EIN: 836009473
UEI: HJ2LVM1L2JU7
Audited by: MHP Assurance Services LLP
Oversight agency: 84 [Department of Education]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 20, 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 20, 2026 (45 days ago).
What is a management decision? →2025-001: Student Financial Aid Cluster - Reporting (Significant Deficiency; Noncompliance) Criteria: Per 34 CFR 675.19(b)(3) and 676.19(b)(3), each year an institution shall submit a Fiscal Operations Report plus other information the Secretary requires. The institution shall ensure that the information reported is accurate and shall submit it on the form and at the time specified by the Secretary. Per the Fiscal Operations Report for the 2023-24 and Application to Participate for 2025-26 Instructions for Part II (Application) Section E, the tuition and fees revenue entered must only be for those students reported in Section D. Condition/context: Tuition and fees for the award year July 1, 2023 to June 30, 2024 reported under Part II (Application) Section E of the Fiscal Operations Report and Application to Participate (FISAP) was incorrectly reported as $11,024,548. The correct amount was $10,380,652. Cause: Human error. Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Additionally, incorrect reporting in the FISAP may result in incorrect award calculations by the Department of Education. The College may be required to return funds to which it is not entitled. Questioned costs: None. Identification as a repeat finding: No. Recommendation: The College should develop, implement, and maintains a thorough system of review of the FISAP to ensure that accurate information is reported. Views of responsible officials and planned corrective actions: Management concurs with the finding. See Exhibit I.
Show full finding ▾Hide full finding ▴2025-001: Student Financial Aid Cluster - Reporting (Significant Deficiency; Noncompliance) Criteria: Per 34 CFR 675.19(b)(3) and 676.19(b)(3), each year an institution shall submit a Fiscal Operations Report plus other information the Secretary requires. The institution shall ensure that the information reported is accurate and shall submit it on the form and at the time specified by the Secretary. Per the Fiscal Operations Report for the 2023-24 and Application to Participate for 2025-26 Instructions for Part II (Application) Section E, the tuition and fees revenue entered must only be for those students reported in Section D. Condition/context: Tuition and fees for the award year July 1, 2023 to June 30, 2024 reported under Part II (Application) Section E of the Fiscal Operations Report and Application to Participate (FISAP) was incorrectly reported as $11,024,548. The correct amount was $10,380,652. Cause: Human error. Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Additionally, incorrect reporting in the FISAP may result in incorrect award calculations by the Department of Education. The College may be required to return funds to which it is not entitled. Questioned costs: None. Identification as a repeat finding: No. Recommendation: The College should develop, implement, and maintains a thorough system of review of the FISAP to ensure that accurate information is reported. Views of responsible officials and planned corrective actions: Management concurs with the finding. See Exhibit I.
2025-001 Student Financial Aid Cluster- Reporting Anticipated completion date: Done Contact person: Nola Rocha Corrective actions: The incorrect inclusion of non-credit course data for new programs in the annual FISAP report resulted from a misinterpretation of reporting criteria. This isolated error affected one reporting element within an otherwise accurate submission. The issue was promptly addressed through clarification of FISAP guidance, staff retraining, and updates to procedural documentation and review checklists to ensure non-credit course activity is properly excluded in future reports. While the dollar amount could be viewed as measurable the financial reporting would not result in any financial impact, as the Department of Education allocates Campus-Based Program funds based on institutional requests and does not provide allocations in excess of those requests.
2025-002: Student Financial Audit Cluster - Special Tests: Return of Title IV Funds and NSLDS Reporting (Significant Deficiency; Noncompliance) Criteria: Per 34 CFR 668.173(b), returns of Title IV funds are required to be deposited or transferred into the bank account maintained under 34 CFR 668.163 or via electronic fund transfers initiated to the U.S. Department of Education as soon as possible, but no later than 45 days after 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 that 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. Per 34 CFR 685.309(b), “Upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary - (i) In the manner and format prescribed by the Secretary; and (ii) Within the timeframe prescribed by the Secretary.” Condition/context: Of the 15 students selected to test both the proper return of Title IV funds and National Student Loan Data System (NSLDS) reporting, we noted the following errors: • Two instances where the funds were not returned within the 45-day period allowed; and • One instance in which the student was not reported within 60 days of the date of determination. Cause: Human error. Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Questioned costs: None. Identification as a repeat finding: No. Recommendation: The Student Financial Aid Office and Registrar’s Office should consider additional controls to ensure the proper review and identification of withdrawals for timeliness of refund payments and reporting to NSLDS. Views of responsible officials and planned corrective actions: Management concurs with the finding. See Exhibit I.
