EIN: 631102108
UEI: QFFCJG7MKFK5
Data as of August 23, 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 (38 days ago).
What is a management decision? →We selected a sample of 25 payroll charges, containing 57 employees. Of those 57, 2 exceptions were noted related to documentation. One employee’s last letter of appointment indicated the position was 100% TRIO; however, the employee was allocated only at 50%, and their new allocation was not documented in a new letter of appointment. And one employee had more than one position but the additional position added letter of appointment or change of status was not provided. Cause: The College has established policies and procedures to prepare letters of appointment and change of status forms to ensure payroll is properly documented as to amount and funding source. These forms are approved by the College President. Letters of appointment were not updated per policy to align with actual grant charges and other records such as emails and spreadsheets were provided contemporaneously to support the allowability of the costs. Effect: Key controls over payroll documentation and adherence to policies and procedures were not operating effectively. Questioned Costs: none Recommendation: We recommend the College adhere to its policies and procedures surrounding the payroll process. Payroll costs funded by federal funds should be adequately documented as to allowability and employees’ total pay documented, reviewed and approved. 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 2025-001 – Allowable Costs (Significant Deficiency and Noncompliance) Information on the Federal Program: U.S. Department of Education, TRIO Cluster Criteria: 2 CFR 200 Subpart E establishes cost principles to apply in determining costs under federal awards. Nonfederal 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 payroll charges, containing 57 employees. Of those 57, 2 exceptions were noted related to documentation. One employee’s last letter of appointment indicated the position was 100% TRIO; however, the employee was allocated only at 50%, and their new allocation was not documented in a new letter of appointment. And one employee had more than one position but the additional position added letter of appointment or change of status was not provided. Cause: The College has established policies and procedures to prepare letters of appointment and change of status forms to ensure payroll is properly documented as to amount and funding source. These forms are approved by the College President. Letters of appointment were not updated per policy to align with actual grant charges and other records such as emails and spreadsheets were provided contemporaneously to support the allowability of the costs. Effect: Key controls over payroll documentation and adherence to policies and procedures were not operating effectively. Questioned Costs: none Recommendation: We recommend the College adhere to its policies and procedures surrounding the payroll process. Payroll costs funded by federal funds should be adequately documented as to allowability and employees’ total pay documented, reviewed and approved. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2025-001 – Allowable Costs (Significant Deficiency and Noncompliance) Information on the Federal Program: U.S. Department of Education, Trio Cluster Criteria: 2 CFR 200 Subpart E establishes cost principles to apply in determining costs under federal awards. Nonfederal 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 payroll charges, containing 57 employees. Of those 57, 2 exceptions were noted related to documentation. One employee’s last letter of appointment indicated the position was 100% Trio; however, the employee was allocated only at 50%, and their new allocation was not documented in a new letter of appointment. And one employee had more than one position but the additional position added letter of appointment or change of status was not provided. Management’s Response: The 2 exceptions noted were documented and had appropriate approvals. However, the form of the documentation was not the form listed in the local procedures. Bevill State will ensure that the form of the documentation and the local procedures are consistent moving forward. Anticipated Completion Date: February 28, 2026
2024-002
FAC accepted this audit on January 21, 2025 — management decision was due July 21, 2025.
