Finding 2022-004 Assistance Listing Number, Federal Agency, and Program Name Federal Agency: Department of Education Federal Programs: TRIO Student Support Services, TRIO Talent Search, TRIO Upward Bound, and TRIO McNair Post-Baccalaureate Achievement Assistance Listing Numbers: 84.042, 84.044, 84.047, and 84.217 Finding Type: Significant Deficiency Repeat Finding: No Criteria Uniform Guidance (2 CFR 200.510(b)) requires a schedule of expenditures of Federal awards that must provide total Federal awards expended for each individual Federal program and the Assistance Listings Number (ALN) or other identifying number when the Assistance Listings information is not available. For a cluster of programs, schedule of expenditures of Federal awards must also provide the total for the cluster. Condition Purdue did not have adequate controls in place to ensure the SEFA was prepared to include appropriate ALN's for each federal program and federal programs were included in the appropriate cluster. Questioned Costs There were no questioned costs identified. Context During our review of the University's SEFA, we noted 1 TRIO grant with expenditures of $275,851 that was improperly included within the Research and Development Cluster, rather than the TRIO cluster. The University completed an additional review of the SEFA identifying an additional TRIO grant with expenditures of $352,099 that was being presented under a placeholder Department of Education ALN and not properly adjusted to the proper ALN. As a result, the TRIO cluster on the SEFA was updated to reflect total expenditures of $3,608,222, which surpassed the Type A threshold and was required to be tested as a major program. The University conducted a full review of ALNs and as a result, 51 ALNs were adjusted. No additional cluster changes were identified. Cause and Effect Purdue University did not have adequate processes and internal control structure in place to ensure appropriate ALNs were ultimately assigned to all grants and that all grants were included in the appropriate cluster. As a result, the TRIO cluster on the SEFA was updated to reflect total expenditures of $3,608,222, which surpassed the Type A threshold and was required to be tested as a major program. Recommendation We recommend that the Univerisy refine their processes and modify their existing internal control structure in place to ensure appropriate ALNs are assigned to all grants and that all grants are included in the appropriate cluster. Views of Responsible Officials and Corrective Action Plan ? A report has been created to identify all grants assigned a placeholder ALN. ? This ALN report will be reviewed monthly by the Senior Manager of the Award Set-Up Team in Post Award to ensure all placeholder ALNs are appropriately and timely corrected once the proper ALN is known. ? Annually, as the SEFA is prepared, a full review of all grants assigned a placeholder ALN will be conducted by the Assistant Director of Post Award and the Assistant Director of Research Quality Assurance and any mis-assigned ALNs will be appropriately corrected before the SEFA is created.
Finding 2022-004 Assistance Listing Number, Federal Agency, and Program Name Federal Agency: Department of Education Federal Programs: TRIO Student Support Services, TRIO Talent Search, TRIO Upward Bound, and TRIO McNair Post-Baccalaureate Achievement Assistance Listing Numbers: 84.042, 84.044, 84.047, and 84.217 Finding Type: Significant Deficiency Repeat Finding: No Criteria Uniform Guidance (2 CFR 200.510(b)) requires a schedule of expenditures of Federal awards that must provide total Federal awards expended for each individual Federal program and the Assistance Listings Number (ALN) or other identifying number when the Assistance Listings information is not available. For a cluster of programs, schedule of expenditures of Federal awards must also provide the total for the cluster. Condition Purdue did not have adequate controls in place to ensure the SEFA was prepared to include appropriate ALN's for each federal program and federal programs were included in the appropriate cluster. Questioned Costs There were no questioned costs identified. Context During our review of the University's SEFA, we noted 1 TRIO grant with expenditures of $275,851 that was improperly included within the Research and Development Cluster, rather than the TRIO cluster. The University completed an additional review of the SEFA identifying an additional TRIO grant with expenditures of $352,099 that was being presented under a placeholder Department of Education ALN and not properly adjusted to the proper ALN. As a result, the TRIO cluster on the SEFA was updated to reflect total expenditures of $3,608,222, which surpassed the Type A threshold and was required to be tested as a major program. The University conducted a full review of ALNs and as a result, 51 ALNs were adjusted. No additional cluster changes were identified. Cause and Effect Purdue University did not have adequate processes and internal control structure in place to ensure appropriate ALNs were ultimately assigned to all grants and that all grants were included in the appropriate cluster. As a result, the TRIO cluster on the SEFA was updated to reflect total expenditures of $3,608,222, which surpassed the Type A threshold and was required to be tested as a major program. Recommendation We recommend that the Univerisy refine their processes and modify their existing internal control structure in place to ensure appropriate ALNs are assigned to all grants and that all grants are included in the appropriate cluster. Views of Responsible Officials and Corrective Action Plan ? A report has been created to identify all grants assigned a placeholder ALN. ? This ALN report will be reviewed monthly by the Senior Manager of the Award Set-Up Team in Post Award to ensure all placeholder ALNs are appropriately and timely corrected once the proper ALN is known. ? Annually, as the SEFA is prepared, a full review of all grants assigned a placeholder ALN will be conducted by the Assistant Director of Post Award and the Assistant Director of Research Quality Assurance and any mis-assigned ALNs will be appropriately corrected before the SEFA is created.
