EIN: 630641064
UEI: MNM8WLBH5DZ5
Audited by: Warren Averett, LLC
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 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 (46 days ago).
What is a management decision? →FAC accepted this audit on January 27, 2025 — management decision was due July 27, 2025.
Of ten vendors tested, one vendor’s services was not properly bid and one vendor was paid over the micro-purchase threshold and therefore should have obtained price or rate quotes. Cause: The College contracted with a vendor for consulting and then retained them for on-going services. These services were not bid. The other vendor was paid more than the micro-purchase threshold during the year, but price or rate quotes were not obtained for purchases. Effect: The College did not comply with federal procurement requirements for these two exceptions. Questioned Costs: $856,476 Recommendation: We recommend the College strengthen its policies and procedures over procurement to ensure vendors 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 2024-001 – Procurement (Significant Deficiency and Noncompliance) Information on the Federal Program: U.S. Department of Education, Assistance listing # 84.031 Higher Education Institutional Aid 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: Of ten vendors tested, one vendor’s services was not properly bid and one vendor was paid over the micro-purchase threshold and therefore should have obtained price or rate quotes. Cause: The College contracted with a vendor for consulting and then retained them for on-going services. These services were not bid. The other vendor was paid more than the micro-purchase threshold during the year, but price or rate quotes were not obtained for purchases. Effect: The College did not comply with federal procurement requirements for these two exceptions. Questioned Costs: $856,476 Recommendation: We recommend the College strengthen its policies and procedures over procurement to ensure vendors 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: The College will strengthen its policies and procedures over procurement to ensure all procurement threshold requirements are identified and all vendors are properly procured. Anticipated Completion Date: February 28, 2025
We selected a sample of 25 non-payroll disbursements each for Title III and Trio programs and three indirect costs for the Trio program. Of the 25 non-payroll disbursements for Title III, two expenses were allocated but the portion charged to the grant did not tie back to the invoice, two expenses were incurred in the prior fiscal year but recorded as current year expenses, and two types of expenses were not in the applicable budgets. Of the 25 non-payroll disbursements for the Trio Cluster, one type of expense exceeded the budget amount and of the three indirect cost calculations, one was not calculated correctly. Cause: On Title III, the College charged a portion of invoices to the grant but the amount could not be recalculated based on the invoice; meals and subscriptions were charged to the grant but the type of expense was not in the budget; and services were performed or orders were placed in the prior year but recognized as current year expenses. On the Trio Cluster, and equipment expenses were charged to the Trio grant but exceeded the grant budget. The indirect cost calculation included previously recorded indirect costs in the base used to recognize and request reimbursement for allowed percentage. Effect: The College did not comply with the exceptions noted for allowable cost and activity requirements. Questioned Costs: Title III $10,261 and Trio Cluster $4,810. Recommendation: We recommend the College strengthen its policies and procedures surrounding non-payroll grant disbursements to ensure disbursements are approved, allowable, and calculations supported. 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 2024-002 – Allowable Costs & Activities (Significant Deficiency and Noncompliance) Information on the Federal Program: U.S. Department of Education, Assistance listing # 84.031 Higher Education Institutional Aid and U.S. Department of Education, Trio Cluster 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.Condition: We selected a sample of 25 non-payroll disbursements each for Title III and Trio programs and three indirect costs for the Trio program. Of the 25 non-payroll disbursements for Title III, two expenses were allocated but the portion charged to the grant did not tie back to the invoice, two expenses were incurred in the prior fiscal year but recorded as current year expenses, and two types of expenses were not in the applicable budgets. Of the 25 non-payroll disbursements for the Trio Cluster, one type of expense exceeded the budget amount and of the three indirect cost calculations, one was not calculated correctly. Cause: On Title III, the College charged a portion of invoices to the grant but the amount could not be recalculated based on the invoice; meals and subscriptions were charged to the grant but the type of expense was not in the budget; and services were performed or orders were placed in the prior year but recognized as current year expenses. On the Trio Cluster, and equipment expenses were charged to the Trio grant but exceeded the grant budget. The indirect cost calculation included previously recorded indirect costs in the base used to recognize and request reimbursement for allowed percentage. Effect: The College did not comply with the exceptions noted for allowable cost and activity requirements. Questioned Costs: Title III $10,261 and Trio Cluster $4,810. Recommendation: We recommend the College strengthen its policies and procedures surrounding non-payroll grant disbursements to ensure disbursements are approved, allowable, and calculations supported. