documentation of a physical inventory performed college-wide was not available. Cause: The College did not perform a physical inventory of assets purchased with federal funds in the last 2 years. Effect: The College did not have appropriate documentation that a physical inventory was performed. Questioned Costs: None Recommendation: We recommend the College strengthen its policies and procedures over equipment management to ensure a physical inventory is performed every 2 years, at a minimum. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Show full finding ▾Hide full finding ▴Finding 2024-011 – Equipment Management (Significant Deficiency and Noncompliance) Information on the Federal Program: U.S. Department of Education, Higher Education- Institutional Aid, Assistance Listing No. 84.031 Criteria: 2 CFR Section 200.313(d)(2) establishes the requirement that a physical inventory of property must be taken and the results reconciled with the property records at least every 2 years. Condition: Documentation of a physical inventory performed college-wide was not available. Cause: The College did not perform a physical inventory of assets purchased with federal funds in the last 2 years. Effect: The College did not have appropriate documentation that a physical inventory was performed. Questioned Costs: None Recommendation: We recommend the College strengthen its policies and procedures over equipment management to ensure a physical inventory is performed every 2 years, at a minimum. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Management's Response: Management concurs with the above finding and notes that an annual physical inventory is done. Moving forward all federal equipment housed in a separate inventory system will be included in the annual physical inventory process. In addition, the tracking and monitoring of these assets will be brought to the asset manager within the fiscal services office. Action will be taken immediately and completed by June 2025.
We tested a sample of 25 withdrawn students. In 5 instances, the change in status was not reported within the required 60-day time frame. Cause: Unofficial withdraws from the College are not determined until after the end of the semester. Based on current procedures, these student status changes were not included in the last report of the semester and the next reporting submission was not submitted timely. Effect: The College did not report the student enrollment status change in a timely manner. Questioned Costs: None Recommendation: We recommend the College strengthen its policies and procedures related to enrollment reporting requirements to comply with the regulations. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Show full finding ▾Hide full finding ▴Finding 2024-012 – Special Tests and Provisions- Enrollment Reporting (Significant Deficiency and Noncompliance) Information on the Federal Program: U.S. Department of Education Student Financial Aid Cluster Criteria: The NSLDS Enrollment Reporting Guide provides requirements and guidance for reporting enrollment details under the Pell grant and other programs. Institutions must update the Enrollment Reporting Roster for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date and submit the changes electronically through the batch method or the National Student Loan Data System (NSLDS) website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. These changes include reductions or increases in attendance levels, withdrawals, graduations or approved leaves-of-absence. Condition: We tested a sample of 25 withdrawn students. In 5 instances, the change in status was not reported within the required 60-day time frame. Cause: Unofficial withdraws from the College are not determined until after the end of the semester. Based on current procedures, these student status changes were not included in the last report of the semester and the next reporting submission was not submitted timely. Effect: The College did not report the student enrollment status change in a timely manner. Questioned Costs: None Recommendation: We recommend the College strengthen its policies and procedures related to enrollment reporting requirements to comply with the regulations. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Management's Response: Management concurs with the audit finding above. The Director of Admissions & Records has worked with the Audit Resource team at NSC to work through a process to ensure that unofficial withdrawals are accurately captured from Banner and reported in a timely manner. The NSC specialist helped the college set up an additional "subsequent of term" submission roughly 30 days after the end of the semester but prior to the first upload of the following semester. As a nonattendance taking institution, this timeframe will allow the college a chance to make withdrawal determinations for students who did not officially withdraw but stopped attending at some point in the semester and code them appropriately in Banner. This action has occurred, been tested and implemented as of January 2025.
FAC accepted this audit on April 10, 2023 — management decision was due October 10, 2023.
