Overview
BCC did not have the required approval from its chief financial officer (CFO) or another member of the executive council (i.e., BCC’s president, any department vice president, or the executive director of human resources) for 10 of the 11 institutional-portion disbursements from HEERF I and HEERF II grants in our sample. We had examined these disbursements to assess the effectiveness of internal controls.
A lack of authorized approvals of HEERF I and HEERF II institutional-portion disbursements increases the risk of improper use of this funding.
Authoritative Guidance
The “Berkshire Community College CARES/GEER/HEERF Funds Policy and Procedures” document states,
- Request is sent to CFO for analysis under the guides of HEERF I, II, III
- If request meets standards as outlined in guidance, the request is approved [by the CFO or a member of the Executive Council]. . . .
- Requests, emails, and documents are kept as back up to the expenditure.
Reasons for Issue
BCC has no monitoring controls to ensure that the required approval process for use of HEERF I and HEERF II funding is consistently followed.
Recommendation
BCC should create and implement monitoring controls to ensure that the required approval process for use of HEERF I and HEERF II funding is consistently followed.
Auditee’s Response
The College established clear internal procedures for HEERF I and HEERF II expenditures that met all requirements as outlined by the federal government. The audit uncovered that these procedures were not followed for every transaction, which we deeply regret.
The re-implementation of Ellucian Colleague, the College’s student information system, slated to launch in January 2023 for the finance module, and April 2023 for the rest of the system, will automate the requisition, purchasing, approval, and disbursement process to record all requests, approvals, and payments with appropriate authority and will apply date stamps for recording purposes.
The College embraces the recommendations of the State Auditor. Until [Colleague] is reimplemented the College is ensuring, through manual processes, that every expenditure has appropriate approval signatures and clear reference for applicability for use of HEERF I and II funds (actually, all college funds). The College is carefully reviewing documented procedures for clarity and completeness and will ensure they are shared broadly. Long tenures by many employees pre-pandemic, may have created an over reliance on institutional memory.
Auditor’s Reply
Based on its response, BCC is taking measures to address our concerns on this matter.
| Date published: | August 30, 2022 |
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