Audit of Springfield Technical Community College Objectives, Scope, and Methodology

An overview of the purpose and process of auditing Springfield Technical 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 Springfield Technical Community College (STCC) 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 STCC 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?2	Yes
Did STCC 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?	Yes
Did STCC receive and administer CARES 18004(a)(2) funding in accordance with the Frequently Asked Questions (FAQ) Rollup Document?	Yes
Did STCC receive and administer Governor’s Emergency Education Relief (GEER) funds in accordance with the guidance issued by US DOE3 and/or the Massachusetts Department of Higher Education (MDHE) interdepartmental service agreement?4	Yes

 

To achieve our objectives, we gained an understanding of the internal controls related to the objectives by reviewing applicable policies and interviewing STCC officials. We evaluated the design and implementation of controls over STCC’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 STCC 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 STCC’s Colleague⁵ financial system. We compared the grant screenshots to the award notification from the federal government and the trial balance of STCC’s general ledger.
• To determine whether STCC had expended CARES 18004(a)(1) student portion funding in accordance with the guidance issued by US DOE, we obtained a list of 2,973 student payments. We stratified the list into two populations: 2,863 payments of $350 and 110 additional payments of various amounts. STCC issued payments of $350 to all eligible students and provided additional payments to students who requested further assistance. These additional payment requests were reviewed, and subject to approval, by STCC management.

• From the population of 2,863 payments of $350, we selected a random, statistical sample of 60. We reviewed each student’s Institutional Student Information Record (ISIR) to verify that s/he had completed the Free Application for Federal Student Aid (FAFSA). To determine whether the method of payment was allowable, we verified that payments to students were made by a method approved by US DOE and examined transcripts to verify that none of the students was enrolled in an online-only program as of March 13, 2020.
• From the population of 110 additional payments, we selected a random, nonstatistical sample of 35 payments to students who requested and received additional CARES 18004(a)(1) student-portion funding to assist with various financial needs. We reviewed each student’s ISIR to verify that s/he had completed the FAFSA, and we reviewed copies of each student’s request form to verify that the purpose of the payment was allowable. To determine whether the payment method was allowable, we verified that payments to students were made by a method approved by the US DOE and examined transcripts to verify that none of the students was enrolled in an online-only program as of March 13, 2020.

• To determine whether STCC had expended CARES 18004(a)(1) institutional funding in accordance with guidance issued by US DOE, we selected a random, nonstatistical sample of 4 transactions from a population of 15. 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 (COVID-19), whether the documentation supported the need for each item or service, and whether each purchase was allowable.
• To determine whether STCC 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 Colleague. We compared the grant screenshots to the award notification from the federal government and the trial balance of STCC’s general ledger.
• To determine whether STCC had expended CARES 18004(a)(2) funding in accordance with guidance issued by US DOE, we selected a random, nonstatistical sample of 5 transactions from a population of 14 transactions in which STCC had used CARES 18004(a)(2) funds to reimburse students who had requested refunds because of the switch to online learning. We reviewed documentation of each student’s refund request to determine whether the refund addressed needs that were directly related to COVID-19. Using the sampled students’ schedules and tuition rates, we calculated and corroborated the refunded amounts.
• To determine whether STCC had expended the institutional portion of GEER funds in accordance with the guidance issued by US DOE and/or the terms in Attachment A of the interdepartmental service agreement issued by MDHE, we selected a random, nonstatistical sample of 4 transactions from a population of 16. We reviewed invoices, payment vouchers, purchase orders, and approvals to determine whether each transaction was related to the disruption of campus operations due to COVID-19 and whether the documentation adequately supported the need for each item or service.

We did not project our results of our tests to the various populations.

Data Reliability

We reviewed access controls and security management for Colleague to determine the reliability of the data therein.

We assessed the completeness and accuracy of the CARES 18004(a)(1) and GEER institutional transaction lists and the CARES 18004(a)(1) and CARES 18004(a)(2) student disbursement lists by reconciling the lists with the general ledger trial balances provided by STCC’s comptroller.

As a result of our data reliability analysis, reconciliations, and information system control work, we found that the data on the lists were sufficiently reliable for the purpose of our audit objectives.

2.     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.

3.     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.

4.     MDHE issued an interdepartmental service agreement that accompanied the GEER award to each recipient for institutional costs. The agreement included requirements for administering the funds.

5.     Colleague is the database system for STCC’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:	August 18, 2021