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Audit of the Middlesex Community College Objectives, Scope, and Methodology

An overview of the purpose and process of auditing the Middlesex Community College

Table of Contents

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 Middlesex Community College (MCC) for the period March 1, 2020 through June 30, 2021.

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; the conclusion we reached regarding each objective; and, if applicable, where each objective is discussed in the audit findings.

Objective

Conclusion

  1. Did MCC administer the student portion of funding under its student award criteria and 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) Higher Education Emergency Relief Fund (HEERF) Frequently Asked Questions (FAQ) Rollup Document?

Yes

  1. Did MCC administer the institutional portion of CARES 18004(a)(1) funding in accordance with Section F of US DOE’s Higher Education Emergency Relief Fund (HEERF) Frequently Asked Questions (FAQ) Rollup Document?

Yes

  1. Did MCC administer the student portion of funding under its student award criteria and Section 314(a)(1) of the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) in accordance with US DOE’s Higher Education Emergency Relief Fund (HEERF) II Public and Private Nonprofit Institution (a)(1) Programs ([Catalog of Federal Domestic Assistance, or CFDA] 84.425E and 84.425F) Frequently Asked Questions?

Yes

  1. Did MCC administer the institutional portion of funding under Section 314(a)(1) of the CRRSAA in accordance with US DOE’s Higher Education Emergency Relief Fund (HEERF) II Public and Private Nonprofit Institution (a)(1) Programs (CFDA 84.425E and 84.425F) Frequently Asked Questions and Higher Education Emergency Relief Fund (HEERF I, II, and III) Lost Revenue Frequently Asked Questions?

Yes

  1. Did MCC administer the institutional portion of funding under Section 2003(a)(1) of the American Rescue Plan (ARP) Act in accordance with US DOE’s Higher Education Emergency Relief Fund III Frequently Asked Questions and Higher Education Emergency Relief Fund (HEERF I, II, and III) Lost Revenue Frequently Asked Questions?

Yes

  1. Did MCC administer the student portion of Governor’s Emergency Education Relief (GEER) funding in accordance with its student award criteria and US DOE’s Frequently Asked Questions about the Governor’s Emergency Education Relief Fund (GEER Fund)?

Yes

  1. Did MCC administer the institutional portion of GEER funding in accordance with US DOE’s Frequently Asked Questions about the Governor’s Emergency Education Relief Fund (GEER Fund) and the Massachusetts Department of Higher Education’s (MDHE’s) interdepartmental service agreement?

Yes

  1. Did MCC update its internal control plan (ICP) to address the 2019 coronavirus (COVID-19) pandemic, in accordance with the Office of the Comptroller of the Commonwealth’s “COVID-19 Pandemic Response Internal Controls Guidance,” dated September 30, 2020?

Yes

  1. Did MCC ensure that its users who had access to the finance and/or financial aid modules in Banner completed cybersecurity awareness training in accordance with Section 6.2.4 of the Executive Office of Technology Services and Security’s (EOTSS’s) Information Security Risk Management Standard IS.010?

No; see Finding 1

 