Reference Number: 2022-002 Compliance Requirement: Reporting Type of Finding: Internal Control and Compliance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Assistance Listing Number(s) and Title: 84.425 ? Higher Education Emergency Relief Fund(HEERF) Federal Awarding Agency: U.S. Department of Education As specified in 2 CFR section 200.303 the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Adequate controls must be in place to ensure proper expenditures are reported in the applicable reporting periods. Adequate controls were not in place to review and approve grant reports for accuracy and completeness of the report prior to their submission to the grantor. Appropriate supporting documentation was not retained in order to reconcile the amounts reported on the HEERF I, II, & III Annual Performance Report Form to the College?s books of record. The College also failed to submit quarterly reports on a timely basis for the quarters ending December 31, 2021, March 31, 2022 and June 30, 2022. Lack of sufficient controls over the review and approval of grant reports to ensure the accuracy and completeness of the report being submitted to the grantor can result in improper reporting which could lead to disallowed costs and late reporting submissions. However, our audit disclosed no instances of unallowable costs. Lack of sufficient controls can result in improper reporting which could lead to late reporting submissions. Recommendation We recommend the strengthening of controls to ensure the quarterly grant reports are reviewed and approved for accuracy and completeness prior to submission to the grantor. The College should design and implement internal controls to ensure compliance with the federal reporting requirements. Views of Responsible Officials of the Auditee The College agrees with Finding 2022-002.
Show full finding ▾Hide full finding ▴Reference Number: 2022-002 Compliance Requirement: Reporting Type of Finding: Internal Control and Compliance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Assistance Listing Number(s) and Title: 84.425 ? Higher Education Emergency Relief Fund(HEERF) Federal Awarding Agency: U.S. Department of Education As specified in 2 CFR section 200.303 the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Adequate controls must be in place to ensure proper expenditures are reported in the applicable reporting periods. Adequate controls were not in place to review and approve grant reports for accuracy and completeness of the report prior to their submission to the grantor. Appropriate supporting documentation was not retained in order to reconcile the amounts reported on the HEERF I, II, & III Annual Performance Report Form to the College?s books of record. The College also failed to submit quarterly reports on a timely basis for the quarters ending December 31, 2021, March 31, 2022 and June 30, 2022. Lack of sufficient controls over the review and approval of grant reports to ensure the accuracy and completeness of the report being submitted to the grantor can result in improper reporting which could lead to disallowed costs and late reporting submissions. However, our audit disclosed no instances of unallowable costs. Lack of sufficient controls can result in improper reporting which could lead to late reporting submissions. Recommendation We recommend the strengthening of controls to ensure the quarterly grant reports are reviewed and approved for accuracy and completeness prior to submission to the grantor. The College should design and implement internal controls to ensure compliance with the federal reporting requirements. Views of Responsible Officials of the Auditee The College agrees with Finding 2022-002.
Reference Number: 2022-002 Compliance Requirement: Reporting Type of Finding: Internal Control and Compliance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Assistance Listing Number(s) and Title: 84.425 ? Higher Education Emergency Relief Fund(HEERF) Federal Awarding Agency: U.S. Department of Education Bishop State has reviewed and recognized the needed changes to be put into place to ensure timely reporting and accurate record keeping for all reported data. Bishop State has the Restricted accountant complete the quarterly and annual HEERF reports and file all data according to the report in an organized and methodical method. Once the Restricted Accountant completes the report the Chief Financial Officer and/or Director of Accounting will review the reports and backup data for approval. Once the reports are approved they are handed over to the Grants Administrator for filing on-line with the Department of Education via the HEERF site. This audit finding is a duplicate to the audit finding 2021-005 from the previous fiscal year. The 2022 fiscal year was 75% of the way over at the time the prior year audit finding was presented to Bishop State Community College. At the point of notification all quarterly and annual reports were filed according to HEERF uniform guidance. No other corrective action had to be taken in the 2022 fiscal year as all other uniform reporting guidance was met for the 2022 audit. Anticipated Completion Date: October 2022. Contact Person: Jessica Davis, Chief Financial Officer
2021-005
FAC accepted this audit on June 29, 2022 — management decision was due December 29, 2022.