We selected a sample of 24 reimbursement draw downs made during the year through the G5 payment system. Procedures were in place to accumulate expenses based on approved invoices and draw the reimbursement amount down through G5, however, documentation of review and approval of amounts to be drawn was not available. Cause: The College did not document the review and approval of the calculated reimbursement before it was drawn down. Effect: Key controls over cash management were not operating effectively. Questioned Costs: None reported Recommendation: We recommend the College strengthen its policies and procedures to properly design and implement controls over the draw down process. 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 – Cash Management (Material Weakness) Information on the Federal Program: U.S. Department of Education, Trio Cluster Criteria: 2 CFR 200.305 establishes the procedures for receiving federal payments. Non-federal entities must design and implement internal controls to ensure compliance with cash management requirements. Condition: We selected a sample of 24 reimbursement draw downs made during the year through the G5 payment system. Procedures were in place to accumulate expenses based on approved invoices and draw the reimbursement amount down through G5, however, documentation of review and approval of amounts to be drawn was not available. Cause: The College did not document the review and approval of the calculated reimbursement before it was drawn down. Effect: Key controls over cash management were not operating effectively. Questioned Costs: None reported Recommendation: We recommend the College strengthen its policies and procedures to properly design and implement controls over the draw down process. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Information on the Federal Program: U.S. Department of Education, Trio Cluster Criteria: 2 CFR 200.305 establishes the procedures for receiving federal payments. Non-federal entities must design and implement internal controls to ensure compliance with cash management requirements. Condition: We selected a sample of 24 reimbursement draw downs made during the year through the G5 payment system. Procedures were in place to accumulate expenses based on approved invoices and draw the reimbursement amount down through G5, however, documentation of review and approval of amounts to be drawn was not available. Management’s Response: The College has always had controls on draw downs associated with separation of duties and the review of grants. The College will ensure a signature page is included to document these efforts of the review and approval of all Federal draw downs. Anticipated Completion Date: January 31, 2025
We selected a Trio sample of 25 payroll charges, containing 56 employee paychecks. Of those 56, five employee's approved pay was not properly documented. The employee had additional pay not on the approved Letter of Appointment (LOA) or the LOA reflected the use of restricted dollars, but the pay was charged to the grant. In addition, of those 56, five employees were charged to a grant that they were not budgeted for. We selected an ARC sample of 10 nonpayroll disbursements to test for controls. Of those 10, one disbursement of four scholarships was not properly documented as approved for payment. Cause: Trio employees received additional stipends or adjunct pay that was not on the approved pay documentation. Employees’ pay was charge to the Trio program but their position/job title was not in the grant budget. ARC students received scholarships posted to their student account but documentation of approval to pay was not available. Effect: Employees’ pay was charged to the Trio grants when they were not allowable based on the budget. Employees’ total pay amounts are not properly documented. Key controls over allowable costs were not operating effectively. Questioned Costs: $2,854 Recommendation: We recommend the College strengthen its policies and procedures surrounding the disbursement process. Payroll costs funded by federal funds should be adequately documented as to allowability and employees’ total pay documented, reviewed and approved. In addition, all nonpayroll disbursements should be approved by management of the grant program. 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 (Significant Deficiency and Noncompliance) Information on the Federal Program: U.S. Department of Education, Trio Cluster and Appalachian Regional Commission (ARC), Appalachian Area Development Assistance Listing No. 23.002 Criteria: 2 CFR 200 Subpart E establishes cost principles to apply in determining costs under federal awards. Nonfederal entities are also required to establish controls over the disbursement process to ensure compliance with allowable cost requirements. Condition: We selected a Trio sample of 25 payroll charges, containing 56 employee paychecks. Of those 56, five employee's approved pay was not properly documented. The employee had additional pay not on the approved Letter of Appointment (LOA) or the LOA reflected the use of restricted dollars, but the pay was charged to the grant. In addition, of those 56, five employees were charged to a grant that they were not budgeted for. We selected an ARC sample of 10 nonpayroll disbursements to test for controls. Of those 10, one disbursement of four scholarships was