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Management's Response: The College will strengthen its policies and procedures surrounding non-payroll grant disbursements to ensure disbursements are approved, allowable, and calculations supported. Management will review budgets on a monthly basis to ensure expenses do not exceed the budget. Management will review indirect cost calculations to ensure they are calculated at the correct percentages. Management will review invoices three months past year end to ensure the proper accrual of expenses. Anticipated Completion Date: February 28, 2025
We selected a sample of six payroll disbursements for Title III and eleven payroll disbursements for the Trio programs. Of the six payroll disbursements for Title III, four exceptions were noted related to approved pay rate documentation. In one instance the position was not in the grant budget and in three instances, the approved pay rate did not agree to the actual paycheck amount. Of the eleven payroll disbursements for the Trio Cluster, thirty-two employees were included. Of these thirty-two, twenty-one exceptions were noted for lack of proper support. Nineteen exceptions were noted in which the actual pay rate did not agree to the budgeted pay rate; two employees’ job descriptions did not fall under an allowable position in the grant budget; one journal entry reclassified payroll costs but the support for pay rate and time charged were not provided; and one employee received additional pay over the approved letter of appointment, and there was no support for the percent charged to the program. Cause: Payroll costs charged to the grants were not properly documented. Effect: The College did not comply with all allowable cost and activity requirements. The College did not comply with the exceptions noted for allowable cost and activity requirements. Questioned Costs: Title III $4,119 and Trio Cluster $25,655. Recommendation: We recommend the College strengthen its policies and procedures surrounding payroll grant disbursements to ensure expenses are properly approved and allowable under the specific grant budget. 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 2024-003 – Allowable Costs & Activities (Significant Deficiency and Noncompliance) Information on the Federal Program: U.S. Department of Education, Assistance listing # 84.031 Higher Education Institutional Aid and U.S. Department of Education, Trio Cluster 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. Condition: We selected a sample of six payroll disbursements for Title III and eleven payroll disbursements for the Trio programs. Of the six payroll disbursements for Title III, four exceptions were noted related to approved pay rate documentation. In one instance the position was not in the grant budget and in three instances, the approved pay rate did not agree to the actual paycheck amount. Of the eleven payroll disbursements for the Trio Cluster, thirty-two employees were included. Of these thirty-two, twenty-one exceptions were noted for lack of proper support. Nineteen exceptions were noted in which the actual pay rate did not agree to the budgeted pay rate; two employees’ job descriptions did not fall under an allowable position in the grant budget; one journal entry reclassified payroll costs but the support for pay rate and time charged were not provided; and one employee received additional pay over the approved letter of appointment, and there was no support for the percent charged to the program. Cause: Payroll costs charged to the grants were not properly documented. Effect: The College did not comply with all allowable cost and activity requirements. The College did not comply with the exceptions noted for allowable cost and activity requirements. Questioned Costs: Title III $4,119 and Trio Cluster $25,655. Recommendation: We recommend the College strengthen its policies and procedures surrounding payroll grant disbursements to ensure expenses are properly approved and allowable under the specific grant budget. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Management's Response: The College will strengthen its policies and procedures surrounding payroll grant disbursements to ensure expenses are properly approved and allowable under the specific grant budget. Management will ensure that budgets are amended when changes in pay rates occur during the grant award periods. Anticipated Completion Date: February 28, 2025
FAC accepted this audit on March 27, 2024 — management decision was due September 27, 2024.