Reference Number 2021-005 Compliance Requirement: Reporting Type of Finding: Internal Control/Compliance Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Assistance Listing Number(s) and Title: 84.425 ? Higher Education Emergency Relief Fund (HEERF) Federal Awarding Agency: U. S. Department of Education Federal Award Numbers: P425E200753, P425F204354, P425J200100 Pass-Through Entity: None Pass-Through Award Number: None Questioned Costs: None The College failed to submit all of the required quarterly reports due for COVID-19 HEERF reporting. Finding The Coronavirus Aid, Relief, and Economic Security (CARES) Act, Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA), and the American Rescue Plan (ARP) established and funded the Higher Education Emergency Relief Fund (HEERF). The reporting requirements for HEERF funding include a Quarterly Budget and Expenditure Report (QBER). Expenditures of awards funded by HEERF I, II, III Sections 18004(a)(1) Institutional Portion, 18004(a)(2), and 18004(a)(3) should be reported using the QBER form developed by the grantor. The form is required to be posted on the institution?s primary website. In addition, the HEERF Student Aid Portion public reporting requirements require quarterly reports containing data elements to be publicly posted. The College was awarded an Institutional Portion grant under 18004(a)(1) and a Historically Black Colleges and Universities (HBCU) grant under 18004(a)(2). Each of the College's quarterly reports during the fiscal year were selected for review. Due to a lack of properly designed and implemented internal controls, the college failed to submit and post quarterly reports for quarters ended December 31, 2020, June 30, 2021, and September 30, 2021. In addition, the college failed to post to their website any quarterly student data for the fiscal year ended 2021. Recommendation The College should design and implement internal controls to ensure compliance with the federal reporting requirements and prepare and post the required quarterly reports for the HEERF Grants. Views of Responsible Officials of the Auditee Bishop State Community College agrees to Finding 2021-005.
Show full finding ▾Hide full finding ▴Reference Number 2021-005 Compliance Requirement: Reporting Type of Finding: Internal Control/Compliance Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Assistance Listing Number(s) and Title: 84.425 ? Higher Education Emergency Relief Fund (HEERF) Federal Awarding Agency: U. S. Department of Education Federal Award Numbers: P425E200753, P425F204354, P425J200100 Pass-Through Entity: None Pass-Through Award Number: None Questioned Costs: None The College failed to submit all of the required quarterly reports due for COVID-19 HEERF reporting. Finding The Coronavirus Aid, Relief, and Economic Security (CARES) Act, Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA), and the American Rescue Plan (ARP) established and funded the Higher Education Emergency Relief Fund (HEERF). The reporting requirements for HEERF funding include a Quarterly Budget and Expenditure Report (QBER). Expenditures of awards funded by HEERF I, II, III Sections 18004(a)(1) Institutional Portion, 18004(a)(2), and 18004(a)(3) should be reported using the QBER form developed by the grantor. The form is required to be posted on the institution?s primary website. In addition, the HEERF Student Aid Portion public reporting requirements require quarterly reports containing data elements to be publicly posted. The College was awarded an Institutional Portion grant under 18004(a)(1) and a Historically Black Colleges and Universities (HBCU) grant under 18004(a)(2). Each of the College's quarterly reports during the fiscal year were selected for review. Due to a lack of properly designed and implemented internal controls, the college failed to submit and post quarterly reports for quarters ended December 31, 2020, June 30, 2021, and September 30, 2021. In addition, the college failed to post to their website any quarterly student data for the fiscal year ended 2021. Recommendation The College should design and implement internal controls to ensure compliance with the federal reporting requirements and prepare and post the required quarterly reports for the HEERF Grants. Views of Responsible Officials of the Auditee Bishop State Community College agrees to Finding 2021-005.
Corrective Action Plan The College recognizes it did not meet deadlines of required HEERF reporting. Staffing changes lead to items not being done. A new Grant Administrator is in place and all reporting will be done on time moving forward. All past quarterly reports are now available on Bishop State website and the Grant Administrator is working to meet reporting deadlines. Anticipated Completion Date: June, 2022 Contact Person(s): Jessica Davis, Chief Financial Officer Melisa Gaither, Grant Administrator
Reference Number Compliance Requirement: 2021-006 Procurement and Suspension/Debarment Type of Finding: Internal Control/Compliance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Assistance Listing Number(s) and Title: 84.425 COVID-19 Higher Education Emergency Relief Fund (HEERF) Federal Awarding Agency: U. S. Department of Education Federal Award Numbers: P425E200753, P425F204354, P425J200100 Pass-Through Entity: None Pass-Through Award Number: None Questioned Costs: $72,390 The College failed to obtain multiple price quotes for purchases made with federal funds in amounts between the micro-purchase threshold ($10,000) and the Alabama Competitive Bid Law threshold ($15,000). Finding Title 2 U. S. Code of Federal Regulations (CFR) Part 200, codifies the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance). Section 200.320 describes the methods of procurement to be followed. This guidance includes procedures for small purchases. Small purchases are purchases higher than the micro purchase threshold but not exceeding the simplified acquisition threshold. During the 2021 fiscal year, the thresholds were $10,000 and $250,000, respectively. When small purchase procedures are used, price or rate quotations should be obtained from an adequate number of sources. However, Section 200.18(a) states, ?The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward?? 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, and the lease of materials, equipment, supplies, or other personal property where the lessee is, or becomes legally and contractually, bound under the terms of the lease, to pay a total amount of 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?? Since the College must also comply with state law, small purchase procedures can only be used for purchases between the micro-purchase threshold ($10,000) and the threshold set by the Alabama Competitive Bid Law ($15,000). 2 CFR Section 200.320(c) states, ?Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold; (2) The item is only available from a single source; (3) The public exigency or emergency will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate.? Section 200.318(i) states, ?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.? Due to a lack of properly implemented internal controls regarding the procurement process, the College awarded three contracts, in the total amount of $72,390, without obtaining price or rate quotations from an adequate number of sources. If the purchases qualified for non-competitive proposals, records sufficient to detail the history of the procurement were not maintained. Recommendation The College should design and implement internal controls to ensure compliance with the Uniform Guidance and the Code of Alabama 1975, Section 41-16-50(a) requirements related to procurement transactions. Views of Responsible Officials of the Auditee Bishop State Community College agrees to Finding 2021-006.
