American Samoa Community CollegeNon-Profit

FINDING 2025‐002 – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Number: 84.063 Federal Program Name: Federal Pell Grant Program Award Year: 2024-25 Criteria: Pell Grant, Section 34 CFR Section 690.83(b) (2) An institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information. It is the College’s responsibility to update this information timely and accurately. The College determines how often it receives the Enrollment Reporting roster file with the default set at every 60 days. Condition and context: 2 submissions of official withdrawals were reported late and not identified prior to submission. 1 submission of a graduated student was not reported timely and not identified prior to submission. 1 submission of an unofficial withdrawal was reported late and not identified prior to submission. 26 students were sampled using a random sampling methodology from a population of 65 withdrawals, and 170 graduates. American Samoa Community College (A Component Unit of the American Samoa Government) Schedule of Findings and Questioned Costs Year Ended September 30, 2025 48 Questioned costs: None. Effect: This information is utilized by the Department of Education, the Federal Direct Loan program, lenders, and other institutions to determine in‐school status. However, American Samoa Community College does not participate in loan programs, which limits the effect of non-compliance. Cause: In 2025, additional controls were implemented, including the reconciling of uploaded reports. Unfortunately, this reconciliation was external report to external report, which was not able to identify students who attended and withdrew from the school during the same enroll roster reporting period. As such, this reconciliation was not able to identify these students timely, which resulted in unidentified and late submission. Repeat finding: Yes. Recommendation: We recommended the College ensure the policy is being followed, which requires a review to be performed independent of the individual who prepares the NSLDS roster. We also recommended the College compare internal student rosters to external roster reports to ensure the rosters are complete and accurate in regard to students reported as graduated or withdrawn. Additionally, we recommend the College retain documentation reflecting all formal reviews of the roster. This recommendation was made in the prior year but not effectively, and correction of the reconciliation was necessary. Views of responsible officials and planned corrective actions: The Financial Aid Office ensures strict adherence to NSLDS reporting timelines. Institutionally, enrollment is certified monthly and the school responds within 15 days of the date NSLDS issues a roster file. Any errors identified through the NSLDS are reviewed, corrected and resubmitted within 10 days. To strengthen accuracy, completeness, and compliance, the Financial Aid Office has implemented a dual-review control system. Contact Person(s): Shanell Tilo, Financial Aid Officer Dr. Emilia Le’i, Dean of Student Services Dr. Letupu Moananu, Vice President of Academics, Community, and Student Affairs

FINDING 2024-002 – Special Tests and Provisions – Return of Title IV Funds Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Number: 84.063, 84.007, 84.033 Federal Program Name: Federal Pell Grant Program Award Year: 2023-24 Criteria: Per 34 CFR Section 668.22, when a student withdraws from an institution before completion of their current academic period and is determined as having not earned 100 percent of their received Title IV assistance, an institution must return the total amount of unearned Title IV assistance received from withdrawn students. Return of Title IV funds (R2T4) are required to be deposited or transferred into the Student Financial Assistance account or electronic fund transfers initiated to the Department of Education (ED) as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Condition and Context: A sample of 8 students who were recipients of Title IV funding and had withdrawn during the year was selected for our testing procedures. Our sample was selected using a random and judgmental sampling methodology, from a population of 42 total withdrawals consisting of 31 unofficial withdrawals and 8 official withdrawals. 4 of the students selected withdrew during the spring term, which included the spring break within the total days used in the R2T4 calculation. Based on the 2023-2024 Federal Student Aid Handbook, scheduled breaks lasting five or more consecutive days are excluded from the total and completed days in the R2T4 calculation (Volume 5, Chapter 1). Furthermore, 34 CFR 668.22 of the eCFR supports this rule by excluding such breaks from the calculation of the payment period. The College did not perform the Title IV calculation within the College’s policy or within Federal requirements, and therefore returned too much funding. Questioned costs: None. Effect: Of the 42 total withdraws, 20 occurred during the spring term resulting in the over return of funds. For the 4 students we tested, there was no impact to the student, but instead the College received less funding due to the over return. Cause: The College’s policy was not adhered to and as such was the control was not operating as intended. Repeat finding: No. Recommendation: We recommend the College ensure the policy is being followed which requires scheduled breaks lasting five or more consecutive days be excluded from the total and completed days in the R2T4 calculation. Views of responsible officials and planned corrective actions: Contact Person(s): Shanell Tauiliili, Financial Aid Officer Dr. Emilia Le' i, Dean of Student Services Letupu Moananu, Vice President of Academics, Community, and Student Affairs

