Overview
During our audit, we also identified the issue below, which we believe warrants Quinsigamond Community College’s (QCC’s) attention.
QCC did not have an adequate segregation of duties over the calculation, distribution, and publication of the Higher Education Emergency Relief Fund (HEERF) grants to students. This led to the following questionable computations of student awards:
- QCC increased the enrollment status multiplier for students who were enrolled half-time only and did not increase any other enrollment status multiplier. We noted that 1,126 students were paid a total of $845,120 in American Rescue Plan Act (ARPA) awards. This resulted in 22% of the total population of HEERF recipients benefiting from the increase in the enrollment status multiplier. The ARPA Student Certification and Agreement states, “the Recipient should consider each student’s particular socioeconomic circumstances in the administration of these grants.”
- We also noted in our sample that one student received $139 more than the $692 Coronavirus Response and Relief Supplemental Appropriations Act award, which is a portion of HEERF, due to using the full-time enrollment status multiplier of 1.2 instead of the three-quarter enrollment status multiplier of 1.0. The student reduced their status on February 18, 2021, and was awarded on March 3, 2021, and the reduction of credit status was not reflected in the reconciliation before posting the student award on March 3, 2021.
QCC management stated that, after reviewing financial aid data for fiscal years 2020 and 2021, they identified that half-time students are significantly more likely to be independent (not living at home) while also supporting other members of their household. However, the funds could have been disbursed equally among all independent students to ensure that the funds were given to students with exceptional need.
QCC’s director of financial aid was solely responsible for the calculation, distribution, and publication of the HEERF, with no other employee reviewing or approving these calculations, distributions, or publications. Section 10.04 of the Office of the Comptroller of the Commonwealth’s Internal Control Guide, July 2021, states, “Management should divide or segregate key duties and responsibilities among different people to reduce the risk of error, misuse, or fraud.”
QCC appeared to lack the proper internal controls that would have mitigated the risk of potential errors in the ARPA student-portion grant calculation. Had there been an adequate segregation of duties, the questionable calculations highlighted above would more likely have been detected.
QCC should establish an appropriate segregation of duties over any student grant programs to ensure the accurate calculation and distribution of funds and the accurate publication of information related to these programs.
Auditee’s Response
The college recognized the need for segregation of duties. This process is currently a practice of the college for various funding that is received. The College understands the concern raised and is always seeking to improve operations to ensure compliance. Due to the unexpected nature of the pandemic, the College was required to distribute HEERF funding in a short time frame with a high volume of disbursements. In addition, the volume of students in need that the college overall serves were tremendously increased. With these challenges QCC strived to meet the need in a timely manner with limited resources. It has not been QCC’s practice for any other fund(s) to be processed or distributed with the intention of segregation of duties in the forefront. As HEERF funds are no longer being awarded, we are unable to take corrective action within that program. However, other federal, state, and institutional financial aid funds are awarded by multiple staff members, with two separate staff members (one in financial aid and one in the Business Office) responsible for disbursement of funds with reconciliations for all funds being processed from other staff members as well. When implementing the new state free community college programs for 2024–2025, QCC has also written reports that validate the amounts awarded to students before disbursement to further minimize error. QCC will continue to review existing and new processes to ensure the segregation of duties and having more personnel involved. The change has been updated in our written documentation.
Auditor’s Reply
QCC stated in its response that “it has not been QCC’s practice for any other fund(s) to be processed or distributed with the intention of segregation of duties in the forefront.” However, given that the lack of segregation of duties appeared to contribute to the grant accounting issues highlighted above, we reiterate the recommendation for QCC to establish an appropriate segregation of duties over student grant programs. The end of QCC’s response appears to indicate that QCC 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.
| Date published: | April 4, 2025 |
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