Audit 16132

2023‐009 (2022‐005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance, Noncompliance, and Questioned Costs greater than $25k) Funding Agency: United States Department of Education Federal Award Agreement Number: N/A Award Year: 2023 Title: Education Stabilization Fund, HEERF Assistance Listing Number: 84.425C, 84.425F Pass‐through Agency: Not Applicable Pass‐through Identification Number: Not Applicable Questioned Costs: $76,109 Condition: The University did not apply the correct small purchase threshold for identifying purchases that need to obtain quotes in their policy. Population $10k‐$20k not included in small purchase policy included transactions totaling $76,109. Progress on resolution of prior year finding: No progress was made. Criteria: Per 2 CFR 200.303(a) requires non‐Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.320(a) sets the micro‐purchase threshold at $10,000 and requires purchases over the micro‐purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. Cause: Policies are not adequate to meet federal guidelines and need to be updated. Effect: The University may unintentionally use a higher‐cost vendor when failing to obtain price or rate quotations for items over the micro‐purchase threshold.

2023‐010 Reporting Controls over Special Reporting (Significant Deficiency in Internal Controls over Compliance) Funding Agency: United States Department of Education Federal Award Agreement Number: Not Applicable Award Year: All Title: Education Stabilization Fund, HEERF Assistance Listing Number: 84.425C, 84.425F Pass‐through Agency: Not Applicable Pass‐through Identification Number: Not Applicable Questioned Costs: Not Applicable Condition: During our review of reports, 1 out of 4 quarterly reports were not submitted timely. Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non‐federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Cause: Due to staff turnover and no procedures in place, the last quarter report was submitted approximately 3 months late. Effect: Late reporting can result in improper reporting which could lead to disallowed costs, however our audit disclosed no instances of unallowable costs.

2023‐009 (2022‐005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance, Noncompliance, and Questioned Costs greater than $25k) Funding Agency: United States Department of Education Federal Award Agreement Number: N/A Award Year: 2023 Title: Education Stabilization Fund, HEERF Assistance Listing Number: 84.425C, 84.425F Pass‐through Agency: Not Applicable Pass‐through Identification Number: Not Applicable Questioned Costs: $76,109 Condition: The University did not apply the correct small purchase threshold for identifying purchases that need to obtain quotes in their policy. Population $10k‐$20k not included in small purchase policy included transactions totaling $76,109. Progress on resolution of prior year finding: No progress was made. Criteria: Per 2 CFR 200.303(a) requires non‐Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.320(a) sets the micro‐purchase threshold at $10,000 and requires purchases over the micro‐purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. Cause: Policies are not adequate to meet federal guidelines and need to be updated. Effect: The University may unintentionally use a higher‐cost vendor when failing to obtain price or rate quotations for items over the micro‐purchase threshold.

2023‐010 Reporting Controls over Special Reporting (Significant Deficiency in Internal Controls over Compliance) Funding Agency: United States Department of Education Federal Award Agreement Number: Not Applicable Award Year: All Title: Education Stabilization Fund, HEERF Assistance Listing Number: 84.425C, 84.425F Pass‐through Agency: Not Applicable Pass‐through Identification Number: Not Applicable Questioned Costs: Not Applicable Condition: During our review of reports, 1 out of 4 quarterly reports were not submitted timely. Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non‐federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Cause: Due to staff turnover and no procedures in place, the last quarter report was submitted approximately 3 months late. Effect: Late reporting can result in improper reporting which could lead to disallowed costs, however our audit disclosed no instances of unallowable costs.

2023‐009 (2022‐005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance, Noncompliance, and Questioned Costs greater than $25k) Funding Agency: United States Department of Education Federal Award Agreement Number: N/A Award Year: 2023 Title: Education Stabilization Fund, HEERF Assistance Listing Number: 84.425C, 84.425F Pass‐through Agency: Not Applicable Pass‐through Identification Number: Not Applicable Questioned Costs: $76,109 Condition: The University did not apply the correct small purchase threshold for identifying purchases that need to obtain quotes in their policy. Population $10k‐$20k not included in small purchase policy included transactions totaling $76,109. Progress on resolution of prior year finding: No progress was made. Criteria: Per 2 CFR 200.303(a) requires non‐Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.320(a) sets the micro‐purchase threshold at $10,000 and requires purchases over the micro‐purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. Cause: Policies are not adequate to meet federal guidelines and need to be updated. Effect: The University may unintentionally use a higher‐cost vendor when failing to obtain price or rate quotations for items over the micro‐purchase threshold.

2023‐010 Reporting Controls over Special Reporting (Significant Deficiency in Internal Controls over Compliance) Funding Agency: United States Department of Education Federal Award Agreement Number: Not Applicable Award Year: All Title: Education Stabilization Fund, HEERF Assistance Listing Number: 84.425C, 84.425F Pass‐through Agency: Not Applicable Pass‐through Identification Number: Not Applicable Questioned Costs: Not Applicable Condition: During our review of reports, 1 out of 4 quarterly reports were not submitted timely. Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non‐federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Cause: Due to staff turnover and no procedures in place, the last quarter report was submitted approximately 3 months late. Effect: Late reporting can result in improper reporting which could lead to disallowed costs, however our audit disclosed no instances of unallowable costs.