FINDING 2024-003 – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Number: 84.063 Federal Program Name: Federal Pell Grant Program Award Year: 2023-24 Criteria: Pell Grant, Section 34 CFR Section 690.83(b) (2) An institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information. It is the College’s responsibility to update this information timely and accurately. The College determines how often it receives the Enrollment Reporting roster file with the default set at every 60 days. Condition and context: 2 submissions of withdrawal were reported late and not identified prior to submission. 20 students were sampled using a random sampling methodology, from a population of 42 withdrawals, and 244 graduates. Questioned costs: None. Effect: This information is utilized by the Department of Education, the Federal Direct Loan program, lenders, and other institutions to determine in-school status. However, American Samoa Community College doesn’t participate in loan programs, which limits the effect of non-compliance. Cause: In fiscal year 2024, the College implemented many new controls which were communicated in the previous corrective action in the preceding year. One control that was not implemented until May 2024 was the control related to the review by the Financial Aid Manager of the prepared Roster File prior to submission. We noted that the control was operating as designed post implementation. The College’s policy was not adhered to between October 2023 and May 2024 and as such was the control was not operating as intended during that period. Repeat finding: Yes. Recommendation: We recommend that the College ensure the policy is being followed which requires a review to be performed independent of the individual who prepares the NSLDS roster. Additionally, we recommend the College retain documentation reflecting all formal reviews of the roster. This Recommendation: We recommend that the College ensure the policy is being followed which requires a review to be performed independent of the individual who prepares the NSLDS roster. Additionally, we recommend the College retain documentation reflecting all formal reviews of the roster. This recommendation was made in the prior year and correction occurred during the current fiscal year; we noted that the control was operating as designed post implementation in May 2024. Views of responsible officials and planned corrective actions: Contact Person(s): Shanell Tauiliili, Financial Aid Officer Dr. Emilia Le' i, Dean of Student Services Letupu Moananu, Vice President of Academics, Community, and Student Affairs

FINDING 2023-002 – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Number: 84.063 Federal Program Name: Federal Pell Grant Program Award Year: 2021-22 Criteria: Pell Grant, Section 34 CFR Section 690.83(b)(2): An institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Condition and context: In fiscal year 2023, the College implemented many new controls which were communicated in the previous corrective action from the preceding year. One area that was not implemented was a control related to the review by the Financial Aid Manager of the prepared Roster File prior to submission. MA noted that the control was not operating as designed since NSLDS submissions were both prepared and submitted by the same person during the current year. Questioned costs: None. Cause: A person other than the Financial Aid Manager was not designated to prepare the submissions. Effect: Because of the lack of a review by an individual independent of the preparer, errors could occur and not be identified prior to submission. This information is utilized by the Department of Education, the Federal Direct Loan program, lenders, and other institutions to determine in-school status. However, American Samoa Community College doesn’t participate in loan programs, which limits the effect of non-compliance. Repeat finding: Yes Recommendation: We recommend the College ensure the policy is being followed which requires a review to be performed independent of the individual who prepares the NSLDS roster. Additionally, we recommend the College retain documentation reflecting all formal reviews of the roster. Views of responsible officials and planned corrective actions: The Financial Aid Coordinator (control #1, with FA Officer as alternate) has been assigned to transmit the bi-monthly Enrollment Report roster. The control #1 reviews the roster and performs data entry, status updates, and submission by the 15th of the reporting month. On the 1st of every nonreporting month, control #1 will review and report any enrollment status changes before the 15th. Financial Aid Manager (control #2) will review the status updates on NSLDS before and after every submission. Identified errors will be documented and returned to control #1 for correction and resubmission. The policy will ensure all student changes in status are identified, updated, and submitted timely and accurately. ASCC FAO participates in Federal Student Aid (FSA) training and conferences regarding NSLDS updates, changes, and functionality. FAO also subscribes to the Weekly Knowledge Center Updates from FSA Partner Connect. ASCC is a member of the National Association of Student Financial Aid Administrators (NASFAA). All of these resources provide access and education in the process of enrollment reporting and compliance, as well as the responsibilities and consequences of inaccurate reporting. Graduates: Students who graduate will be updated into NSLDS within one week after graduation. Official / Unofficial Withdrawal: All Withdrawals must then be reported to NSLDS within 45 days. On the 1st of every nonreporting month, control #1 will review and report any enrollment status changes before the 15th. Contact Person(s): Shanell Tauiliili, Financial Aid Officer Dr. Emilia Le’i, Dean of Student Services Letupu Moananu, Vice President of Academics, Community, and Student Affairs

FINDING 2022-002 ? Special Tests and Provisions ? Return of Title IV Funds Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Numbers: 84.063, 84.007, 84.033 Federal Program Name: Student Financial Assistance Cluster Award Year: 2021-22 Criteria: Per 34 CFR Section 668.22; When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date. The unearned amount of title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated from the amount of title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew. Return of Title IV funds (R2T4) are required to be deposited or transferred into the Student Financial Assistance account or electronic fund transfers initiated to the Department of Education (ED) as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Condition and context: A sample of 24 students who were recipients of Title IV funding and had withdrawn during the year was selected for our testing procedures. Our sample was selected using a random and judgmental sampling methodology, from a population of 59 total withdrawals. Student records were compared to the calculation of the return of Title IV funds. We noted that the identification of withdrawn students is not timely, therefore, the initial calculation to return Title IV was late for seven of the twenty-four selected for testing with four as official withdrawals and three as unofficial withdrawals. Questioned costs: None Effect: The College did not perform the Title IV calculation within a reasonable time, and as such the return of funds was delayed. Cause: This occurred because the process in place was not designed effectively to identify the withdrawal of students, either official or unofficial, to calculate the return of Title IV funds and to remit amounts on a timely basis. Repeat finding: Yes, 2021-002 Recommendation: We recommend the College implement a process to identify official and unofficial withdrawals on a timely basis and that the calculations be performed within the required timeframe. Views of responsible officials and planned corrective actions: Official Withdrawals: Financial Aid Counselors are responsible for the Identification of Official Withdrawals through the Attendance Pattern Comparison Report (APCR), which is run every Monday (or next business day). Each Counselor (control #1) is responsible for the performance of the R2T4 form for their respective students and forward to the designated Counselor (control #2) to ensure accuracy and completion. Control #2 is responsible to manually input the calculations into Datatel and ensure adjustments, if any, are processed and returned via COD. This action is to be completed and included in the next scheduled batch closure or no later than 45 days from the date of withdrawal. Unofficial Withdrawals: After final grades have been posted at the end of each session or semester, each counselor will review their respective students through student transcript, identify those with ?zero credits earned? and determine last date of attendance. Official Withdrawal procedures will then be performed. Official / Unofficial Withdrawal: All Withdrawals must then be reported to NSLDS by the Financial Aid Coordinator (with FA Officer as alternate) within 45 days. Anticipated completion of the corrective action is expected by June 2023.