Show full finding ▾Hide full finding ▴Reference Number Compliance Requirement: 2021-006 Procurement and Suspension/Debarment Type of Finding: Internal Control/Compliance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Assistance Listing Number(s) and Title: 84.425 COVID-19 Higher Education Emergency Relief Fund (HEERF) Federal Awarding Agency: U. S. Department of Education Federal Award Numbers: P425E200753, P425F204354, P425J200100 Pass-Through Entity: None Pass-Through Award Number: None Questioned Costs: $72,390 The College failed to obtain multiple price quotes for purchases made with federal funds in amounts between the micro-purchase threshold ($10,000) and the Alabama Competitive Bid Law threshold ($15,000). Finding Title 2 U. S. Code of Federal Regulations (CFR) Part 200, codifies the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance). Section 200.320 describes the methods of procurement to be followed. This guidance includes procedures for small purchases. Small purchases are purchases higher than the micro purchase threshold but not exceeding the simplified acquisition threshold. During the 2021 fiscal year, the thresholds were $10,000 and $250,000, respectively. When small purchase procedures are used, price or rate quotations should be obtained from an adequate number of sources. However, Section 200.18(a) states, ?The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward?? 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, and the lease of materials, equipment, supplies, or other personal property where the lessee is, or becomes legally and contractually, bound under the terms of the lease, to pay a total amount of 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?? Since the College must also comply with state law, small purchase procedures can only be used for purchases between the micro-purchase threshold ($10,000) and the threshold set by the Alabama Competitive Bid Law ($15,000). 2 CFR Section 200.320(c) states, ?Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold; (2) The item is only available from a single source; (3) The public exigency or emergency will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate.? Section 200.318(i) states, ?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.? Due to a lack of properly implemented internal controls regarding the procurement process, the College awarded three contracts, in the total amount of $72,390, without obtaining price or rate quotations from an adequate number of sources. If the purchases qualified for non-competitive proposals, records sufficient to detail the history of the procurement were not maintained. Recommendation The College should design and implement internal controls to ensure compliance with the Uniform Guidance and the Code of Alabama 1975, Section 41-16-50(a) requirements related to procurement transactions. Views of Responsible Officials of the Auditee Bishop State Community College agrees to Finding 2021-006.
Corrective Action Plan The College recognizes two purchasing issues occurred with HEERF funding. The purchasing of safety services during the pandemic to control people in and out of the buildings was first placed on the security firm that secured the bid, however due to the pandemic they were not able to full fill the obligations of the bid and a second service had to be secured quickly for the health and safety of all employees and students on-site at Bishop State Community College. The additional purchases made it through in error and corrective action has been taken to remedy the likelihood of it occurring again. A purchasing agent has been employed to monitor the volume of all spending and control vendor selection. Anticipated Completion Date: January 2022 Contact Person(s): Jessica Davis, Chief Financial Officer Rhonda Williams, Purchasing Agent
FAC accepted this audit on December 20, 2021 — management decision was due June 20, 2022.