not properly documented as approved for payment. Cause: Trio employees received additional stipends or adjunct pay that was not on the approved pay documentation. Employees’ pay was charge to the Trio program but their position/job title was not in the grant budget. ARC students received scholarships posted to their student account but documentation of approval to pay was not available. Effect: Employees’ pay was charged to the Trio grants when they were not allowable based on the budget. Employees’ total pay amounts are not properly documented. Key controls over allowable costs were not operating effectively. Questioned Costs: $2,854 Recommendation: We recommend the College strengthen its policies and procedures surrounding the disbursement process. Payroll costs funded by federal funds should be adequately documented as to allowability and employees’ total pay documented, reviewed and approved. In addition, all nonpayroll disbursements should be approved by management of the grant program. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Information on the Federal Program: U.S. Department of Education, Trio Cluster and Appalachian Regional Commission (ARC), Appalachian Area Development Assistance Listing No. 23.002 Criteria: 2 CFR 200 Subpart E establishes cost principles to apply in determining costs under federal awards. Nonfederal entities are also required to establish controls over the disbursement process to ensure compliance with allowable cost requirements. Condition: We selected a Trio sample of 25 payroll charges, containing 56 employee paychecks. Of those 56, five employee's approved pay was not properly documented. The employee had additional pay not on the approved Letter of Appointment (LOA) or the LOA reflected the use of restricted dollars, but the pay was charged to the grant. In addition, of those 56, five employees were charged to a grant that they were not budgeted for. We selected an ARC sample of 10 nonpayroll disbursements to test for controls. Of those 10, one disbursement of four scholarships was not properly documented as approved for payment. Management’s Response: The College will strengthen its policies and procedures surrounding the disbursement process. The College will document approvals on all payroll changes at the college and on the grant budgets. All scholarships will have prior written approval before scholarships will be applied. The College will also amend all grants when needed to properly reflect all job titles and expenditure items. Anticipated Completion Date: February 28, 2025
FAC accepted this audit on January 23, 2024 — management decision was due July 23, 2024.
We selected a sample of 21 students who withdrew and were receiving financial aid. Of the students tested, there were two instances in which the College incorrectly calculated the percentage of aid earned. Cause: The College performed return of Title IV calculations in the system, however, a system glitch was discovered six months after the initial calculations and the College determined the system did not properly calculate the amount of aid earned. The calculations were later updated but not within the required time frame. Effect: The College returned the incorrect amount of financial aid. Questioned Costs: None reported Recommendation: We recommend the College strengthen its policies and procedures surrounding the withdrawal process to accurately document each requirement and implement checks and balances to ensure compliance with all 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 2023-002 – Special Tests and Provisions: Withdrawal Testing (Significant Deficiency and Noncompliance) Information on the Federal Program: U.S. Department of Education, Student Financial Aid Cluster Criteria: 34 CFR Part 668.22 establishes rules governing the student withdrawal process including the determination of the amount of Title IV assistance the student earned and return the unearned Title IV aid within 45 days. Condition: We selected a sample of 21 students who withdrew and were receiving financial aid. Of the students tested, there were two instances in which the College incorrectly calculated the percentage of aid earned. Cause: The College performed return of Title IV calculations in the system, however, a system glitch was discovered six months after the initial calculations and the College determined the system did not properly calculate the amount of aid earned. The calculations were later updated but not within the required time frame. Effect: The College returned the incorrect amount of financial aid. Questioned Costs: None reported Recommendation: We recommend the College strengthen its policies and procedures surrounding the withdrawal process to accurately document each requirement and implement checks and balances to ensure compliance with all withdrawal requirements. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Corrective Action Plan: Management is in the process of updating Policies and Procedures to help ensure that calculations are run correctly and timely. The Financial Aid office and the Finance Office will work together each semester to ensure Banner setup is correct, updated, and working properly prior to any calculations being performed. Anticipated Completion Date: January 31, 2024
2022-011
FAC accepted this audit on January 17, 2023 — management decision was due July 17, 2023.