Show full finding ▾Hide full finding ▴2025-002: Student Financial Audit Cluster - Special Tests: Return of Title IV Funds and NSLDS Reporting (Significant Deficiency; Noncompliance) Criteria: Per 34 CFR 668.173(b), returns of Title IV funds are required to be deposited or transferred into the bank account maintained under 34 CFR 668.163 or via electronic fund transfers initiated to the U.S. Department of Education as soon as possible, but no later than 45 days after 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 that 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. Per 34 CFR 685.309(b), “Upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary - (i) In the manner and format prescribed by the Secretary; and (ii) Within the timeframe prescribed by the Secretary.” Condition/context: Of the 15 students selected to test both the proper return of Title IV funds and National Student Loan Data System (NSLDS) reporting, we noted the following errors: • Two instances where the funds were not returned within the 45-day period allowed; and • One instance in which the student was not reported within 60 days of the date of determination. Cause: Human error. Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Questioned costs: None. Identification as a repeat finding: No. Recommendation: The Student Financial Aid Office and Registrar’s Office should consider additional controls to ensure the proper review and identification of withdrawals for timeliness of refund payments and reporting to NSLDS. Views of responsible officials and planned corrective actions: Management concurs with the finding. See Exhibit I.
2025-002: Student Financial Audit Cluster - Special Tests: Return of T itle IV Funds and NSLDS Reporting Anticipated completion date: done - June 18, 2025 Contact person: Brandi Payne Cervera Corrective actions: The two late aid returns were made under the following circumstances. Student's effective date of the withdrawal was March 25, 2025. However, the withdrawal was not processed in our Colleague system until April 9, 2025. The backdated effective date of the withdrawal in Colleague did not appear on our enrollment activity report that is used to identify complete withdrawals because this report is run weekly using a defined date range. As a result, the student's withdrawal was not identified in a timely manner. The withdrawal was identified by our Assistant Director upon her review of students with all non-passing grades at the end of the semester prior to the audit testing (see existing procedure/internal control below). The return-of-funds was processed as soon as the withdrawal was discovered, but it was out of the 45-day required timeframe. We have implemented a new procedure, as follows. New procedure (backdated withdrawal): The Registrar's Office will immediately notify Financial Aid of any withdrawals received by the Registrar's Office that require a backdated effective date in Colleague to ensure that we are returning funds within the required timeframe. The Financial Aid Director, Assistant Director of Financial Aid, and the Registrar met and developed this new procedure. The procedure was implemented on June 18, 2025. An institution must certify enrollment information to the National Student Loan Data System (NSLDS) every 60 days. Because of the issue with the backdated effective date of the withdrawal described above, the enrollment reporting for this student was made outside of the 60-day reporting window. I request the removal of the NSLDS reporting deficiency since the late processing of the student's withdrawal and return-of-funds was the root cause of the late NSLDS reporting, and there were no other enrollment reporting issues. The second late return was due to human error. After a R2T4 calculation has been performed, there is an "Update Student Aid" button on the ROFC screen in Colleague that must be manually marked "yes" in order for the return of- funds to post to the student's account. This step was missed for one student which caused the late return-of-funds outside of the required 45-day timeframe. New procedure (human error): Assistant Director has put a standing item on her calendar to review RT24's every Wednesday with a notation to check the "Update Student Aid" box in Colleague so that the return will occur. The Assistant Director will also check the list of withdrawals after each weekly aid transmittal to make sure the aid returns have all posted to the student accounts as expected. This procedure was put into place on June 18, 2025. Existing Procedure/Internal Control: We can say with certainty that out of the 165 withdrawals for the 2024/2025 award year, the two students identified in the audit were the only two late returns. The Assistant Director of Financial Aid reviews all students with non-passing grades at the end of each semester to identify unofficial withdrawals and to ensure that all returns were made appropriately and that no R2T4 calculations were missed. Potential issues are identified through this end-of-semester review. This is how the issue with the backdated withdrawal date described above was discovered. She will continue this effective internal control process each semester which will confirm that our new procedures are working as intended.