We selected a sample of 2 reports submitted for the HEERF program during the year. For both the annual and quarterly report examined, there was no documentation of a control such as reviewing and approving the report prior to submission. In addition, the annual report programmatic data source documentation varied from the data reported for several items. Cause: The College had a team managing the COVID funds due to their unique nature. While they were contact with each other about the program and reports, documentation of a review and approval was not available. The annual report included programmatic accomplishments and the report provided to support the data had several variances. Effect: The College did not properly implement documentation of internal controls to ensure compliance with reporting requirements. Questioned Costs: None reported Recommendation: We recommend the College strengthen its policies and procedures surrounding grant reporting to include documentation of controls such as review and approvals to ensure documentation is retained to support compliance requirements. 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 2023-004 – Reporting (Significant Deficiency and Noncompliance) Information on the federal program: U.S. Department of Education, Assistance listing # 84.425 Education Stabilization Fund Criteria: 2 CFR 200.328-300 establish requirements for designing and monitoring internal controls over reporting requirements of a non-federal entity. Controls should be implemented to ensure accurate and complete reporting compliance. Condition: We selected a sample of 2 reports submitted for the HEERF program during the year. For both the annual and quarterly report examined, there was no documentation of a control such as reviewing and approving the report prior to submission. In addition, the annual report programmatic data source documentation varied from the data reported for several items. Cause: The College had a team managing the COVID funds due to their unique nature. While they were contact with each other about the program and reports, documentation of a review and approval was not available. The annual report included programmatic accomplishments and the report provided to support the data had several variances. Effect: The College did not properly implement documentation of internal controls to ensure compliance with reporting requirements. Questioned Costs: None reported Recommendation: We recommend the College strengthen its policies and procedures surrounding grant reporting to include documentation of controls such as review and approvals to ensure documentation is retained to support compliance requirements. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Management’s Response: The College will strengthen its policies and procedures to ensure documentation of review and approvals for reporting to ensure reporting compliance. Anticipated Completion Date: February 28, 2024
FAC accepted this audit on February 12, 2023 — management decision was due August 12, 2023.
We selected a sample of 10 students who withdrew and were receiving financial aid. Of the 10 students tested, there were seven students with exceptions related to the return of Title IV process. Cause: The College did not return the correct amount of aid earned and/or did not return the aid within 45 days, as required. Effect: The College returned the incorrect amount of financial aid and/or did not return financial aid timely. Questioned Costs: None reported Recommendation: We recommend the College strengthen its policies and procedures surrounding the withdrawal process, especially the return of Title IV process, to accurately to ensure compliance with withdrawal requirements. 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 2022-010 ? Special Tests and Provisions: Withdrawal Testing (Material Weakness and Noncompliance) ? Repeat Finding Information on the federal program: U.S. Department of Education Student Financial Aid Cluster Criteria: 34 CFR part 668 establishes rules governing the student withdrawal process including the determination of the amount of unearned financial aid, calculation of earned Title IV assistance and return of unearned Title IV aid within 45 days. Condition: We selected a sample of 10 students who withdrew and were receiving financial aid. Of the 10 students tested, there were seven students with exceptions related to the return of Title IV process. Cause: The College did not return the correct amount of aid earned and/or did not return the aid within 45 days, as required. Effect: The College returned the incorrect amount of financial aid and/or did not return financial aid timely. Questioned Costs: None reported Recommendation: We recommend the College strengthen its policies and procedures surrounding the withdrawal process, especially the return of Title IV process, to accurately to ensure compliance with withdrawal requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Management's View: The College's term calendar did not properly reflect all semester breaks and holidays resulting in improper return calculations. Moving forward , the College will include all semester breaks and holidays in the calculation. Further, administrative withdrawal procedures were not concise which caused discrepancies in student registration status. The student registration status is key to the calculation of the Title IV funds to be returned to the Department of Education. The discrepancy resolution was outside of the 45-day requirement causing the returns of Title IV funds to be untimely. Corrective Action Plan: The Director Student Financial Services, the Registrar and the Vice President of Instruction will work together to ensure communication and compliance with Faculty regarding administrative withdrawal policy and procedures.