We selected a sample of 12 students who withdrew and were receiving financial aid. Of the 12 students tested, there were two instances in which the College incorrectly calculated the percentage of aid earned. Cause: The College did not properly calculate the amount of aid earned by using the incorrect withdrawal date. Effect: The College returned the incorrect amount of financial aid. Questioned Costs: None reported Recommendation: We recommend the College strengthen its policies and procedures surrounding the withdrawal process to accurately document each requirement and implement checks and balances to ensure compliance with all 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 2022-011 ? Special Tests and Provisions: Withdrawal Testing (Significant Deficiency and Noncompliance) 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 withdrawal date, calculation of earned Title IV assistance and return of unearned Title IV aid within 45 days. Condition: We selected a sample of 12 students who withdrew and were receiving financial aid. Of the 12 students tested, there were two instances in which the College incorrectly calculated the percentage of aid earned. Cause: The College did not properly calculate the amount of aid earned by using the incorrect withdrawal date. Effect: The College returned the incorrect amount of financial aid. Questioned Costs: None reported Recommendation: We recommend the College strengthen its policies and procedures surrounding the withdrawal process to accurately document each requirement and implement checks and balances to ensure compliance with all withdrawal requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-011 ? Special Tests and Provisions: Withdrawal Testing (Significant Deficiency and Noncompliance) 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 withdrawal date, calculation of earned Title IV assistance and return of unearned Title IV aid within 45 days. Condition: We selected a sample of 12 students who withdrew and were receiving financial aid. Of the 12 students tested, there were two instances in which the College incorrectly calculated the percentage of aid earned. Management?s View: The issue occurred due to a timing difference of the date drop forms being submitted to Student Services and the effective drop date entered into Banner. In this instance, the drop forms were submitted on a Friday when the College operates on a half-day schedule. The form was entered the following Monday, and the entry should have been backdated to Friday. This caused Financial Aid?s Title IV return calculation to be off by two days. Corrective Action Plan: Management is in process of updating Policies and Procedures to incorporate Financial Aid into the student drop process. Financial Aid will receive emailed copies of student drop forms as they are submitted to Student Services. Financial Aid will review the dates in Banner prior to finalizing Title IV return calculations to ensure that the dates the forms were submitted match the date the drop was recorded as in Banner. This will take effect immediately as the policies are formally updated. Anticipated Completion Date: September 30, 2023
We selected a sample of six vendors to test for proper procurement procedures. Of those six, one vendor was not properly procured. Cause: The College did not obtain price quotes for a purchase which met the small purchase threshold. Effect: The College was not in compliance with federal procurement standards. Questioned Costs: None reported Recommendation: We recommend the College strengthen its policies and procedures surrounding the procurement process to ensure all purchases higher than the micro-purchase threshold 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 2022-012 ? Procurement (Significant Deficiency and Noncompliance) (Repeat finding) Information on the Federal Program: U.S. Department of Education, CFDA No. 84.425, COVID-19 Education Stabilization Fund ? Higher Education Emergency Relief Fund Criteria: 2 CFR 200.320 establishes the methods of procurement to be followed for non-federal entities when acquiring goods and services with federal awards. Aggregate purchases higher than the micro-purchase threshold must use the small purchase procedures which require price quotes be obtained from an adequate number of qualified sources. Condition: We selected a sample of six vendors to test for proper procurement procedures. Of those six, one vendor was not properly procured. Cause: The College did not obtain price quotes for a purchase which met the small purchase threshold. Effect: The College was not in compliance with federal procurement standards. Questioned Costs: None reported Recommendation: We recommend the College strengthen its policies and procedures surrounding the procurement process to ensure all purchases higher than the micro-purchase threshold are properly procured. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-012 ? Procurement (Significant Deficiency and Noncompliance) (Repeat finding) Information on the Federal Program: U.S. Department of Education, CFDA No. 84.425, COVID-19 Education Stabilization Fund ? Higher Education Emergency Relief Fund Criteria: 2 CFR 200.320 establishes the methods of procurement to be followed for non-federal entities when acquiring goods and services with federal awards. Aggregate purchases higher than the micro-purchase threshold must use the small purchase procedures which require price quotes be obtained from an adequate number of qualified sources. Condition: We selected a sample of six vendors to test for proper procurement procedures. Of those six, one vendor was not properly procured. Management?s View: Management was made aware of this during the end of the prior year audit. These purchases had already been made by that time. Management has implemented a corrective action plan to ensure that policies and procedures are followed. Corrective Action Plan: Management has informed department heads regarding the need to obtain multiple quotes for purchases higher than the micro-purchase threshold and below the bid threshold. Management is in process of updating Policies and Procedures to include this requirement for Procurement. Going forward, requisitions submitted requiring multiple quotes will not be approved without a minimum of three (3) quotes provided by the requester. This will take effect immediately as the policies are formally updated. Anticipated Completion Date: September 30, 2023