FINDING 2022-003 ? Special Tests and Provisions - Enrollment Reporting Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Number: 84.063 Federal Program Name: Federal Pell Grant Program Award Year: 2021-22 Criteria: Pell Grant, Section 34 CFR Section 690.83(b) (2) An institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. The National Student Loan Data System (NSLDS) is the Department of Education?s (ED) centralized database for students? enrollment information. It is the College?s responsibility to update this information timely and accurately. Effective January 12, 2023; NSLDS has published issues with the enrollment reporting website, affecting submissions from July 19, 2022 to February 28, 2023, thus those have been removed from the condition and context section. The College determines how often it receives the Enrollment Reporting roster file with the default set at every 60 days. The College has engaged the National Student Clearinghouse's (NSC) services to assist with the reporting of student's status changes and degrees to the NSLDS. Condition and context: In our audit sample of 25 items, which included 12 withdrawals and 13 graduated students, 11 status changes were reported late to NSLDS. Our sample was selected using a random sampling methodology, from a population of 104 withdrawals, and 174 graduates. Subsequently, the withdrawn or graduated student status was corrected for the sampled students, but not within the required timeframe. Questioned costs: None Effect: This information is utilized by ED, the Federal Direct Loan program, lenders, and other institutions to determine in-school status. American Samoa Community College doesn?t participate in loan programs, which limits the effect of non-compliance. Cause: This occurred because of a lack of control in place to monitor for compliance. Repeat finding: Yes, 2021-003. Recommendation: We recommend the College follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. Furthermore, we recommend the College educate staff involved in the process regarding the Enrollment Reporting compliance responsibilities and the consequences of inaccurate reporting to the NSLDS via the NSC. This policy should specifically address the personnel assigned to various tasks (data entry and review). Opportunities for additional NSC training in this area and others are available through the NSC?s Clearinghouse Academy page. Lastly, we recommend the College establish an internal monitoring control whereby a designated individual with NSLDS access, spot-checks the status updates on NSLDS on a sample basis so as to internally audit the submissions. Views of responsible officials and planned corrective actions: NSLDS Plan and Corrective Actions: The Financial Aid Coordinator (control #1, with FA Officer as alternate) has been assigned to transmit the bi-monthly Enrollment Report roster. The control #1 reviews the roster and performs data entry, status updates and submission by the 15th of the reporting month. On the 1st of every nonreporting month, control #1 will review and report any enrollment status changes before the 15th. Counselor III (control #2) is assigned to monitor and spot check the status updates on NSLDS after the 25th of every month to internally audit the submissions. The policy will ensure all student changes in status are identified, updated and submitted timely and accurately. ASCC FAO participates in Federal Student Aid (FSA) training and conferences regarding NSLDS updates, changes and functionality. FAO also subscribes to the Weekly Knowledge Center Updates from FSA Partner Connect. ASCC is a member of the National Association of Student Financial Aid Administrators (NASFAA). All of these resources provide access and education in the process of enrollment reporting and compliance, as well as responsibilities and consequences of inaccurate reporting. Controls (#1 and #2) shall be included accordingly in the job descriptions of the Financial Aid Coordinator and Counselor III as well as the Financial Aid Standard Operating Procedures for consistency in compliance and reporting. Graduates: Students who graduate will be updated into NSLDS within one week after graduation. Official / Unofficial Withdrawal: All Withdrawals must then be reported to NSLDS within 45 days. Anticipated completion of the corrective action is expected by June 2023.

FINDING 2022-004 ? Special Tests and Provisions ? Gramm-Leach-Bliley Act ? Student Information Security; Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Numbers: 84.063, 84.007, 84.033 Federal Program Name: Student Financial Assistance Cluster Award Year: 2021-22 Criteria: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Under an institution?s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)) Condition and context: A written risk assessment wasn?t performed that addressed the three required areas noted in 6 CFR 314.4 (b), which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing, and responding to attacks, intrusions, or other systems failures until September 2022. Questioned costs: None Effect: The College does have limited controls in place surrounding student information security, which limits the effect of non-compliance. Cause: The finding and significant deficiency is due to a prior lack of understanding over the compliance requirement during the first half of the year and delays in implementation due to COVID-19. Repeat finding: Yes, 2021-004 Recommendation: We recommended the College?s designated individual should finalize and complete documentation surrounding the risk assessment that addresses the three required areas noted in 16 CFR 314.4 (b), which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) detecting, preventing and responding to attacks, intrusions, or other systems failures. This should be in place for the entire fiscal year. Views of responsible officials and planned corrective actions: The College has designated the Chief Information Officer (CIO) and on the following Items were completed in September 2022: a. ASCC Data / Information Security Program b. Risk Assessment that addresses (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) detecting, preventing and responding to attacks, intrusions, or other systems failures. The risk assessment identified action items to resolve findings and controls that are put in place in the meantime. Action Items and controls are reviewed and updated monthly. In November 2022, The Federal Student Aid (FSA) Cyber Compliance Team confirmed that ASCC has satisfied the minimum information security requirements under Gramm-Leach-Bliley Act (GLBA) and closed its. The next annual complete Risk Assessment will be completed in August 2023, and ASCC will continue to complete a Risk Assessment annually to stay in compliance with GLBA. Anticipated completion of the corrective action is expected by October 2023.