2021-004
FAC accepted this audit on September 12, 2022 — management decision was due March 12, 2023.
Reference Number: 2021-003 Compliance Requirement: Special Tests and Provisions Type of Finding: Internal Control/Compliance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance ALN Numbers and Titles: Student Financial Assistance Cluster 84.063 ? Federal Pell Grant Program 84.007 ? Federal Supplemental Educational Opportunity Grants Federal Awarding Agency: U. S. Department of Education Federal Award Numbers: P063P201058 P007A200045 Pass-through Entity: None Pass-through Award Number: None Questioned Costs: None The College did not disburse Federal Title IV credit balances within the 14 days required by Title 34 of the Code of Federal Regulations Section 668.164. Finding Title 34 of the Code of Federal Regulations (CFR) 668 Subpart K - Cash Management and the Financial Student Aid (FSA) Handbook establishes the disbursement procedures for Title IV, HEA program funds. 34 CFR 668.164(h)(1) states ?A title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period as provided under paragraph (c) of this section?. 34 CFR 668.164 (h)(2) states ?A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than - (i) Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) Fourteen (14) days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.? Due to a lack of properly designed and implemented internal controls, the College did not disburse all Title IV, HEA credit balances within the required timeframe. Forty students with a total of 82 disbursements were tested and it was determined that ten of the disbursements were not made within the 14-day requirement. Recommendation The College should design and implement internal controls to ensure that Title IV, HEA credit balances are disbursed in accordance with 34 CFR 668.164(h)(1) and 34 CFR 668.164(h)(2). 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: 2021-003 Compliance Requirement: Special Tests and Provisions Type of Finding: Internal Control/Compliance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance ALN Numbers and Titles: Student Financial Assistance Cluster 84.063 ? Federal Pell Grant Program 84.007 ? Federal Supplemental Educational Opportunity Grants Federal Awarding Agency: U. S. Department of Education Federal Award Numbers: P063P201058 P007A200045 Pass-through Entity: None Pass-through Award Number: None Questioned Costs: None The College did not disburse Federal Title IV credit balances within the 14 days required by Title 34 of the Code of Federal Regulations Section 668.164. Finding Title 34 of the Code of Federal Regulations (CFR) 668 Subpart K - Cash Management and the Financial Student Aid (FSA) Handbook establishes the disbursement procedures for Title IV, HEA program funds. 34 CFR 668.164(h)(1) states ?A title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period as provided under paragraph (c) of this section?. 34 CFR 668.164 (h)(2) states ?A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than - (i) Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) Fourteen (14) days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.? Due to a lack of properly designed and implemented internal controls, the College did not disburse all Title IV, HEA credit balances within the required timeframe. Forty students with a total of 82 disbursements were tested and it was determined that ten of the disbursements were not made within the 14-day requirement. Recommendation The College should design and implement internal controls to ensure that Title IV, HEA credit balances are disbursed in accordance with 34 CFR 668.164(h)(1) and 34 CFR 668.164(h)(2). Views of Responsible Officials of the Auditee: Management agrees with this finding and will take corrective actions.