2023‐009 (2022‐005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance, Noncompliance, and Questioned Costs greater than $25k) Funding Agency: United States Department of Education Federal Award Agreement Number: N/A Award Year: 2023 Title: Education Stabilization Fund, HEERF Assistance Listing Number: 84.425C, 84.425F Pass‐through Agency: Not Applicable Pass‐through Identification Number: Not Applicable Questioned Costs: $76,109 Condition: The University did not apply the correct small purchase threshold for identifying purchases that need to obtain quotes in their policy. Population $10k‐$20k not included in small purchase policy included transactions totaling $76,109. Progress on resolution of prior year finding: No progress was made. Criteria: Per 2 CFR 200.303(a) requires non‐Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.320(a) sets the micro‐purchase threshold at $10,000 and requires purchases over the micro‐purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. Cause: Policies are not adequate to meet federal guidelines and need to be updated. Effect: The University may unintentionally use a higher‐cost vendor when failing to obtain price or rate quotations for items over the micro‐purchase threshold.

2023‐010 Reporting Controls over Special Reporting (Significant Deficiency in Internal Controls over Compliance) Funding Agency: United States Department of Education Federal Award Agreement Number: Not Applicable Award Year: All Title: Education Stabilization Fund, HEERF Assistance Listing Number: 84.425C, 84.425F Pass‐through Agency: Not Applicable Pass‐through Identification Number: Not Applicable Questioned Costs: Not Applicable Condition: During our review of reports, 1 out of 4 quarterly reports were not submitted timely. Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non‐federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Cause: Due to staff turnover and no procedures in place, the last quarter report was submitted approximately 3 months late. Effect: Late reporting can result in improper reporting which could lead to disallowed costs, however our audit disclosed no instances of unallowable costs.

2023‐009 (2022‐005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance, Noncompliance, and Questioned Costs greater than $25k) Funding Agency: United States Department of Education Federal Award Agreement Number: N/A Award Year: 2023 Title: Education Stabilization Fund, HEERF Assistance Listing Number: 84.425C, 84.425F Pass‐through Agency: Not Applicable Pass‐through Identification Number: Not Applicable Questioned Costs: $76,109 Condition: The University did not apply the correct small purchase threshold for identifying purchases that need to obtain quotes in their policy. Population $10k‐$20k not included in small purchase policy included transactions totaling $76,109. Progress on resolution of prior year finding: No progress was made. Criteria: Per 2 CFR 200.303(a) requires non‐Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.320(a) sets the micro‐purchase threshold at $10,000 and requires purchases over the micro‐purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. Cause: Policies are not adequate to meet federal guidelines and need to be updated. Effect: The University may unintentionally use a higher‐cost vendor when failing to obtain price or rate quotations for items over the micro‐purchase threshold.

2023‐010 Reporting Controls over Special Reporting (Significant Deficiency in Internal Controls over Compliance) Funding Agency: United States Department of Education Federal Award Agreement Number: Not Applicable Award Year: All Title: Education Stabilization Fund, HEERF Assistance Listing Number: 84.425C, 84.425F Pass‐through Agency: Not Applicable Pass‐through Identification Number: Not Applicable Questioned Costs: Not Applicable Condition: During our review of reports, 1 out of 4 quarterly reports were not submitted timely. Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non‐federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Cause: Due to staff turnover and no procedures in place, the last quarter report was submitted approximately 3 months late. Effect: Late reporting can result in improper reporting which could lead to disallowed costs, however our audit disclosed no instances of unallowable costs.

2023‐009 (2022‐005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance, Noncompliance, and Questioned Costs greater than $25k) Funding Agency: United States Department of Education Federal Award Agreement Number: N/A Award Year: 2023 Title: Education Stabilization Fund, HEERF Assistance Listing Number: 84.425C, 84.425F Pass‐through Agency: Not Applicable Pass‐through Identification Number: Not Applicable Questioned Costs: $76,109 Condition: The University did not apply the correct small purchase threshold for identifying purchases that need to obtain quotes in their policy. Population $10k‐$20k not included in small purchase policy included transactions totaling $76,109. Progress on resolution of prior year finding: No progress was made. Criteria: Per 2 CFR 200.303(a) requires non‐Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.320(a) sets the micro‐purchase threshold at $10,000 and requires purchases over the micro‐purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. Cause: Policies are not adequate to meet federal guidelines and need to be updated. Effect: The University may unintentionally use a higher‐cost vendor when failing to obtain price or rate quotations for items over the micro‐purchase threshold.

2023‐010 Reporting Controls over Special Reporting (Significant Deficiency in Internal Controls over Compliance) Funding Agency: United States Department of Education Federal Award Agreement Number: Not Applicable Award Year: All Title: Education Stabilization Fund, HEERF Assistance Listing Number: 84.425C, 84.425F Pass‐through Agency: Not Applicable Pass‐through Identification Number: Not Applicable Questioned Costs: Not Applicable Condition: During our review of reports, 1 out of 4 quarterly reports were not submitted timely. Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non‐federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Cause: Due to staff turnover and no procedures in place, the last quarter report was submitted approximately 3 months late. Effect: Late reporting can result in improper reporting which could lead to disallowed costs, however our audit disclosed no instances of unallowable costs.