FINDING 2022-005 ? Reporting Requirements ? Smith-Lever; Significant Deficiency in Internal Control over Compliance U.S. Department of Agriculture, Smith-Lever Funding Assistance Listing Numbers: 10.511 Federal Program Name: Smith-Lever (Various Programs) Award Year: 2021-22 Criteria: In accordance with grant requirements, a filing of the SF-425 is required on an annual basis with a due date of December 30th. Condition and context: The annual report was submitted on April 18, 2022, which was past the due date of December 30, 2021. Questioned costs: None Effect: The College is not in compliance with reporting requirements of the grant. Cause: With a delay in the financial close and reporting cycle, there was a delay in filing the report. Repeat finding: No Recommendation: We recommend the College implement controls to ensure timely submission of annual report. Views of responsible officials and planned corrective actions: Controls are in place for the Finance Division to ensure the timely submission of required financial reports for grant programs. The Finance Division will review and strengthen its processes and controls to ensure that the reconciliations of account balances are done on a timely basis to make sure that the expenses reported in the annual reports are accurate. A timeline of required reports will be provided by the Finance Officer to the Assistant Finance Officer and Accountants to follow and ensure that reports are submitted in a timely manner. Anticipated completion of the corrective action is expected by September 2023.

FINDING 2021-002 ? Special Tests and Provisions ? Return of Title IV Funds Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Numbers: 84.063, 84.007, 84.033 Federal Program Name: Student Financial Assistance Cluster Award Year: 2020-21 Criteria: Per 34 CFR Section 668.22, when a student withdraws from an institution before completion of their current academic period and is determined as having not earned 100 percent of their received Title IV assistance, an institution must return the total amount of unearned Title IV assistance received from withdrawn students. Return of Title IV funds (R2T4) are required to be deposited or transferred into the Student Financial Assistance account or electronic fund transfers initiated to the Department of Education (ED) as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Condition and Context: A sample of 15 students who were recipients of Title IV funding and had withdrawn during the year was selected for our testing procedures. Our sample was selected using a random and judgmental sampling methodology, from a population of 41 total withdrawals consisting of 27 unofficial withdrawals and 14 official withdrawals. Student records were compared to the calculation of the return of Title IV funds. We noted that the identification of withdrawal students is not timely, therefore, the initial calculation to return Title IV was late for each selection within the sample. Questioned costs: None Effect: The College did not perform the Title IV calculation within a reasonable time, and as such the return of funds was delayed. Cause: This occurred because the process in place was not designed effectively to identify the withdrawal of students, either official or unofficial, to calculate the return of Title IV funds and to remit amounts on a timely basis. Repeat Finding: Yes Recommendation: We recommend the College implement a process in which an individual in the student financial aid department reviews each return of Title IV funds calculation prior to executing the return. The review should be documented to ensure accuracy and completion. We noticed improvement with calculations by the utilization of the in-house software and the process of returning Title IV were within the 45-day period as required. Additional controls should be implemented to ensure that both unofficial and official withdrawals are identified on a timely basis, and then calculated and returned if necessary. Views of responsible officials and planned corrective actions: A new financial aid officer was hired during the 2021 fiscal year, and increased controls, as described below. These processes and controls were fully implemented by June 30, 2021. Official Withdrawals: Financial Aid Counselors are responsible for the identification of Official Withdrawals through the APCR (Attendance Pattern Comparison Report), which is run on the 15th (or next business day) of every month. Each Counselor (control #1) is responsible for the performance of the R2T4 form for their respective students and forward to the designated Counselor (control #2) to ensure accuracy and completion. Control #2 is responsible to manually input the calculations into Datatel and ensure adjustments, if any, are processed and returned via COD. This action should be completed and included in the next scheduled batch closure or no later than 45 days from the date of withdrawal. Unofficial Withdrawals: After final grades have been posted at the end of each semester, each counselor will review their respective students, identify those with ?zero credits earned? and determine last date of attendance. Official Withdrawal procedures will then be performed. Official / Unofficial Withdrawal: All Withdrawals must then be reported to NSLDS within 45 days.