Corrective Action Plan: The College will disburse and refund Title IV aid to students within the 14-day regulatory time frame after the credit balance is established on the student account. To ensure that credit balance payments are issued within 14 days, the College will utilize the report detailing credit balances posted on each student account. The Office of Student Financial Services will verify that all credit balances indicated on the report are disbursed by the Business Affairs Office within the required 14-day. The College has developed a system of checks and balances between the Business Affairs Office and the Office of Student Financial Services. Anticipated Completion Date: August, 2022 Contact Person: Cassandra R. Hollins, Director of Student Financial Services
Reference Number: 2021-004 Compliance Requirement: Special Tests and Provisions Type of Finding: Internal Control/Compliance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance ALN Numbers and Titles: Student Financial Assistance Cluster 84.063 ? Federal Pell Grant Program 84.007 ? Federal Supplemental Educational Opportunity Grants Federal Awarding Agency: U. S. Department of Education Federal Award Numbers: P063P201058 P007A200045 Pass-through Entity: None Pass-through Award Number: None Questioned Costs: None The College did not calculate the return Title IV amount properly or within the required timeframe. Finding According to 34 CFR 668.22, when a Title IV grant recipient withdraws from an institution during a period 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 grant assistance that the student earned is less than the amount of Title IV grant assistance that was disbursed to the student, the difference must be returned to the Title IV programs. 34 CFR 668.22 (j) describes the Timeframe for the Return of Title IV Funds: ?An institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution?s determination that the student withdrew... For an institution that is not required to take attendance, an institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of (i) Payment period or period of enrollment, (ii) Academic year in which the student withdrew, or (iii) Education program for which the student withdrew.? Twenty-five return of Title IV calculations were selected for testing. Four returns were completed incorrectly which resulted in a 25% error rate. One of the returns was miscalculated and the College returned $1,135.36 more than required. For the remaining three returns, the College performed a proper calculation for each, but failed to return the Title IV funds resulting in the College returning $1,745.00 less than required. This resulted in known questioned costs of none. In addition, ten errors were noted where the College did not return funds within the 45-day limit which resulted in a 63% error rate. Recommendation The College should perform Title IV refund calculations and return Title IV funds in accordance with Title 34 of the Code of Federal Regulations, Part 668.22. 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: 2021-004 Compliance Requirement: Special Tests and Provisions Type of Finding: Internal Control/Compliance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance ALN Numbers and Titles: Student Financial Assistance Cluster 84.063 ? Federal Pell Grant Program 84.007 ? Federal Supplemental Educational Opportunity Grants Federal Awarding Agency: U. S. Department of Education Federal Award Numbers: P063P201058 P007A200045 Pass-through Entity: None Pass-through Award Number: None Questioned Costs: None The College did not calculate the return Title IV amount properly or within the required timeframe. Finding According to 34 CFR 668.22, when a Title IV grant recipient withdraws from an institution during a period 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 grant assistance that the student earned is less than the amount of Title IV grant assistance that was disbursed to the student, the difference must be returned to the Title IV programs. 34 CFR 668.22 (j) describes the Timeframe for the Return of Title IV Funds: ?An institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution?s determination that the student withdrew... For an institution that is not required to take attendance, an institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of (i) Payment period or period of enrollment, (ii) Academic year in which the student withdrew, or (iii) Education program for which the student withdrew.? Twenty-five return of Title IV calculations were selected for testing. Four returns were completed incorrectly which resulted in a 25% error rate. One of the returns was miscalculated and the College returned $1,135.36 more than required. For the remaining three returns, the College performed a proper calculation for each, but failed to return the Title IV funds resulting in the College returning $1,745.00 less than required. This resulted in known questioned costs of none. In addition, ten errors were noted where the College did not return funds within the 45-day limit which resulted in a 63% error rate. Recommendation The College should perform Title IV refund calculations and return Title IV funds in accordance with Title 34 of the Code of Federal Regulations, Part 668.22. Views of Responsible Officials of the Auditee Management agrees with this finding and will take corrective actions.