2021-004
During audit procedures we tested controls over applicable compliance requirements. We tested two drawdowns for cash management requirements. One of the draws was a reimbursement for lost revenue. Although the method to calculate lost revenue was reviewed and approved, the individual calculations and amounts to be drawn were not reviewed and approved. We tested five disbursements made directly to students as grant awards. Of these five, four disbursements did not have documentation of review or approval of the amounts to be paid. Cause: The College did not properly document controls over cash management and allowable costs. Effect: The College was not in compliance with internal control requirements for grant management. Questioned Costs: None reported Recommendation: We recommend the College strengthen its policies and procedures to ensure internal controls are properly implemented and documented. 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 2022-013 ? Internal Controls Over Grant Management (Significant Deficiency) Information on the Federal Program: U.S. Department of Education, CFDA No. 84.425, COVID-19 Education Stabilization Fund ? Higher Education Emergency Relief Fund Criteria: 2 CFR 200.303 requires non-federal entities receiving federal awards establish and maintain internal controls over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations and the terms and conditions of the federal awards. Condition: During audit procedures we tested controls over applicable compliance requirements. We tested two drawdowns for cash management requirements. One of the draws was a reimbursement for lost revenue. Although the method to calculate lost revenue was reviewed and approved, the individual calculations and amounts to be drawn were not reviewed and approved. We tested five disbursements made directly to students as grant awards. Of these five, four disbursements did not have documentation of review or approval of the amounts to be paid. Cause: The College did not properly document controls over cash management and allowable costs. Effect: The College was not in compliance with internal control requirements for grant management. Questioned Costs: None reported Recommendation: We recommend the College strengthen its policies and procedures to ensure internal controls are properly implemented and documented. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-013 ? Internal Controls Over Grant Management (Significant Deficiency) Information on the Federal Program: U.S. Department of Education, CFDA No. 84.425, COVID-19 Education Stabilization Fund ? Higher Education Emergency Relief Fund Criteria: 2 CFR 200.303 requires non-federal entities receiving federal awards establish and maintain internal controls over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations and the terms and conditions of the federal awards. Condition: During audit procedures we tested controls over applicable compliance requirements. We tested two drawdowns for cash management requirements. One of the draws was a reimbursement for lost revenue. Although the method to calculate lost revenue was reviewed and approved, the individual calculations and amounts to be drawn were not reviewed and approved. We tested five disbursements made directly to students as grant awards. Of these five, four disbursements did not have documentation of review or approval of the amounts to be paid. Management?s View: Management had previously held many discussions regarding drawdown calculations and student disbursements either verbally or during in-person meetings that were not formally documented. Corrective Action Plan: Management is in process of updating Policies and Procedures. Management will ensure that all drawdown calculations will be sent to the Director of Accounting and Finance and the VP of Administration and Operations for review and approval via email. Student disbursement information, including the method of determining qualifying students and amounts, will be sent by the Dean of Students to the VP of Administration and Operations for review and approval. In the event such information is discussed verbally or at in-person meetings, documentation of date, time, and summary of the discussion will be documented. This will take effect immediately as the policies are formally updated. Anticipated Completion Date: September 30, 2023
FAC accepted this audit on September 29, 2022 — management decision was due March 29, 2023.
Reference Number: 2021-004 Compliance Requirement: Procurement and Suspension/Debarment Type of Finding: Internal Control/Compliance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance ALN Numbers and Titles: Higher Education Emergency Relief Fund (HEERF) 84.425E ? HEERF Student Aid Portion 84.452F ? HEERF Institutional Portion 84.425M ? HEERF Strengthening Institutions Program (SIP) Federal Awarding Agency: U.S. Department of Education Federal Award Numbers: P425E202120; P425F202247; P425M210012 Pass-through Entity: None Pass-through Award Number: None Questioned Costs: None 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 200.318(a) states, ?The Non-Federal entity must use its own 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(f) 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, 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 $44,755.00. 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: Management agrees with this finding and will take corrective actions.