FINDING 2021-003 ? Enrollment Reporting, Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Number: 84.063 Federal Program Name: Federal Pell Grant Program Award Year: 2020-21 Criteria: Pell Grant, Section 34 CFR Section 690.83(b) (2) An institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. The National Student Loan Data System (NSLDS) is the Department of Education?s (ED) centralized database for students? enrollment information. It is the College?s responsibility to update this information timely and accurately. The College determines how often it receives the Enrollment Reporting roster file with the default set at every 60 days. The College has engaged the National Student Clearinghouse's (NSC) services to assist with the reporting of student's status changes and degrees to the NSLDS. Condition and context: In our audit sample of 20 items, which included 12 withdrawals and 8 graduated students, all were reported late. Our sample was selected using a random sampling methodology, from a population of 41 withdrawals, and 136 graduates. Subsequently, the withdrawn or graduated student status was corrected for the sampled students, but not within the required timeframe. Questioned costs: None Effect: This information is utilized by ED, the Federal Direct Loan program, lenders, and other institutions to determine in-school status. American Samoa Community College doesn?t participate in loan programs, which limits the effect of non-compliance. Cause: This occurred because of a lack of control in place to monitor for compliance. Repeat Finding: Yes Recommendation: We recommend the College follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. Furthermore, we recommend the College educate staff involved in the process regarding the Enrollment Reporting compliance responsibilities and the consequences of inaccurate reporting to the NSLDS via the NSC. This policy should specifically address the personnel assigned to various tasks (data entry and review). Opportunities for additional NSC training in this area and others are available through the NSC?s Clearinghouse Academy page. Lastly, we recommend the College establish an internal monitoring control whereby a designated individual with NSLDS access, spot-checks the status updates on NSLDS on a sample basis so as to internally audit the submissions. Views of responsible officials and planned corrective actions: NSLDS Plan and Corrective Actions: The Financial Aid Coordinator (control #1, with FA Officer as alternate) has been assigned to transmit the bi-monthly Enrollment Report roster. The FA Coordinator reviews the roster and performs data entry, status updates and submission by the 15th of the reporting month. Counselor III (control #2) is assigned to monitor and spot check the status updates. The policy will ensure all student changes in status are identified, updated and submitted within the required timeframe. ASCC FAO participates in Federal Student Aid (FSA) training and conferences regarding NSLDS updates, changes and functionality. FAO also subscribes to the Weekly Knowledge Center Updates from FSA Partner Connect. ASCC is a member of the National Association of Student Financial Aid Administrators (NASFAA). All of these resources provide access and education in the process of enrollment reporting and compliance, as well as responsibilities and consequences. Graduates: Students who graduate will be updated into NSLDS within one week after graduation. Official / Unofficial Withdrawal: All Withdrawals must then be reported to NSLDS within 45 days.

FINDING 2021-004 ? Special Tests and Provisions ? Gramm-Leach-Bliley Act ? Student Information Security; Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Numbers: 84.063, 84.007, 84.033 Federal Program Name: Student Financial Assistance Cluster Award Year: 2020-21 Criteria: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Under an institution?s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)) Condition and context: A written risk assessment wasn?t performed that addressed the three required areas noted in 6 CFR 314.4 (b), which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing, and responding to attacks, intrusions, or other systems failures. Questioned costs: None Effect: The College does have limited controls in place surrounding student information security, which limits the effect of non-compliance. Cause: The finding and significant deficiency is due to a prior lack of understanding over the compliance requirement during the first half of the year and delays in implementation due to COVID-19. Repeat finding: Yes Recommendation: We recommend the College?s designated individual should finalize and complete documentation surrounding the risk assessment that addresses the three required areas noted in 16 CFR 314.4 (b), which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) detecting, preventing and responding to attacks, intrusions, or other systems failures. Views of responsible officials and planned corrective actions: The College has designated the Chief Information Officer (CIO), to coordinate and propose a data/information security program to be adopted by the College, as well as complete a risk assessment for ?internal and external risks to the security, confidentiality and integrity of customer information,? focusing on relevant areas including: ?(1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures,? as required by the Gramm-Leach-Bliley (GLB) Act. To better understand the compliance requirements, CIO performed research on requirements and began drafting an Information Security Program Plan, describing the process the College will take in order to ensure the security of records, protect against anticipated threats and hazards to security of these records, and protect against unauthorized access or use of these records or information in ways that will cause harm or inconvenience to ASCC customers or students. This plan will also summarize the risk assessment process ASCC is undertaking to complete the GLB Act requirements and includes ASCC policies this Program is supported by and helps to enforce. The challenges this year in completing the Information Security Program Plan and the Risk Assessment is ASCC having limited Information Technology (IT) staff, and with Covid-19 forcing many services to be provided online, more IT services have become a priority, creating more activities and projects for the Management Information Systems (MIS) Division. The MIS Division has worked this year to fill vacant position to assist with these added responsibilities. CIO was also hired within this Fiscal Year in order to address these significant compliance requirements as well as complete important IT projects.

FINDING 2021-005 ? Reporting Requirements ? HEERF Institutional Portion; Significant Deficiency in Internal Control over Compliance Education Stabilization Fund (Higher Education Emergency Relief Fund - Institutional Portion) Assistance Listing Numbers: 84.425F Federal Program Name: Higher Education Relief Fund Award Year: 2020-21 Criteria: In accordance with OMB Guidance, there are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition and context: Quarterly reports were submitted timely, but the amounts reported within the institutional report were inconsistent with expenditures included in the SEFA. Questioned costs: None Effect: The College does have limited controls in place surrounding relevant training for new programs as they become available. In addition, the limited resources restricted their access to relevant information to understand reporting requirements. Cause: With a delay in the financial close and reporting cycle, and quick reporting requirements these amounts were inconsistently reported. The finding and significant deficiency is due to a prior lack of understanding over the compliance requirement of implementation due to COVID-19. Repeat finding: No Recommendation: We recommend additional training and updated quarterly reports be submitted. We also recommend that future expenses be coded timely to grants for reporting purposes. Views of responsible officials and planned corrective actions: Controls are in place for the Finance Division to ensure that account balances are reconciled on a timely basis to support the general ledger for the year end closing. This is to ensure that the internal controls required by the Generally Accepted Accounting Principles are followed in the financial closing and to prepare the accurate Schedule of Expenditures of Federal Awards (SEFA) in accordance with the Uniform Guidance. The Finance Division will review and strengthen its processes and controls to ensure that the reconciliations of account balances are done on a timely basis to make sure that the expenses reported in the quarterly reports are tied to the SEFA and general ledger. Anticipated completion of the corrective action is expected by September 2022.