Corrective Action Plan: The College will perform Title IV refund calculations and verify the accuracy of all calculations. The Office of Student Financial Services has worked with the Registrar's Office, Academic Affairs leadership, and the Business Affairs Office to streamline the collection, review, and processing of unofficial withdrawals. Streamlining the unofficial withdrawal process will allow for timely and accurate reporting, return of Title IV funds, and reconciliation of funds between the College and Common Origination and Disbursement (COD). Anticipated Completion Date: September, 2022 Contact Person: Cassandra R. Hollins, Director of Student Financial Services
Reference Number: 2021-005 Compliance Requirement: Eligibility Type of Finding: Internal Control/Compliance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance ALN Number and Title: Student Financial Assistance Cluster 84.063 ? Federal Pell Grant Program 84.007 ? Federal Supplemental Educational Opportunity Grants Federal Awarding Agency: U. S. Department of Education Federal Award Numbers: P063P201058 P007A200045 Pass-through Entity: None Pass-through Award Number: None Questioned Costs: $3,174.50 The College failed to properly calculate Title IV disbursements. Finding Title 34 of the Code of Federal Regulations (CFR) Part 690.80 requires the recalculation of a Federal Pell Grant award to account for changes to the student?s cost of attendance, expected family contribution (EFC), or enrollment status. For a change in the student?s enrollment status from one academic term to another term within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period. If a student?s projected enrollment status changes during a payment period before the student begins attendance in all of his or her classes for that payment period, the institution shall recalculate the student?s enrollment status to reflect only those classes for which the student actually began attendance. Forty student records were selected from the population of 2,257 Federal Pell Grant student records for the financial aid award year for testing compliance with Title IV student eligibility requirements. Audit tests performed determined the College failed to properly calculate or recalculate the Federal Pell Grant award based on enrollment or change in enrollment status, as required, for three students. One student was awarded Pell Grant for full-time enrollment but should have only been ? time enrollment. The remaining two student?s enrollment status changed during the registration period from ? time or half-time enrollment to less than half-time however, the Pell Grant award was not recalculated based on the change in enrollment status. It appears the enrollment status change was due to attendance not being verified for the two students in the System. The College could not provide other documentation indicating that the students attended class. This resulted in a Federal Pell Grant over award of $3,174.50. Recommendation The College should recalculate Federal Pell Grant awards in accordance with Title 34 of the Code of Federal Regulations, Part 690.80. 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: 2021-005 Compliance Requirement: Eligibility Type of Finding: Internal Control/Compliance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance ALN Number and Title: Student Financial Assistance Cluster 84.063 ? Federal Pell Grant Program 84.007 ? Federal Supplemental Educational Opportunity Grants Federal Awarding Agency: U. S. Department of Education Federal Award Numbers: P063P201058 P007A200045 Pass-through Entity: None Pass-through Award Number: None Questioned Costs: $3,174.50 The College failed to properly calculate Title IV disbursements. Finding Title 34 of the Code of Federal Regulations (CFR) Part 690.80 requires the recalculation of a Federal Pell Grant award to account for changes to the student?s cost of attendance, expected family contribution (EFC), or enrollment status. For a change in the student?s enrollment status from one academic term to another term within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period. If a student?s projected enrollment status changes during a payment period before the student begins attendance in all of his or her classes for that payment period, the institution shall recalculate the student?s enrollment status to reflect only those classes for which the student actually began attendance. Forty student records were selected from the population of 2,257 Federal Pell Grant student records for the financial aid award year for testing compliance with Title IV student eligibility requirements. Audit tests performed determined the College failed to properly calculate or recalculate the Federal Pell Grant award based on enrollment or change in enrollment status, as required, for three students. One student was awarded Pell Grant for full-time enrollment but should have only been ? time enrollment. The remaining two student?s enrollment status changed during the registration period from ? time or half-time enrollment to less than half-time however, the Pell Grant award was not recalculated based on the change in enrollment status. It appears the enrollment status change was due to attendance not being verified for the two students in the System. The College could not provide other documentation indicating that the students attended class. This resulted in a Federal Pell Grant over award of $3,174.50. Recommendation The College should recalculate Federal Pell Grant awards in accordance with Title 34 of the Code of Federal Regulations, Part 690.80. Views of Responsible Officials of the Auditee Management agrees with this finding and will take corrective actions.