FAC accepted this audit on December 18, 2024 — management decision was due June 18, 2025.
FAC accepted this audit on January 26, 2024 — management decision was due July 26, 2024.
Criteria: 34 CFR 668.22(a)(6)(iii)(A) requires an institution to provide, within 30 days of the date the institution determines that a student has withdrawn, written notification to the student, or the parent in the case of a Parent PLUS loan, detailing the specific items outlined in paragraphs 1-5 of the aforementioned section. Condition/context: Of the 20 students selected for testing the proper return of Title IV funds, we noted one instance in which the student was eligible for a post-withdrawal disbursement of loan funds. In this instance, the College did not provide written notification to the student and the student was disbursed loan funds. Cause: The Student Financial Aid Office does not have a control in place to ensure that it provides written notification of post-withdrawal eligibility prior to a disbursement. Effect: The College could disburse funds to students or parents who did not wish to receive them. Questioned costs: None. Identification as a repeat finding: No. Recommendation: The Student Financial Aid Office should implement a control to ensure that the proper notification is sent to students who are eligible for a post-withdrawal disbursement. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Show full finding ▾Hide full finding ▴Criteria: 34 CFR 668.22(a)(6)(iii)(A) requires an institution to provide, within 30 days of the date the institution determines that a student has withdrawn, written notification to the student, or the parent in the case of a Parent PLUS loan, detailing the specific items outlined in paragraphs 1-5 of the aforementioned section. Condition/context: Of the 20 students selected for testing the proper return of Title IV funds, we noted one instance in which the student was eligible for a post-withdrawal disbursement of loan funds. In this instance, the College did not provide written notification to the student and the student was disbursed loan funds. Cause: The Student Financial Aid Office does not have a control in place to ensure that it provides written notification of post-withdrawal eligibility prior to a disbursement. Effect: The College could disburse funds to students or parents who did not wish to receive them. Questioned costs: None. Identification as a repeat finding: No. Recommendation: The Student Financial Aid Office should implement a control to ensure that the proper notification is sent to students who are eligible for a post-withdrawal disbursement. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Corrective Action: The College’s Return of Title IV Funds procedure was reviewed. The following language was revised in the post-withdrawal disbursement (PWD) section of this procedure as a control to ensure that advanced written notification is not missed in the future: A written notification will be sent to a student (or parent) that is eligible for a PWD of Federal Direct Loan within 30 days of the date of determination. The type and amount of Title IV loan funds that will be credited to the student’s charges and the amount that will directly disburse will be offered to the student, or the parent in the case of a PLUS Loan. The notification will explain that the student or parent can accept all or part of the loan disbursement and will advise the student or parent that no post-withdrawal disbursement of Title IV loan funds will be made unless the school receives a confirmation response within the established timeframe of 14 days. Please note that loan PWDs are very rare at the College because the vast majority of our students that wish to borrow complete their loan requirements and receive their loan disbursement prior to their withdrawal date. In the case of the student noted in the finding, the student completed his loan requirements (i.e., master promissory note and loan entrance counseling) only a couple of days before the date he became ineligible. We acknowledge an advanced written notice was not sent, but please note that a written notification was sent to the student immediately following the loan disbursement informing the student about his right to cancel all or part of the loan and the procedures and timeframe in which to do so. Anticipated Completion Date: July 1, 2023 Contact Person: Brandi Payne Cervera
Criteria: 16 CFR 314.3 requires an institution to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to the institution’s size and complexity, the nature and scope of activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in §314.4 and shall be reasonably designed to achieve the objectives of this part. Condition/context: The College does not have a written comprehensive information security program that addresses all of the elements required by 16 CFR 314.4. Cause: The College does not have a control in place to ensure that policies are reviewed and updated in accordance with Federal deadlines. Effect: The College is not compliant with the Gramm-Leach-Bliley Act. Questioned costs: None. Identification as a repeat finding: No. Recommendation: The College should implement a control to monitor changes in Federal guidelines in order to update policies timely. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Show full finding ▾Hide full finding ▴Criteria: 16 CFR 314.3 requires an institution to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to the institution’s size and complexity, the nature and scope of activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in §314.4 and shall be reasonably designed to achieve the objectives of this part. Condition/context: The College does not have a written comprehensive information security program that addresses all of the elements required by 16 CFR 314.4. Cause: The College does not have a control in place to ensure that policies are reviewed and updated in accordance with Federal deadlines. Effect: The College is not compliant with the Gramm-Leach-Bliley Act. Questioned costs: None. Identification as a repeat finding: No. Recommendation: The College should implement a control to monitor changes in Federal guidelines in order to update policies timely. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Corrective Action: The College was aware of the new required elements for our comprehensive information security program procedure but missed the June 9 deadline to finalize the procedure changes. The required Gramm-Leach-Bliley Act procedures were in draft form at the time of the audit review. The required procedures were finalized in July and approved by the President’s Cabinet on August 1, 2023, and were effective on that same date. The approved procedures address all elements as required by 16 CFR 314.4, and the College is now in full compliance with the Gramm-Leach-Bliley Act. Anticipated Completion Date: August 1, 2023 Contact Person: Chad Marley
FAC accepted this audit on December 6, 2022 — management decision was due June 6, 2023.