Reference Number: 2020-003 Compliance Requirement: Cash Management Type of Finding: Internal Control Internal Control Impact: Significant Deficiency Compliance Impact: None CFDA Number(s) and Title: 84.063 ? Federal Pell Grant Program 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work-Study Program Federal Awarding Agency: U. S. Department of Education Federal Award Number: P063P191045 P007A190062 P033A190062 Pass-through Entity: N/A Pass-through Award Number: N/A Questioned Costs: None The College did not reconcile the amounts recorded for student Title IV aid on the Department of Education systems with amounts recorded for student Title IV aid in the College?s general ledger. Finding Title 34 of the Code of Federal Regulations (CFR) 668 Subpart L ? Financial Responsibility and the Financial Student Aid (FSA) Handbook discuss an institution?s financial responsibility and the required reconciliation process. 34 CFR 668.171(a) states, ?To begin and continue to participate in any Title IV, HEA program, an institution must demonstrate to the Secretary that it is financially responsible??. The FSA Handbook states, ?The cash management regulations establish rules and procedures that a school must follow in requesting, managing, and returning FSA program funds. Under the cash management regulations, a school has a fiduciary responsibility to have a system in place to: safeguard FSA funds; ensure FSA funds are used only for the purposes intended; act on the student?s behalf to repay a student?s FSA education loan debt when the school is unable to pay a credit balance directly to the student; and return to the Department any FSA funds that cannot be used as intended.? A key component of the system described is a reconciliation. The U. S. Department of Education has three systems that are involved in the reconciliation process. The Common Origination and Disbursement System (COD) which is the system used for processing, storing, and reconciling certain FSA programs. The G5 System is a grants management system. Among other things, the system is used for awards and payments. Finally, the National Student Loan Data Systems (NSLDS) is the Department?s central data base for student aid. NSLDS receives data from schools, guaranty agencies, the Direct Loan program, and other Department of Education programs. The FSA Handbook states, ?Title IV reconciliation is the process by which a school reviews and compares Title IV aid (grants, loans, and Campus-Based aid) recorded on the Department?s systems (COD, G5, NSLDS) with the information in the school?s internal records. Through reconciliation, disbursement and cash discrepancies are identified and resolved in a timely manner to ensure the school meets all regulatory requirements. Schools must document their reconciliation process and retain any reconciliation documentation for audit and review purposes.? Due to a lack of properly implemented internal controls, the College did not reconcile Title IV Pell Grant Program and Campus Based Program amounts recorded on the Department?s system with amounts recorded in the general ledger. This caused the Pell grant payments on the general ledger to be $15,332.41 less than COD. Also, the Federal Supplemental Educational Opportunity Grant payments recorded on the general ledger were $1,672.95 less than the amount reported on the Fiscal Operations Report and Application to Participate (FISAP) for administrative costs. Recommendation The College should design and implement internal controls to ensure that the amounts recorded for student Title IV aid on the Department of Education systems (COD, G5, NSDLS) are reconciled with amounts recorded for student Title IV aid in the College?s general ledger. Views of Responsible Officials of the Auditee Management agrees with this finding and will take corrective actions.
Show full finding ▾Hide full finding ▴Reference Number: 2020-003 Compliance Requirement: Cash Management Type of Finding: Internal Control Internal Control Impact: Significant Deficiency Compliance Impact: None CFDA Number(s) and Title: 84.063 ? Federal Pell Grant Program 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work-Study Program Federal Awarding Agency: U. S. Department of Education Federal Award Number: P063P191045 P007A190062 P033A190062 Pass-through Entity: N/A Pass-through Award Number: N/A Questioned Costs: None The College did not reconcile the amounts recorded for student Title IV aid on the Department of Education systems with amounts recorded for student Title IV aid in the College?s general ledger. Finding Title 34 of the Code of Federal Regulations (CFR) 668 Subpart L ? Financial Responsibility and the Financial Student Aid (FSA) Handbook discuss an institution?s financial responsibility and the required reconciliation process. 