Corrective Action Plan: The College will recalculate the Federal Pell Grant award based on enrollment or change in enrollment status as required by the Title 34 CFR, 690.80. The Office of Student Financial Services will evaluate the Federal Pell Grant eligibility based on the student's current verified enrollment status. The College has multiple instructional terms within a semester. A student's Pell is adjusted based on their enrollment and within these different terms. Before disbursing funds, the College will ensure that different Ellucian/Banner edits are applied and/or review reports from the Ellucian/Banner Argos system to prevent an over award or under award. If the Pell grant award does not match the student current enrollment status, the award will be adjusted. Anticipated Completion: September, 2022 Contact Person: Cassandra R. Hollins, Director of Student Financial Services
FAC accepted this audit on December 5, 2021 — management decision was due June 5, 2022.
Reference Number: 2020-004 Compliance Requirement: Procurement and Suspension/Debarment Type of Finding: Internal Control/Compliance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance CFDA Numbers and Title: 84.425F ? HEERF Institutional Portion 84.425J ? HEERF Historically Black Colleges and Universities (HBCUs) Federal Awarding Agency: U.S. Department of Education Federal Award Numbers: P425F204104 P425J200089 Pass-through Entity: None Pass-through Award Number: None Questioned Costs: $115,715.29 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) and failed to bid purchases over 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 2020 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 200.318(a) stated, ?The Non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part.? 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(f) stated, ?Procurement by non-competitive proposals is procurement through solicitation of a proposal from only one source and may be used only when one or more of the following circumstances apply: (1) The item is available only from a single source; (2) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (3) 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 (4) After solicitation of a number of sources, competition is determined inadequate.? Section 200.318(i) stated, ?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 five contracts, between the amounts of $10,000 and $15,000, during the fiscal year without obtaining price or rate quotations from an adequate number of sources. These purchases totaled $65,135.29. The College also purchased $50,580.00 in promotional supplies without bidding the award under the Code of Alabama 1975, Section 41-16-50(a). If the purchases qualified for non-competitive proposals, records sufficient to detail the history of 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: Management agrees with this finding and will take corrective actions.
Show full finding ▾Hide full finding ▴Reference Number: 2020-004 Compliance Requirement: Procurement and Suspension/Debarment Type of Finding: Internal Control/Compliance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance CFDA Numbers and Title: 84.425F ? HEERF Institutional Portion 84.425J ? HEERF Historically Black Colleges and Universities (HBCUs) Federal Awarding Agency: U.S. Department of Education Federal Award Numbers: P425F204104 P425J200089 Pass-through Entity: None Pass-through Award Number: None Questioned Costs: $115,715.29 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) and failed to bid purchases over 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 2020 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 200.318(a) stated, ?The Non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part.? 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(f) stated, ?Procurement by non-competitive proposals is procurement through solicitation of a proposal from only one source and may be used only when one or more of the following circumstances apply: (1) The item is available only from a single source; (2) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (3) 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 (4) After solicitation of a number of sources, competition is determined inadequate.? Section 200.318(i) stated, ?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 five contracts, between the amounts of $10,000 and $15,000, during the fiscal year without obtaining price or rate quotations from an adequate number of sources. These purchases totaled $65,135.29. The College also purchased $50,580.00 in promotional supplies without bidding the award under the Code of Alabama 1975, Section 41-16-50(a). If the purchases qualified for non-competitive proposals, records sufficient to detail the history of 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: Management agrees with this finding and will take corrective actions.