See Schedule of Findings and Questioned Cost for chart/table 2022-001: Reporting Criteria: 2 CFR 200.327 ? Financial Reporting; and the laws, regulations, and the provisions of contract or grant agreements pertaining to the specific programs require that reports be complete, accurate, and supported by accounting records (if applicable) and be submitted in compliance with the appropriate deadlines. Condition/Context: A total of five reports were selected for testing, this included one annual report, two quarterly reports related to the Student Portion and two quarterly reports related to the Institutional Portion. Of these five reports: ? The Quarterly Institutional report for the period ending September 30, 2021 improperly categorized $165,000 of expenditures as software as opposed to the proper category, revenue replacement. ? The Annual report for the period ending December 31, 2021 improperly categorized $165,000 of expenditures as software as opposed to the proper category, revenue replacement. Additionally, revenue replacement expenditures were improperly reported by $37,910. Questioned Costs: $0 Cause: The College's internal control system did not have a sufficient control process in place to ensure all reports were accurate or a sufficient control process to review the reports for propriety to identify errors. Effect: If a non-Federal entity fails to comply with Federal statutes, regulations or the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, which include requiring payments as reimbursements rather than advance payments, withholding authority to proceed to the next phase until receipt of evidence of acceptable performance within a given period of performance, require additional, more detailed financial reports, require additional project monitoring, require the non-Federal entity to obtain technical or management assistance, and establish additional prior approvals. If the Federal awarding agency determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding agency may take one or more of the following actions, as appropriate in the circumstances: ? Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency. ? (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. ? (c) Wholly or partly suspend or terminate the Federal award. ? (d) Initiate suspension or debarment proceedings as authorized under 2 CFR part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). ? (e) Withhold further Federal awards for the project or program. ? (f) Take other remedies that may be legally available. Identifications as a Repeat Finding: Yes. Recommendation: We recommend the College revise its control procedures to ensure reporting is completed accurately and to include an independent review before submission Views of Responsible Officials: Management concurs with the finding. See Exhibit I.
Show full finding ▾Hide full finding ▴See Schedule of Findings and Questioned Cost for chart/table 2022-001: Reporting Criteria: 2 CFR 200.327 ? Financial Reporting; and the laws, regulations, and the provisions of contract or grant agreements pertaining to the specific programs require that reports be complete, accurate, and supported by accounting records (if applicable) and be submitted in compliance with the appropriate deadlines. Condition/Context: A total of five reports were selected for testing, this included one annual report, two quarterly reports related to the Student Portion and two quarterly reports related to the Institutional Portion. Of these five reports: ? The Quarterly Institutional report for the period ending September 30, 2021 improperly categorized $165,000 of expenditures as software as opposed to the proper category, revenue replacement. ? The Annual report for the period ending December 31, 2021 improperly categorized $165,000 of expenditures as software as opposed to the proper category, revenue replacement. Additionally, revenue replacement expenditures were improperly reported by $37,910. Questioned Costs: $0 Cause: The College's internal control system did not have a sufficient control process in place to ensure all reports were accurate or a sufficient control process to review the reports for propriety to identify errors. Effect: If a non-Federal entity fails to comply with Federal statutes, regulations or the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, which include requiring payments as reimbursements rather than advance payments, withholding authority to proceed to the next phase until receipt of evidence of acceptable performance within a given period of performance, require additional, more detailed financial reports, require additional project monitoring, require the non-Federal entity to obtain technical or management assistance, and establish additional prior approvals. If the Federal awarding agency determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding agency may take one or more of the following actions, as appropriate in the circumstances: ? Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency. ? (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. ? (c) Wholly or partly suspend or terminate the Federal award. ? (d) Initiate suspension or debarment proceedings as authorized under 2 CFR part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). ? (e) Withhold further Federal awards for the project or program. ? (f) Take other remedies that may be legally available. Identifications as a Repeat Finding: Yes. Recommendation: We recommend the College revise its control procedures to ensure reporting is completed accurately and to include an independent review before submission Views of Responsible Officials: Management concurs with the finding. See Exhibit I.
