Audit of Greenfield Community College Objectives, Scope, and Methodology

An overview of the purpose and process of auditing Greenfield Community College.

Overview

In accordance with Section 12 of Chapter 11 of the Massachusetts General Laws, the Office of the State Auditor has conducted a performance audit of certain activities of Greenfield Community College (GCC) for the period March 1, 2020 through September 30, 2020.

We conducted this performance audit in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

Below is a list of our audit objectives, indicating each question we intended our audit to answer and the conclusion we reached regarding each objective.

Objective	Conclusion
Did GCC receive and administer the student portion of funding under Section 18004(a)(1) of the Coronavirus Aid, Relief, and Economic Security (CARES) Act in accordance with Sections C, D, and E of the United States Department of Education’s (US DOE’s) Frequently Asked Questions (FAQ) Rollup Document? 1	Yes
Did GCC receive and administer the institutional portion of CARES 18004(a)(1) funding in accordance with Section F of the Frequently Asked Questions (FAQ) Rollup Document ?	See Other Matters
Did GCC receive and allocate CARES 18004(a)(2) funding in accordance with Section F of the Frequently Asked Questions (FAQ) Rollup Document?	Yes
Did GCC receive and allocate Governor’s Emergency Education Relief (GEER) funds in accordance with the guidance issued by US DOE2 and/or the Massachusetts Department of Higher Education interdepartmental service agreement? 3	Yes

To achieve our objectives, we gained an understanding of the internal controls related to the objectives by reviewing applicable policies and interviewing GCC officials. We evaluated the design and implementation of controls over GCC’s purchasing process and tested the operating effectiveness of these controls. In addition, we performed the following procedures to address the objectives.

• To determine whether GCC had appropriately received and allocated the student and institutional portions of CARES 18004(a)(1) funding, we obtained screenshots of the funding authorization in the federal government’s grant system and the allocations in GCC’s Banner⁴ financial system. We compared the grant screenshots to the award notification from the federal government and the trial balance of GCC’s general ledger.
• To determine whether GCC had expended CARES 18004(a)(1) student-portion funding in accordance with the guidance issued by US DOE, we selected a random, nonstatistical sample of 50 student payments from a population of 647. We reviewed each student’s Institutional Student Information Record to verify that the student had completed the Free Application for Student Aid. To determine that the payment method was allowable, we verified that payments to students were made by a method approved by US DOE and examined transcripts to verify that the students were not enrolled in an online-only program on March 13, 2020.
• To determine whether GCC had received and administered CARES 18004(a)(1) institutional funding in accordance with guidance issued by US DOE, we selected a random, nonstatistical sample of 27 expense transactions from a population of 101. We reviewed invoices, payment vouchers, purchase orders, and approvals to determine whether each transaction was related to the disruption of campus operations due to the 2019 coronavirus, whether the documentation supported the need for each item or service, and whether each purchase was allowable.
• To determine whether GCC had appropriately received and allocated CARES 18004(a)(2) funding, we obtained screenshots of the funding authorization in the federal government’s grant system and the allocations in Banner. We compared the grant screenshots to the award notification from the federal government and the trial balance of GCC’s general ledger.
• To determine whether GCC had appropriately received and allocated institutional GEER funding, we obtained screenshots of the institutional funding allocation in Banner. We compared these screenshots to the award notification and to the trial balance of GCC’s general ledger.

Because we used a nonstatistical approach for our audit samples, we could not project our results to the populations of CARES fund expenditures.

Data Reliability

We interviewed knowledgeable officials about the data and tested the data for missing, invalid, and duplicate records, as well as dates outside the audit period. We also assessed the completeness and accuracy of the CARES 18004(a)(1) institutional transaction list and the CARES 18004(a)(1) student disbursement list by reconciling the lists with the general ledger and trial balances provided by the GCC comptroller. Finally, we tested GCC’s information system controls (access and security management). As a result of our data reliability analysis and reconciliations, we found that the data in the lists were sufficiently reliable for the purpose of our audit objectives.

1.     Because of the federal mandate to accelerate the distribution of money from the Higher Education Emergency Relief Fund to students, there was not sufficient time to develop detailed guidance to govern the administration of these funds. Guidance was provided through a series of documents responding to frequently asked questions. In October 2020, US DOE issued a Frequently Asked Questions (FAQ) Rollup Document that combined all prior frequently asked questions into one document. We used this document as a criterion in conducting the audit.

2.     US DOE issued guidance for using CARES GEER funds in a document called Frequently Asked Questions about the Governor’s Emergency Education Relief Fund. In addition, Governors or state education authorities were required to sign a “Certification and Agreement for Funding” that described compliance requirements.

3.     The Massachusetts Department of Higher Education issued an interdepartmental service agreement that accompanied the GEER award to each recipient for institutional costs. The agreement noted requirements for administering the funds.

4.     Banner is the database system for GCC’s administrative activities, accounting, and student files. It is designed to link various integrated modules, including modules for registration, student billing, and financial aid, to the college’s financial system.

Date published:	July 12, 2021