Corrective Action Plan: The College is knowledgeable of the State of Alabama and Federal purchasing and procurement guidelines and will comply with procurement policies. The College will strengthen its internal controls and follow-up processes to ensure procurement transactions are in compliance with the Uniform Guidance and the Code of Alabama 1975, Section 41-16-50(a). Anticipated Completion Date: August, 2021 Contact Person(s): Sharon S. Crews, Vice President of Administrative & Fiscal Services
Reference Number: 2020-005 Compliance Requirement: Cash Management Type of Finding: Internal Control/Compliance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance CFDA Numbers and Title: 84.063 ? Federal Pell Grant Program 84.007 ? Federal Supplemental Educational Opportunity Grants Federal Awarding Agency: U.S. Department of Education Federal Award Numbers: P063P 191058 P007A190045 Pass-through Entity: None Pass-through Award Number: None Questioned Costs: None The College failed to return outstanding uncashed Pell and SEOG award checks in the amount of $132,309.70 to the Secretary of Education. Finding 34 CFR 668.164(l) and the Financial Student Aid (FSA) Handbook discuss unclaimed FSA funds. The FSA Handbook states, ?A school must return to the Department any FSA program funds, except FWS Program funds, that it attempts to disburse directly to a student or parent if the student or parent does not receive the funds or cash the check. (For FWS funds, a school is required to return only the federal portion of the payroll disbursement.) A school must have a process that ensures FSA funds never escheat to a state or revert to the school or any other third party.? 34 CFR 668.164(l) states, "If a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check." Due to a lack of properly implemented internal controls and a lack of a process to review unclaimed FSA funds, the College has not returned $132,309.70 of uncashed Pell and SEOG student grant award checks to the Secretary of Education. The checks have been outstanding over 240 days with several dating back to 1998. Recommendation The College should design and implement internal controls and implement a process to review unclaimed FSA funds to ensure outstanding uncashed Pell and SEOG Grant funds are properly submitted to the Secretary of Education. 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: Cash Management Type of Finding: Internal Control/Compliance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance CFDA Numbers and Title: 84.063 ? Federal Pell Grant Program 84.007 ? Federal Supplemental Educational Opportunity Grants Federal Awarding Agency: U.S. Department of Education Federal Award Numbers: P063P 191058 P007A190045 Pass-through Entity: None Pass-through Award Number: None Questioned Costs: None The College failed to return outstanding uncashed Pell and SEOG award checks in the amount of $132,309.70 to the Secretary of Education. Finding 34 CFR 668.164(l) and the Financial Student Aid (FSA) Handbook discuss unclaimed FSA funds. The FSA Handbook states, ?A school must return to the Department any FSA program funds, except FWS Program funds, that it attempts to disburse directly to a student or parent if the student or parent does not receive the funds or cash the check. (For FWS funds, a school is required to return only the federal portion of the payroll disbursement.) A school must have a process that ensures FSA funds never escheat to a state or revert to the school or any other third party.? 34 CFR 668.164(l) states, "If a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check." Due to a lack of properly implemented internal controls and a lack of a process to review unclaimed FSA funds, the College has not returned $132,309.70 of uncashed Pell and SEOG student grant award checks to the Secretary of Education. The checks have been outstanding over 240 days with several dating back to 1998. Recommendation The College should design and implement internal controls and implement a process to review unclaimed FSA funds to ensure outstanding uncashed Pell and SEOG Grant funds are properly submitted to the Secretary of Education. Views of Responsible Officials of the Auditee: Management agrees with this finding and will take corrective actions.
Corrective Action Plan: The College has reviewed the guidance on unclaimed FSA funds. The College has subsequently updated its internal controls and processes related to outstanding student checks. The College continues to reconcile its Title IV funds between the COD, FISAP and Business Office and believe all accounts are balanced. The College will continue to review and improve its internal controls and processes utilizing the Banner software platform to ensure that outstanding uncashed PELL and SEOG Grant funds are properly identified, resolved and submitted to the Secretary of Education. Anticipated Completion Date: September, 2021 Contact Person(s): Monique Silas, Director of Accounting
FAC accepted this audit on November 8, 2020 — management decision was due May 8, 2021.
FAC accepted this audit on April 11, 2019 — management decision was due October 11, 2019.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on June 26, 2018 — management decision was due December 26, 2018.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on June 21, 2017 — management decision was due December 21, 2017.
GSA_MIGRATION
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GSA_MIGRATION
2015-002
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