34 CFR 668.171(a) states, ?To begin and continue to participate in any Title IV, HEA program, an institution must demonstrate to the Secretary that it is financially responsible??. The FSA Handbook states, ?The cash management regulations establish rules and procedures that a school must follow in requesting, managing, and returning FSA program funds. Under the cash management regulations, a school has a fiduciary responsibility to have a system in place to: safeguard FSA funds; ensure FSA funds are used only for the purposes intended; act on the student?s behalf to repay a student?s FSA education loan debt when the school is unable to pay a credit balance directly to the student; and return to the Department any FSA funds that cannot be used as intended.? A key component of the system described is a reconciliation. The U. S. Department of Education has three systems that are involved in the reconciliation process. The Common Origination and Disbursement System (COD) which is the system used for processing, storing, and reconciling certain FSA programs. The G5 System is a grants management system. Among other things, the system is used for awards and payments. Finally, the National Student Loan Data Systems (NSLDS) is the Department?s central data base for student aid. NSLDS receives data from schools, guaranty agencies, the Direct Loan program, and other Department of Education programs. The FSA Handbook states, ?Title IV reconciliation is the process by which a school reviews and compares Title IV aid (grants, loans, and Campus-Based aid) recorded on the Department?s systems (COD, G5, NSLDS) with the information in the school?s internal records. Through reconciliation, disbursement and cash discrepancies are identified and resolved in a timely manner to ensure the school meets all regulatory requirements. Schools must document their reconciliation process and retain any reconciliation documentation for audit and review purposes.? Due to a lack of properly implemented internal controls, the College did not reconcile Title IV Pell Grant Program and Campus Based Program amounts recorded on the Department?s system with amounts recorded in the general ledger. This caused the Pell grant payments on the general ledger to be $15,332.41 less than COD. Also, the Federal Supplemental Educational Opportunity Grant payments recorded on the general ledger were $1,672.95 less than the amount reported on the Fiscal Operations Report and Application to Participate (FISAP) for administrative costs. Recommendation The College should design and implement internal controls to ensure that the amounts recorded for student Title IV aid on the Department of Education systems (COD, G5, NSDLS) are reconciled with amounts recorded for student Title IV aid in the College?s general ledger. Views of Responsible Officials of the Auditee Management agrees with this finding and will take corrective actions.
Corrective Action Plan The College has reviewed Title 34 of the Code of Federal Regulations (CFR) 668 Subpart L ? Financial Responsibility and the Financial Student Aid (FSA) Handbook discuss an institution?s financial responsibility and the required reconciliation process. 34 CFR 668.171 and has employed a restricted fund accountant that is responsible for the monthly reconciliation of all restricted accounts to include all federal title iv funds, as well as all other federal and state grant funds. Anticipated Completion Date: Correction started in March 2021 and has been completed. Contact Person(s): Waconda Towner, Restricted Fund Accountant (251) 405-7050 wtowner@bishop.edu Kelly Little, Director of Accounting (251) 405-7059 klittle@bishop.edu
Reference Number: 2020-004 Compliance Requirement: Reporting Type of Finding: Compliance/Internal Control Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance CFDA Number(s) and Title: 84.063 ? Federal Pell Grant Program 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work-Study Program Federal Awarding Agency: U. S. Department of Education Federal Award Number: P063P191045, P007A190062, P033A190062 Pass-through Entity: N/A Pass-through Award Number: N/A Questioned Costs: None The College failed to submit disbursements and/or adjustments of disbursements of Pell Grant funds within in the required timeframe. Finding Federal Register, Volume 84, Number 212 states, "An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement". The Common Origination and Disbursement (COD) System is the federal system through which Federal Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan and TEACH Grant awards are processed. During the review of Federal Student Aid Pell Grant disbursement records, 25 COD records for which disbursements and adjustments were necessary were tested due to activity on these accounts. The review indicated that six of the twenty-five (24%) COD records were not submitted to COD within the 15-day requirement. The College did not have adequate controls in place to ensure disbursements or adjustments to disbursements were made within the required timeframe. Failure to submit disbursement records within the required timeframe could result in the rejection of all or part of the reported disbursement. Recommendation The College should develop controls to ensure compliance with Federal Grant Program regulations and submit student disbursement records within the required timeframe. Views of Responsible Officials of the Auditee Management agrees with this finding and will take corrective actions.