To achieve our objectives, we gained an understanding of the internal controls related to the objectives by reviewing applicable policies and interviewing MCC officials. We evaluated the design and implementation of controls over MCC’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 MCC administered CARES 18004(a)(1) student-portion funding in accordance with US DOE’s Higher Education Emergency Relief Fund (HEERF) Frequently Asked Questions (FAQ) Rollup Document, we selected a random, statistical sample of 60 student payments from a population of 4,890, with a confidence level of 95%, a tolerable error rate of 5%, and expected error rate of 0%. To determine whether each sampled student was eligible to receive CARES Act student-portion funding, we reviewed each sampled student’s Institutional Student Information Record (ISIR) to verify that the student had completed the Free Application for Federal Student Aid (FAFSA). To determine that the payment method was allowable, we reviewed whether MCC used a US DOE–approved method to pay students. We examined copies of requests for additional funding (Higher Education Emergency Relief Fund applications) when applicable. We also examined copies of the schedules corresponding to the semester when each student received a payment (spring, summer, or fall) to verify that each student was enrolled in courses for the appropriate semester. If students received payments for the spring 2020 semester, we examined their schedules to verify that they were not enrolled in online-only programs on March 13, 2020. Additionally, because MCC had developed its own award criteria for students, we verified that sampled students received the appropriate payment amounts based on their priority levels and award tiers.
  • To determine whether MCC administered CARES 18004(a)(1) institutional-portion funding in accordance with US DOE’s Higher Education Emergency Relief Fund (HEERF) Frequently Asked Questions (FAQ) Rollup Document, we selected a random, nonstatistical sample of 35 institutional-portion transactions from a population of 152. We reviewed purchase orders, invoices, approvals, and general ledger entries to determine the reason for each transaction, whether each transaction was related to the disruption of campus operations due to COVID-19, whether the documentation adequately supported the need for each item or service, and whether each transaction was allowable.
  • To determine whether MCC administered CRRSAA 314(a)(1) student-portion funding in accordance with US DOE’s Higher Education Emergency Relief Fund (HEERF) II Public and Private Nonprofit Institution (a)(1) Programs (CFDA 84.425E and 84.425F) Frequently Asked Questions, we selected a statistical sample of 60 student payments from a population of 5,637, with a confidence level of 95%, a tolerable error rate of 5%, and an expected error rate of 0%. We reviewed copies of issued checks, electronic transfers to students, and account statements to determine whether MCC used a US DOE–approved method to pay students. To determine whether MCC administered student-portion funding in accordance with its own award criteria, we reviewed sampled students’ ISIRs to verify that their expected family contributions were under $10,000. Additionally, to determine whether the students received the appropriate amounts based on their priority levels and award tiers, we verified the number of credit hours on the students’ schedules and noted whether they submitted requests for supplemental funding.
  • To determine whether MCC administered CRRSAA 314(a)(1) institutional-portion funding in accordance with US DOE’s Higher Education Emergency Relief Fund (HEERF) II Public and Private Nonprofit Institution (a)(1) Programs (CFDA 84.425E and 84.425F) Frequently Asked Questions, we selected a random, nonstatistical sample of 10 institutional-portion transactions from a population of 23. We reviewed purchase orders, invoices, approvals, journal entries, and lost-revenue calculations to determine the reason for each transaction, whether each transaction was related to the disruption of campus operations due to COVID-19, whether each amount of lost revenue was calculated correctly based on US DOE’s Higher Education Emergency Relief Fund (HEERF I, II, and III) Lost Revenue Frequently Asked Questions if the transaction was used to defray revenue loss, whether the documentation adequately supported the need for each item or service, and whether each transaction was allowable.
  • During the audit period, MCC incurred only one ARP Act transaction, which was used to defray lost revenue. To determine whether MCC administered ARP 2003(a)(1) institutional-portion funding in accordance with US DOE’s Higher Education Emergency Relief Fund III Frequently Asked Questions, we verified that the amount of lost revenue was calculated correctly based on US DOE’s Higher Education Emergency Relief Fund (HEERF I, II, and III) Lost Revenue Frequently Asked Questions.
  • To determine whether MCC administered GEER student-portion funding in accordance with US DOE’s Frequently Asked Questions about the Governor’s Emergency Education Relief Fund (GEER Fund) and MCC’s award criteria, we selected a random, nonstatistical sample of 40 student payments from a population of 469. To determine whether each sampled student was eligible to receive GEER student funding, we reviewed each sampled student’s ISIR to verify that the student had completed a FAFSA. We also reviewed copies of sampled students’ schedules to verify that they were enrolled in courses during the fall 2020 semester. Additionally, we reviewed copies of issued checks and/or electronic transfers to students and tested to ensure that sampled students received the appropriate amounts based on their priority levels and award tiers.
  • To determine whether MCC administered GEER institutional-portion funding in accordance with US DOE’s Frequently Asked Questions about the Governor’s Emergency Education Relief Fund (GEER Fund) and MDHE’s interdepartmental service agreement, we selected a random, nonstatistical sample of 20 institutional-portion transactions from a population of 57. We reviewed purchase orders, invoices, approvals, and journal entries to determine whether each transaction was related to the disruption of campus operations due to COVID-19, whether the documentation adequately supported the need for each item or service, and whether each transaction was allowable.
  • To determine whether MCC made recommended updates to its ICP to comply with the Office of the Comptroller of the Commonwealth’s “COVID-19 Pandemic Response Internal Controls Guidance,” we reviewed MCC’s ICP, fiscal year 2020 and fiscal year 2021 Internal Control Questionnaires, and “Safe Return to Campus Plan.”
  • To determine whether MCC’s users who had access to the finance and/or financial aid modules in Banner completed annual cybersecurity awareness training in accordance with EOTSS’s Information Security Risk Management Standard IS.010, we selected a random, nonstatistical sample of 35 Banner users with finance and/or financial aid module access from a population of 158. We reviewed each sampled user’s training documentation and determined whether the user completed the training by the due date.

When using nonstatistical sampling, we could not project the results to the entire population.

Data Reliability

To determine the reliability of the data in Banner, we conducted interviews with MCC officials who had knowledge about the data and tested MCC’s access and security management information system controls. We tested the CARES (a)(1), CRRSAA (a)(1), and GEER institutional-portion transaction lists, and the CARES (a)(1), CRRSAA (a)(1), and GEER student-portion transaction lists, for missing, invalid, and duplicate records, as well as records outside the audit period. We also compared the totals of these lists to the general ledger provided by MCC’s comptroller and verified the accuracy of the Banner user list by comparing it to an employee list provided by MCC’s Human Resources Department. As a result of these procedures, we found that the data on the lists were sufficiently reliable for the purpose of our audit objectives.

Date published: May 31, 2022
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