FINDING 2020-003 ? Special Tests and Provisions ? Return of Title IV FundsSignificant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education CFDA Number: 84.063, 84.007, 84.033 Federal Program Name: Student Financial Assistance Cluster Award Year: 2019-20 Criteria: Per 34 CFR Section 668.22, when a student withdraws from an institution before completion of their current academic period and is determined as having not earned 100 percent of their received Title IV assistance, an institution must return the total amount of unearned Title IV assistance received from withdrawn students. Return of Title IV funds (R2T4) are required to be deposited or transferred into the Student Financial Assistance account or electronic fund transfers initiated to the Department of Education (ED) as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the cancelled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Condition and Context: A sample of 23 students who were recipients of Title IV funding and had withdrawn during the year was selected. Student records were compared to the calculation of the return of Title IV funds. We noted there were inconsistencies within the calculations, creating variances between what was returned, and what should have been returned. Additionally, the Title IV funds were not returned within the 45-day period as required. The Financial Aid office recalculated each of the R2T4 calculations for the entire population of both unofficial and official withdrawals during the award period 2019-2020, that were under the 60% attendance requirement. This resulted in 24 recalculations, and a total net adjustment in the amount of $11,061, which was returned to the Department of Education subsequent to year end. Questioned costs: $11,061 Effect: The College had not returned all Title IV funds related to their R2T4 calculations in the time required by ED. Of the total 13 incorrect calculations, the calculations were subsequently corrected and returned to ED. Cause: This occurred because the process in place was not designed effectively to calculate the return of Title IV funds and to remit amounts on a timely basis. Cause: This occurred because the process in place was not designed effectively to calculate the return of Title IV funds and to remit amounts on a timely basis. Repeat finding: Yes Recommendation: We recommend the College implement a process in which an individual in the student financial aid department review each return of Title IV funds calculation prior to executing the return. The review should be documented to ensure completion. Additional controls should be implemented to ensure that both unofficial and official withdrawals are calculated and returned on a timely basis. Views of responsible officials and planned corrective actions: The Financial Aid Officer is responsible for the review of R2T4 compliance and has updated the regulations and procedures to ensure this finding is corrected and adhered to. The Financial Aid Officer has been charged by the Dean of Student Services to enforce and monitor this internal control. Corrective measures/actions will be implemented when standard operating procedures/internal controls are not followed. Further consequences will be subjected to the review of the Vice President of Academic, Community, and Student Affairs, and the President. Anticipated completion of the corrective action is expected by August 2021.

FINDING 2020-004 ? Enrollment Reporting, Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education CFDA Number: 84.063 Federal Program Name: Federal Pell Grant Program Award Year: 2019-20 Criteria: Per 34 CFR Section 690.83, the National Student Loan Data System (NSLDS) is the Department of Education?s centralized database for students? enrollment information. It is the College?s responsibility to update this information timely and accurately. Condition and context: The College determines how often it receives the Enrollment Reporting roster file with the default set at every 60 days. The College has engaged the National Student Clearinghouse's (NSC) services to assist with the reporting of student's status changes and degrees to the NSLDS. In our audit sample of 19 withdrawals and 8 graduated students, none had been reported timely. Subsequently, the withdrawn student status was corrected for the sampled students, but not within the required timeframe. Our sample was selected using a random sampling methodology, rather than a statistical sampling methodology. Questioned costs: None noted Effect: This information is utilized by ED, the Federal Direct Loan program, lenders, and other institutions to determine in-school status. American Samoa Community College doesn?t participate in loan programs, which limits the effect of non-compliance. Cause: This occurred because of a lack of control in place to monitor for compliance. Repeat finding: Yes Recommendation: We recommend the College follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. Furthermore, we recommend the College educate staff involved in the process regarding the Enrollment Reporting compliance responsibilities and the consequences of inaccurate reporting to the NSLDS via the NSC. This policy should specifically address the personnel assigned to various tasks (data entry and review). Opportunities for additional NSC training in this area and others are available through the NSC?s Clearinghouse Academy page. Lastly, we recommend the College establish an internal monitoring control whereby a designated individual with NSLDS access, spot-checks the status updates on NSLDS on a sample basis so as to internally audit the submissions. Views of responsible officials and planned corrective actions: The Financial Aid Officer will be responsible for the review of NSLDS reporting and has updated regulations and procedures to ensure the NSLDS report is updated in a timely manner. The procedure was revised on 12/7/2020 as follows: The Financial Aid Coordinator has been assigned to complete bimonthly updates to the Enrollment Report roster file in spreadsheet transmitted from the NSLDS, with the Counselor II as the alternate. This practice will eliminate interruptions in the completion of the reporting requirements. The Financial Aid Officer (alternately the Financial Aid Counselor III) conducts a final review of this spreadsheet for submission to NSLDS. For graduates and official withdrawals, students who graduate will be updated into NSLDS within one week after graduation. Students who completely withdraw from ASCC will be updated into the NSLDS system within one week after performance of R2T4. Students who earned zero-credits and are unofficial withdrawals will be updated into NSLDS within 45 days. Anticipated completion of the corrective action is expected by August 2021.