2022-001: Reporting Corrective Action: Due to ever-evolving processes, LCCC did not fully comprehend all reporting nuances for the HEER program. The Comptroller and Director of Sponsored Awards will continue to perform in-depth reviews of all reporting guidance and requirements to ensure accurate reporting. Anticipated Completion Date: June 30, 2023 Contact Persons: Nola Rocha, Comptroller and Jennifer McCartney, Director of Sponsored Awards and Compliance
2021-001
FAC accepted this audit on December 15, 2021 — management decision was due June 15, 2022.
See Schedule of Findings and Questioned Costs for chart/table. Criteria: 2 CFR 200.327 ? Financial Reporting; and the laws, regulations, and the provisions of contract or grant agreements pertaining to the specific programs require that reports be complete, accurate, and supported by accounting records (if applicable) and be submitted in compliance with the appropriate deadlines. Per various guidance published by ED, the Higher Education Emergency Relief Fund (HEERF) portion of the ESF requires the following with respect to reporting: ? Annual reporting: The HEERF Data Collection Form was required to be submitted to ED via the Annual Report Data Collection System on February 8, 2021 and applied to the reporting period from March 13, 2020 through December 31, 2020. ? Quarterly public reporting (student portion): Institutes of Higher Education (IHE) was required to publicly post certain information on its website no later than 30 days after award and update that information every 45 days thereafter. However, on August 31, 2020, ED revised the requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Instead of posting a 45-day report on or after August 31, 2020, IHE should post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after its last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. IHE may have until the end of the second calendar quarter, June 30, 2021, to post these retroactive reports if it has not already done so. ? Quarterly public reporting (institutional portion): A new, separate form was to be posted covering aggregate amounts spent for all HEERF funds each quarterly reporting period. IHE must post this quarterly report form no later than 10 days after the end of each calendar quarter apart from the first report, which was due on October 30, 2020, and the report covering the first quarter of 2021, which was due on July 10, 2021. The forms are required to be conspicuously posted on the institution?s primary website on the same page the reports of IHE?s activities as to the emergency financial aid grants to students (Student Portion) are posted. Condition/context: A total of three reports were selected for testing, including one annual report, one quarterly report related to the Student Portion and one quarterly report related to the Institutional Portion. Of these three reports: ? The Quarterly Student number for the period ended March 31, 2021 did not properly include the number of students eligible to receive emergency financial aid. ? The Quarterly Institutional for the period ended December 31, 2020 was not properly posted to the College?s webpage. Questioned costs: $0 Cause: The College?s internal control system did not have a sufficient control process in place to ensure all reports were accurate and properly posted to the College?s website or a sufficient control process to review the reports for propriety to identify errors. Effect: If a non-Federal entity fails to comply with Federal statutes, regulations, or the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, which include requiring payments as reimbursements rather than advance payments; withholding authority to proceed to the next phase until receipt of evidence of acceptable performance within a given period of performance; requiring additional, more detailed financial reports; requiring additional project monitoring; requiring the non-Federal entity to obtain technical or management assistance; and establishing additional prior approvals. If the Federal awarding agency determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding agency may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR Part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Identification as a repeat finding: No. Recommendation: We recommend the College implement control procedures to ensure required reporting is completed. Additionally, we recommend the College revise its procedures to include an independent review of reports for accuracy before they are submitted and posted. Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I.
