• This page, Berkshire Community College Did Not Collect and Retain Adequate Detailed Documentation To Support Expenditures Charged to Federal Funding It Received for Emergency Support., is   offered by
  • Office of the State Auditor

Berkshire Community College Did Not Collect and Retain Adequate Detailed Documentation To Support Expenditures Charged to Federal Funding It Received for Emergency Support.

Without collecting and retaining adequate documentation, BCC cannot provide assurance that the funding has been used for its intended purposes.

Table of Contents

Overview

Berkshire Community College (BCC) could not provide adequate records for 18 of the 50 Higher Education Emergency Relief Fund (HEERF) I and HEERF II institutional-portion transactions in our sample. We had examined these transactions to substantiate that they were related to the 2019 coronavirus (COVID-19) and were for student grants, refunds, scholarships, information technology equipment or software for students, COVID-19-related safety supplies, computer system upgrades, the defraying of expenses such as distance education or faculty and staff member training, or other student support activities.

BCC could not provide adequate records for 1 of the 35 Governor’s Emergency Education Relief (GEER) Fund student-portion transactions we examined to identify the transactions’ purposes. BCC also could not provide adequate records for 9 of the 20 GEER Fund institutional-portion transactions we examined to substantiate that the transactions were related to COVID-19 and were for staff members,6 student services, building services, or temporary facilities.

Without collecting and retaining adequate documentation to support that expenditures of federal funding are related to COVID-19, BCC cannot provide assurance that the funding has been used for its intended purposes. Furthermore, noncompliance with record retention requirements for federal grants may result in BCC having to repay the funding and may adversely affect its ability to obtain future funding.

Authoritative Guidance

Section 200.334 of Title 2 of the Code of Federal Regulations, which the federal Office of Management and Budget uses in its Uniform Guidance (2014), requires the following:

Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report . . . as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.

Reasons for Issue

BCC has no monitoring controls to ensure that all required supporting documentation for its federal expenditures is collected and retained.

Recommendation

BCC should create and implement monitoring controls to ensure that all required supporting documentation for its federal expenditures is collected and retained.

Auditee’s Response

While the College believes proper procedures and controls were in place for the audit period, the global pandemic required moving from [on-premises] to remote work and adapting a paper-based procurement system to an online system. In our internal post audit discovery, we found supporting documents, but they were stored in multiple locations. The requested documentation was not provided to the State Auditors in a timely fashion, if at all. This illustrated the issue outlined by this audit.

We are creating a streamlined monitoring system for transactions to ensure approval from inception to payment. This process has already begun with the post audit business discovery effort. A financial software upgrade is in progress, which includes extensive training for employees who will interact with it. In the meantime, all documents are reviewed for adherence to the requirements of federal and state guidelines and approved by designated signatories.

Auditor’s Reply

Based on its response, BCC is taking measures to address our concerns on this matter.

6.    Staff member transactions are expenses that were needed to compensate staff and faculty members for training on remote learning, hygiene, and ways to minimize the spread of disease when in-person classes resumed.

Date published: August 30, 2022

Help Us Improve Mass.gov  with your feedback

Please do not include personal or contact information.
Feedback