FINDING 2020-005 ? Special Tests and Provisions ? Gramm-Leach-Bliley Act ? Student Information Security; Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education CFDA Number: 84.063, 84.007, 84.033 Federal Program Name: Student Financial Assistance Cluster Award Year: 2019-20 Criteria: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the Gramm-Leach-Bliley Act (16 CFR313.3(k)(2)(vi). Under an institution?s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)) Condition and context: A written risk assessment wasn?t performed that addressed the three required areas noted in 6 CFR 314.4 (b), which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3)Detecting, preventing and responding to attacks, intrusions, or other systems failures. Questioned costs: None noted Effect: The College does have limited controls in place surrounding student information security, which limits the effect of non-compliance. Cause: The finding and significant deficiency is due to the lack of understanding over the compliance requirement. Repeat finding: Yes Recommendation: We recommend the College designate an individual to coordinate the information security program. This individual should perform and document a risk assessment that addresses the three required areas noted in 16 CFR 314.4 (b), which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures. Views of responsible officials and planned corrective actions: The College will designate the newly hired Information Officer to coordinate and propose a data/information security program to be adopted by the College. The Vice President of Administration and Finance will review all proposed rules and regulations, and policies that pertain to data/information systems, accessibility, security, data transmission and disposal, annual training, and will propose the necessary clarifications in rules and regulations for the review of the College President. The Information Officer will implement and document a risk assessment to address the three required areas as referenced in 16 CFR 314.4 (b) that include, Employee training and management; information systems, including network and software design, as well as information processing, storage, transmission and disposal; and, Detecting, preventing and responding to attacks, intrusions, or other systems failure.

FINDING 2019-003 Special Tests and Provisions ? Return of Title IV Funds Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education CFDA Number: 84.063, 84.007, 84.033 Federal Program Name: Student Financial Assistance Cluster Award Year: 2018-19 Criteria: Per 34 CFR Section 668.22, when a student withdraws from an institution before completion of their current academic period and is determined as having not earned 100 percent of their received Title IV assistance, an institution must return the total amount of unearned Title IV assistance received from withdrawn students. Return of Title IV funds (R2T4) are required to be deposited or transferred into the Student Financial Assistance account or electronic fund transfers initiated to the U.S. Department of Education (ED) as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Condition and Context: A sample of 10 students who were recipients of Title IV funding and had withdrawn during the year was selected from a population of 25. Student records were compared to the calculation of the return of Title IV funds. We noted there were inconsistencies within the calculations, creating variances between what was returned and what should have been returned. Additionally, the Title IV funds were not returned within the 45-day period as required. The Financial Aid office recalculated each of the R2T4 calculations for the entire population of both unofficial and official withdrawals during the award period 2018-2019 that were under the 60% attendance requirement. This resulted in 24 recalculations and a total net adjustment in the amount of $7,371, which was returned to the ED subsequent to year end. Questioned costs: $7,371 Effect: The College had not returned all Title IV funds related to their R2T4 calculations in the time required by ED. Of the total 24 incorrect calculations, the calculations were subsequently corrected and returned to ED. Cause: This occurred because the process in place was not designed effectively to calculate the return of Title IV funds and to remit amounts on a timely basis. Repeat finding: No Recommendation: We recommend the College implement a process in which an individual in the student financial aid department review each return of Title IV funds calculation prior to executing the return. The review should be documented to ensure completion. Additional controls should be implemented to ensure that both unofficial and official withdrawals are calculated and returned on a timely basis.

FINDING 2019-004 Enrollment Reporting Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education CFDA Number: 84.063 Federal Program Name: Federal Pell Grant Program Award Year: 2018-19 Criteria: The National Student Loan Data System (?NSLDS?) is the U.S. Department of Education?s (ED) centralized database for students? enrollment information. It is the College?s responsibility to update this information timely and accurately. The College determines how often it receives the Enrollment Reporting roster file with the default set at every 60 days. The College has engaged the National Student Clearinghouse's (NSC) services to assist with the reporting of student's status changes and degrees to the NSLDS. Condition and context: In our audit sample of 10 withdrawals and 10 graduated students, none had been reported timely. Subsequently, the withdrawn student status had been corrected for the sampled students, but not within the required timeframe. Our sample was selected using a random methodology, rather than a statistical sampling methodology. Questioned costs: None noted Effect: This information is utilized by ED, the Federal Direct Loan program, lenders, and other institutions to determine in-school status. The College doesn?t participate in loan programs, which limits the effect of non-compliance. Cause: This occurred because of a lack of control in place to monitor for compliance. Repeat finding: No Recommendation: We recommend the College follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. Furthermore, we recommend the College educate staff involved in the process regarding the Enrollment Reporting compliance responsibilities and the consequences of inaccurate reporting to the NSLDS via the NSC. This policy should specifically address the personnel assigned to various tasks (data entry and review). Opportunities for additional NSC training in this area and others are available through the NSC?s Clearinghouse Academy page. Lastly, we recommend the College establish an internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot-checks the status updates on NSLDS so as to internally audit the submissions