Show full finding ▾Hide full finding ▴See Schedule of Findings and Questioned Costs for chart/table. Criteria: 2 CFR 200.327 ? Financial Reporting; and the laws, regulations, and the provisions of contract or grant agreements pertaining to the specific programs require that reports be complete, accurate, and supported by accounting records (if applicable) and be submitted in compliance with the appropriate deadlines. Per various guidance published by ED, the Higher Education Emergency Relief Fund (HEERF) portion of the ESF requires the following with respect to reporting: ? Annual reporting: The HEERF Data Collection Form was required to be submitted to ED via the Annual Report Data Collection System on February 8, 2021 and applied to the reporting period from March 13, 2020 through December 31, 2020. ? Quarterly public reporting (student portion): Institutes of Higher Education (IHE) was required to publicly post certain information on its website no later than 30 days after award and update that information every 45 days thereafter. However, on August 31, 2020, ED revised the requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Instead of posting a 45-day report on or after August 31, 2020, IHE should post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after its last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. IHE may have until the end of the second calendar quarter, June 30, 2021, to post these retroactive reports if it has not already done so. ? Quarterly public reporting (institutional portion): A new, separate form was to be posted covering aggregate amounts spent for all HEERF funds each quarterly reporting period. IHE must post this quarterly report form no later than 10 days after the end of each calendar quarter apart from the first report, which was due on October 30, 2020, and the report covering the first quarter of 2021, which was due on July 10, 2021. The forms are required to be conspicuously posted on the institution?s primary website on the same page the reports of IHE?s activities as to the emergency financial aid grants to students (Student Portion) are posted. Condition/context: A total of three reports were selected for testing, including one annual report, one quarterly report related to the Student Portion and one quarterly report related to the Institutional Portion. Of these three reports: ? The Quarterly Student number for the period ended March 31, 2021 did not properly include the number of students eligible to receive emergency financial aid. ? The Quarterly Institutional for the period ended December 31, 2020 was not properly posted to the College?s webpage. Questioned costs: $0 Cause: The College?s internal control system did not have a sufficient control process in place to ensure all reports were accurate and properly posted to the College?s website or a sufficient control process to review the reports for propriety to identify errors. Effect: If a non-Federal entity fails to comply with Federal statutes, regulations, or the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, which include requiring payments as reimbursements rather than advance payments; withholding authority to proceed to the next phase until receipt of evidence of acceptable performance within a given period of performance; requiring additional, more detailed financial reports; requiring additional project monitoring; requiring the non-Federal entity to obtain technical or management assistance; and establishing additional prior approvals. If the Federal awarding agency determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding agency may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR Part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Identification as a repeat finding: No. Recommendation: We recommend the College implement control procedures to ensure required reporting is completed. Additionally, we recommend the College revise its procedures to include an independent review of reports for accuracy before they are submitted and posted. Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I.
2021-001: Reporting Corrective Action: Due to ever-evolving processes, LCCC did not fully comprehend all reporting requirements for the HEERF program this past fiscal year. Regarding the Current year, the Interim Director of Sponsored Awards and Compliance and the Comptroller have closely reviewed all posted reporting requirements, as well as the October 2021 letter from the Dept. of Education listing the new requirements for HEERF quarterly reporting. Moving forward, the Interim Director of Sponsored Awards and Compliance, together with the Comptroller, will review the Department of Education website for any changes and will corroborate to ascertain that accurate amounts and information are included in each quarterly report. In addition, an independent review will be requested to assess all reports for accuracy before the reports are posted/submitted. Anticipated Completion Date: June 30, 2022 Contact Persons: Nola Rocha, Comptroller, and Jennifer McCartney, Intern Director of Sponsored Awards and Compliance
FAC accepted this audit on February 16, 2021 — management decision was due August 16, 2021.
FAC accepted this audit on November 4, 2019 — management decision was due May 4, 2020.
FAC accepted this audit on December 4, 2018 — management decision was due June 4, 2019.
FAC accepted this audit on November 20, 2017 — management decision was due May 20, 2018.
FAC accepted this audit on December 7, 2016 — management decision was due June 7, 2017.
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