Show full finding ▾Hide full finding ▴Reference Number: 2020-004 Compliance Requirement: Reporting Type of Finding: Compliance/Internal Control Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance CFDA Number(s) and Title: 84.063 ? Federal Pell Grant Program 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work-Study Program Federal Awarding Agency: U. S. Department of Education Federal Award Number: P063P191045, P007A190062, P033A190062 Pass-through Entity: N/A Pass-through Award Number: N/A Questioned Costs: None The College failed to submit disbursements and/or adjustments of disbursements of Pell Grant funds within in the required timeframe. Finding Federal Register, Volume 84, Number 212 states, "An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement". The Common Origination and Disbursement (COD) System is the federal system through which Federal Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan and TEACH Grant awards are processed. During the review of Federal Student Aid Pell Grant disbursement records, 25 COD records for which disbursements and adjustments were necessary were tested due to activity on these accounts. The review indicated that six of the twenty-five (24%) COD records were not submitted to COD within the 15-day requirement. The College did not have adequate controls in place to ensure disbursements or adjustments to disbursements were made within the required timeframe. Failure to submit disbursement records within the required timeframe could result in the rejection of all or part of the reported disbursement. Recommendation The College should develop controls to ensure compliance with Federal Grant Program regulations and submit student disbursement records within the required timeframe. Views of Responsible Officials of the Auditee Management agrees with this finding and will take corrective actions.
Corrective Action Plan The College has reviewed Federal Register, Volume 84, number 212 and has undergone a system wide software conversion. In the conversion, the College acquired software that communicates with COD nightly and kicks out any errors or issues each morning, minimizing potential reporting time delays. Monthly reconciliation and open lines of communication between a new Accounts Receivable Accountant and the Financial Aid office staff will also prevent excessive time delays. Anticipated Completion Date: Corrective action occurred at time of conversion on to a new ERP system In July 2020. The new ERP system allows for smooth and timely reporting to the federal systems and provides daily reports of any errors or adjustments. Contact Person(s): Cynthia White, Accounts Receivable Accountant (251) 405-7016 cwhite@bishop.edu Dr. Gail Beggs, Financial Aid Director
Reference Number: 2020-005 Compliance Requirement: Eligibility Type of Finding: Compliance/Internal Control Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance CFDA Number(s) and Title: 84.007 ? Federal Supplemental Educational Opportunity Grants 84.063 ? Federal Pell Grant Program 84.033 ? Federal Work-Study Program Federal Awarding Agency: U. S. Department of Education Federal Award Number: P007A190062, P0639191045, P033A190062 Pass-through Entity: N/A Pass-through Award Number: N/A Questioned Costs: $1,000.00 The College over-awarded Title IV aid in the amount of $1,000.00 to one student during the 2019-2020 financial assistance award year. Finding 34 CFR, 673.5(a)(1) states, ?An institution may only award or disburse a Federal Perkins loan or an FSEOG to a student if that loan or the FSEOG, combined with the other estimated financial assistance the student receives, does not exceed the student's financial need.? In order to test student eligibility, a random sample of 25 students who received Pell Gants were chosen for testing. Four of these students received Federal Supplemental Educational Opportunity Grants (FSEOG) totaling $2,800. During testing, it was noted that one student was awarded and disbursed aid of $1,185.39 more than the student?s financial need. The amount was made up of FSEOG in the amount of $1,000 and other aid in the amount of $185.39. The over- payment was due to the College awarding and not removing FSEOG funds prior to awarding other aid. Recommendation The College should develop internal controls to ensure compliance with 34 CFR, 673.5(a)(1) in awarding student financial assistance. Views of Responsible Officials of the Auditee Management agrees with this finding and will take corrective actions.
Show full finding ▾Hide full finding ▴Reference Number: 2020-005 Compliance Requirement: Eligibility Type of Finding: Compliance/Internal Control Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance CFDA Number(s) and Title: 84.007 ? Federal Supplemental Educational Opportunity Grants 84.063 ? Federal Pell Grant Program 84.033 ? Federal Work-Study Program Federal Awarding Agency: U. S. Department of Education Federal Award Number: P007A190062, P0639191045, P033A190062 Pass-through Entity: N/A Pass-through Award Number: N/A Questioned Costs: $1,000.00 The College over-awarded Title IV aid in the amount of $1,000.00 to one student during the 2019-2020 financial assistance award year. Finding 34 CFR, 673.5(a)(1) states, ?An institution may only award or disburse a Federal Perkins loan or an FSEOG to a student if that loan or the FSEOG, combined with the other estimated financial assistance the student receives, does not exceed the student's financial need.? In order to test student eligibility, a random sample of 25 students who received Pell Gants were chosen for testing. Four of these students received Federal Supplemental Educational Opportunity Grants (FSEOG) totaling $2,800. During testing, it was noted that one student was awarded and disbursed aid of $1,185.39 more than the student?s financial need. The amount was made up of FSEOG in the amount of $1,000 and other aid in the amount of $185.39. The over- payment was due to the College awarding and not removing FSEOG funds prior to awarding other aid. Recommendation The College should develop internal controls to ensure compliance with 34 CFR, 673.5(a)(1) in awarding student financial assistance. Views of Responsible Officials of the Auditee Management agrees with this finding and will take corrective actions.
