Mount Wachusett Community College - Finding 1

Mount Wachusett Community College did not update its internal control plan with a COVID-19 pandemic response plan.

Overview

Mount Wachusett Community College’s (MWCC’s) internal control plan was not updated with a COVID-19 component as required by the Office of the Comptroller of the Commonwealth’s (CTR’s) “COVID-19 Pandemic Response Internal Controls Guidance,” issued September 30, 2020. MWCC’s internal control plan was last updated in June 2020.

An internal control plan identifies objectives and risks and identifies control activities to mitigate risks that may prevent an agency from accomplishing its public mission. Without updating its internal control plan, MWCC may not identify and/or mitigate all risks that may prevent it from accomplishing its objectives.

Authoritative Guidance

CTR’s “COVID-19 Pandemic Response Internal Controls Guidance,” dated September 30, 2020, states,

Department internal control plans must be based on risk assessments and updated annually, or when significant changes occur. Because the COVID-19 Pandemic has affected all departments, The Comptroller, in consultation with the State Auditor’s Office, is providing two options for updating internal controls.

1. If the impact to your department is such that it can be reflected in your Internal Control Plan (ICP), then update the ICP as you would for any other mid-year changes.
2. Departments experiencing a significant impact, and requiring the accumulation of substantial documentation (e.g. changes to business processes, requirements of federal and state-specific laws or guidance, new funds or new programs), can draft a separate COVID-19 Pandemic Response Plan Appendix to the ICP as an organized set (hard or soft copies) of emails, documents, risk assessments, policies, and procedures.

Reasons for Issue

MWCC’s current vice president of administration and finance informed us that a draft internal control plan was created by the previous vice president of administration and finance during summer 2020; however, the draft was never approved.

Recommendation

MWCC should establish policies and procedures to ensure that its internal control plan is updated annually and when significant changes occur.⁵

Auditee’s Response

MWCC does regularly review and update the internal control plan annually in accordance with the Office of State Comptroller guidance but will implement procedures to ensure documentation of such reviews. In the case of the COVID-19 Response Plan the “draft” plan shared was the most current version used by the college to guide and direct its response. We acknowledge this plan was never finalized into a “final” plan as the guidance from federal, state and local health officials continued to evolve throughout the pandemic which necessitated the college remain nimble in order to quickly respond to the latest guidance. However, we do understand under normal operating conditions that all such plans and internal controls should be incorporated into the Internal Control plan in a “final” approved format.

Auditor’s Reply

Based on its response, MWCC is taking measures to address our concerns regarding this matter. As part of our post-audit review process, we will follow up on this matter in approximately six months.

5.    We would normally recommend that the auditee establish required policies and procedures it failed to establish. In this instance, however, the COVID-19 pandemic public health emergency declaration has been rescinded, and it is necessary to establish a policy that would no longer be in effect.

Date published:	December 27, 2024