FINDING 2019-005 Special Tests and Provisions ? Gramm-Leach-Bliley Act ? Student Information Security Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education CFDA Number: 84.063, 84.007, 84.033 Federal Program Name: Student Financial Assistance Cluster Award Year: 2018-19 Criteria: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Under an institution?s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)) Condition and context: A written risk assessment wasn?t performed that addressed the three required areas noted in 6 CFR 314.4 (b), which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures. Questioned costs: None noted Effect: The College does have limited controls in place surrounding student information security, which limits the effect of non-compliance. Cause: The finding and significant deficiency is due to the lack of understanding over the compliance requirement. Repeat finding: No Recommendation: We recommend the College designate an individual to coordinate the information security program. This individual should perform and document a risk assessment that addresses the three required areas noted in 16 CFR 314.4 (b), which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures.

FINDING 2019-006 ? Equipment and Real Property Management, Significant Deficiency in Internal Control Over Compliance U.S. Department of Agriculture CFDA Number: 10.511 Federal Program Name: Smith-Lever Funding (Various Programs) Award Year: 2018-19 Criteria: Per 2 CFR 215.34(3) - A physical inventory of equipment shall be taken and the results reconciled with the equipment records at least once every two years. Condition: The College did not inventory all equipment purchased with federal funds within the last two years. Context: During our testing of equipment and real property management, we noted that for all four items in our sample, an inventory of these items had not been performed in the prior two years. Our sample was selected using a random methodology, rather than a statistical sampling methodology. Cause: It appears the controls in place were not designed properly to ensure an inventory was being performed every two years. Repeat finding: No Effect: The lack of policies in place create non-compliance to the requirement that equipment purchased with federal funds be inventoried at least once every two years. Questioned costs: None noted. Recommendation: We recommend the College ensure that all equipment purchased with federal funds is tagged and inventoried every two years. In addition, the College should maintain documentation of when the inventory takes place and have procedures in place to track any new additions or disposals.

FINDING 2019-007 ? Allowable Costs/Cost Principles, Significant Deficiency in Internal Control Over Compliance U.S. Department of Agriculture CFDA Number: 10.511 Federal Program Name: Smith-Lever Funding (Various Programs) Award Year: 2018-19 Criteria: Per 2 CFR ? 200.445 - Goods or services for personal use - Costs of housing (e.g., depreciation, maintenance, utilities, furnishings, rent), housing allowances and personal living expenses are only allowable as direct costs regardless of whether reported as taxable income to the employees. In addition, to be allowable, direct costs must be approved in advance by a Federal awarding agency. Condition: The College applied housing allowance expenditures to the grant, based on the faculty time allocated to the grant. The College used the housing allowance to recruit faculty members from off island to work on the grant. Context: During our testing of Allowable Costs/Cost Principles, we selected a sample of 25 items from a population of 361. Two of the 25 selections were for housing allowances, which is a part of faculty contracts in these cases. These costs are unallowable per Uniform Guidance without prior approval from the awarding agency, which was not obtained in advance. Cause: The College lacked an understanding of what is allowable to be charged to the grant. Repeat finding: No. Effect: Unallowable costs were allocated to the grant without prior approval. Based upon additional review of the costs to the grant during the current fiscal year, we noted four faculty members for which a housing allowance was paid as part of their contracts. The housing allowance expenditures totaled $20,550 during the current fiscal year. Questioned costs: $20,550 Recommendation: We recommend the College implement controls to ensure that all costs are allowable to the grant prior to reimbursement. In addition, we recommend the College contact the federal agency for approval of these expenditures or return the expenditures to the awarding agency.

FINDING 2019-008 ? Allowable Costs/Cost Principles, Significant Deficiency in Internal Control Over Compliance U.S. Department of Agriculture CFDA Number: 10.511 Federal Program Name: Smith-Lever Funding (Various Programs) Award Year: 2018-19 Criteria: Per 2 CFR ? 200.430 ? Compensation ? personal services, (i) Allowable activities. Charges to Federal awards may include reasonable amounts for activities contributing and directly related to work under an agreement, such as delivering special lectures about specific aspects of the ongoing activity, writing reports and articles, developing and maintaining protocols (human, animals, etc.), managing substances/chemicals, managing and securing project-specific data, coordinating research subjects, participating in appropriate seminars, consulting with colleagues and graduate students, and attending meetings and conferences. Condition: The College completes time and effort reports for faculty and staff members who apply time to grants. The payroll expenditures allocated to the grant did not represent the proportionate share of time as reported. Context: During our testing of Allowable Costs/Cost Principles, we selected a sample of 26 items from a population of 13,564. Two of the 26 selections? time and effort report did not represent the amount of expenditure allocated to the grant. These costs are unallowable based upon the Uniform Guidance, as the proportionate share of payroll costs should have been allocated based on the time and effort reports. Cause: It appears the controls in place were designed effectively but were not implemented correctly to ensure that payroll costs would be allocated based on the time and effort reports for the period. Repeat finding: No. Effect: Unallowable costs were charged to the grant. Questioned costs: $605 Recommendation: We recommend the College implement controls to ensure that all costs are allowable to the grant prior to reimbursement. Additional controls should be in place to review the allocated payroll, to the time and effort reports every payroll cycle to ensure accuracy of the allocation.

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