Corrective Action Plan The College has undergone a system wide software conversion. In the conversion, the College acquired software that allows for auto-packaging of financial aid funds, including SEOG. Parameters are set within the system to prevent over awards. Since the awarding of SEOG occurs using the software system, this eliminates any over awards attributed to human error. In addition, should an over award occur a report is generated overnight so that immediate action can take place to correct the error. In addition, the Business Office staff and the Financial Aid Office staff communicate regularly to monitor all additional outside funding sources to prevent inadvertent over awards. Anticipated Completion Date: Corrected July 2020, with implementation of Ellucian ERP system. Contact Person(s): Dr. Gail Beggs, Financial Aid Director
Reference Number: 2020-006 Compliance Requirement: Reporting Type of Finding: Compliance/Internal Control Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance CFDA Number(s) and Title: 84.031 ? Higher Education ? Institutional Aid Federal Awarding Agency: U. S. Department of Education Federal Award Number: P031B170069-19 P031B170068-19 P031B150010-19 P031B150009-19 Pass-through Entity: N/A Pass-through Award Number: N/A Questioned Costs: None The College could not provide adequate supporting documentation for annual performance reports submitted for the Higher Education-Institutional Aid program. Finding Title 2 U. S. Code of Federal Regulations (CFR) Part 200.334 of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states, ?financial records, supporting documents, statistical records, and all other non- Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a sub-recipient.? Due to a lack of properly implemented internal controls over the reporting process for the Higher Education ? Institutional Aid annual performance reports, the College could not provide supporting documentation for the financial activity of the grant, nor could the College provide accurate supporting documentation for the enrollment data reported. Failure to properly report grant performance could result in reduced or canceled funding. Recommendation The College should implement internal controls to ensure proper reporting in compliance with the Uniform Guidance, Part 200.334. Views of Responsible Officials of the Auditee Management agrees with this finding and will take corrective actions.
Show full finding ▾Hide full finding ▴Reference Number: 2020-006 Compliance Requirement: Reporting Type of Finding: Compliance/Internal Control Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance CFDA Number(s) and Title: 84.031 ? Higher Education ? Institutional Aid Federal Awarding Agency: U. S. Department of Education Federal Award Number: P031B170069-19 P031B170068-19 P031B150010-19 P031B150009-19 Pass-through Entity: N/A Pass-through Award Number: N/A Questioned Costs: None The College could not provide adequate supporting documentation for annual performance reports submitted for the Higher Education-Institutional Aid program. Finding Title 2 U. S. Code of Federal Regulations (CFR) Part 200.334 of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states, ?financial records, supporting documents, statistical records, and all other non- Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a sub-recipient.? Due to a lack of properly implemented internal controls over the reporting process for the Higher Education ? Institutional Aid annual performance reports, the College could not provide supporting documentation for the financial activity of the grant, nor could the College provide accurate supporting documentation for the enrollment data reported. Failure to properly report grant performance could result in reduced or canceled funding. Recommendation The College should implement internal controls to ensure proper reporting in compliance with the Uniform Guidance, Part 200.334. Views of Responsible Officials of the Auditee Management agrees with this finding and will take corrective actions.
Corrective Action Plan The Office of Title III will house and maintain financial records, supporting documents, statistical records and all other non-Federal entity records pertinent to Title III funds used to complete Annual Performance Reports, including data stored on disc for a period of three years or longer. In addition, hard copies of data used will be secured in the appropriate filing space located in the Office of Title III. Anticipated Completion Date: The implementation date/completion date for the aforementioned Corrective Action Plan is January 10, 2022. Contact Person(s): Reginald Crenshaw, PhD, Director of Title III Funds (251) 405-7231 rcrenshaw@bishop.edu
FAC accepted this audit on June 27, 2017 — management decision was due December 27, 2017.
GSA_MIGRATION
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GSA_MIGRATION
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