Show full finding ▾Hide full finding ▴Reference Number: 2021-004 Compliance Requirement: Procurement and Suspension/Debarment Type of Finding: Internal Control/Compliance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance ALN Numbers and Titles: Higher Education Emergency Relief Fund (HEERF) 84.425E ? HEERF Student Aid Portion 84.452F ? HEERF Institutional Portion 84.425M ? HEERF Strengthening Institutions Program (SIP) Federal Awarding Agency: U.S. Department of Education Federal Award Numbers: P425E202120; P425F202247; P425M210012 Pass-through Entity: None Pass-through Award Number: None Questioned Costs: None 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 200.318(a) states, ?The Non-Federal entity must use its own 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(f) 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, 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 $44,755.00. 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: Management agrees with this finding and will take corrective actions.
Corrective Action Plan: The College will 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. Anticipated Completion Date: September 30, 2022 Contact Person: John Skalnik, Vice President of Administration and Operations
Reference Number: 2021-005 Compliance Requirement: Procurement and Suspension/Debarment Type of Finding: Internal Control/Compliance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance ALN Numbers and Titles: Higher Education Emergency Relief Fund (HEERF) 84.425E ? HEERF Student Aid Portion 84.452F ? HEERF Institutional Portion 84.425M ? HEERF Strengthening Institutions Program (SIP) Federal Awarding Agency: U.S. Department of Education Federal Award Numbers: P425E202120; P425F202247; P425M210012 Pass-through Entity: None Pass-through Award Number: None Questioned Costs: None The College failed to document the verification of vendors showing that they are not suspended or disbarred. Finding: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). 2 CFR 200.318(a) states, ?The Non-Federal entity must use its own 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?? Due to a lack of documented procurement procedures, requiring the retention of procurement documentation, it was noted that the College failed to document or retain documentation of the verification that vendors were not suspended or debarred. The College was unable to provide adequate documentation for 4 out of 5 vendors tested. As a result, procurements could be improperly entered into with vendors that are suspended or debarred. Recommendation: The College should implement policies and procures to ensure proper suspension and debarment checks are performed and that documentation of the checks are retained. 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: Procurement and Suspension/Debarment Type of Finding: Internal Control/Compliance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance ALN Numbers and Titles: Higher Education Emergency Relief Fund (HEERF) 84.425E ? HEERF Student Aid Portion 84.452F ? HEERF Institutional Portion 84.425M ? HEERF Strengthening Institutions Program (SIP) Federal Awarding Agency: U.S. Department of Education Federal Award Numbers: P425E202120; P425F202247; P425M210012 Pass-through Entity: None Pass-through Award Number: None Questioned Costs: None The College failed to document the verification of vendors showing that they are not suspended or disbarred. Finding: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). 2 CFR 200.318(a) states, ?The Non-Federal entity must use its own 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?? Due to a lack of documented procurement procedures, requiring the retention of procurement documentation, it was noted that the College failed to document or retain documentation of the verification that vendors were not suspended or debarred. The College was unable to provide adequate documentation for 4 out of 5 vendors tested. As a result, procurements could be improperly entered into with vendors that are suspended or debarred. Recommendation: The College should implement policies and procures to ensure proper suspension and debarment checks are performed and that documentation of the checks are retained. Views of Responsible Officials of the Auditee: Management agrees with this finding and will take corrective actions.
Corrective Action Plan: The College will implement policies and procedures to ensure proper suspension and debarment checks are performed and that documentation of the checks are retained. Anticipated Completion Date: September 30, 2022 Contact Person: John Skalnik, Vice President of Administration and Operations
FAC accepted this audit on June 28, 2017 — management decision was due December 28, 2017.
GSA_MIGRATION
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GSA_MIGRATION
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