Finding 2022-004 Assistance Listing Number, Federal Agency, and Program Name Federal Agency: Department of Education Federal Programs: TRIO Student Support Services, TRIO Talent Search, TRIO Upward Bound, and TRIO McNair Post-Baccalaureate Achievement Assistance Listing Numbers: 84.042, 84.044, 84.047, and 84.217 Finding Type: Significant Deficiency Repeat Finding: No Criteria Uniform Guidance (2 CFR 200.510(b)) requires a schedule of expenditures of Federal awards that must provide total Federal awards expended for each individual Federal program and the Assistance Listings Number (ALN) or other identifying number when the Assistance Listings information is not available. For a cluster of programs, schedule of expenditures of Federal awards must also provide the total for the cluster. Condition Purdue did not have adequate controls in place to ensure the SEFA was prepared to include appropriate ALN's for each federal program and federal programs were included in the appropriate cluster. Questioned Costs There were no questioned costs identified. Context During our review of the University's SEFA, we noted 1 TRIO grant with expenditures of $275,851 that was improperly included within the Research and Development Cluster, rather than the TRIO cluster. The University completed an additional review of the SEFA identifying an additional TRIO grant with expenditures of $352,099 that was being presented under a placeholder Department of Education ALN and not properly adjusted to the proper ALN. As a result, the TRIO cluster on the SEFA was updated to reflect total expenditures of $3,608,222, which surpassed the Type A threshold and was required to be tested as a major program. The University conducted a full review of ALNs and as a result, 51 ALNs were adjusted. No additional cluster changes were identified. Cause and Effect Purdue University did not have adequate processes and internal control structure in place to ensure appropriate ALNs were ultimately assigned to all grants and that all grants were included in the appropriate cluster. As a result, the TRIO cluster on the SEFA was updated to reflect total expenditures of $3,608,222, which surpassed the Type A threshold and was required to be tested as a major program. Recommendation We recommend that the Univerisy refine their processes and modify their existing internal control structure in place to ensure appropriate ALNs are assigned to all grants and that all grants are included in the appropriate cluster. Views of Responsible Officials and Corrective Action Plan ? A report has been created to identify all grants assigned a placeholder ALN. ? This ALN report will be reviewed monthly by the Senior Manager of the Award Set-Up Team in Post Award to ensure all placeholder ALNs are appropriately and timely corrected once the proper ALN is known. ? Annually, as the SEFA is prepared, a full review of all grants assigned a placeholder ALN will be conducted by the Assistant Director of Post Award and the Assistant Director of Research Quality Assurance and any mis-assigned ALNs will be appropriately corrected before the SEFA is created.
Finding 2022-004 Assistance Listing Number, Federal Agency, and Program Name Federal Agency: Department of Education Federal Programs: TRIO Student Support Services, TRIO Talent Search, TRIO Upward Bound, and TRIO McNair Post-Baccalaureate Achievement Assistance Listing Numbers: 84.042, 84.044, 84.047, and 84.217 Finding Type: Significant Deficiency Repeat Finding: No Criteria Uniform Guidance (2 CFR 200.510(b)) requires a schedule of expenditures of Federal awards that must provide total Federal awards expended for each individual Federal program and the Assistance Listings Number (ALN) or other identifying number when the Assistance Listings information is not available. For a cluster of programs, schedule of expenditures of Federal awards must also provide the total for the cluster. Condition Purdue did not have adequate controls in place to ensure the SEFA was prepared to include appropriate ALN's for each federal program and federal programs were included in the appropriate cluster. Questioned Costs There were no questioned costs identified. Context During our review of the University's SEFA, we noted 1 TRIO grant with expenditures of $275,851 that was improperly included within the Research and Development Cluster, rather than the TRIO cluster. The University completed an additional review of the SEFA identifying an additional TRIO grant with expenditures of $352,099 that was being presented under a placeholder Department of Education ALN and not properly adjusted to the proper ALN. As a result, the TRIO cluster on the SEFA was updated to reflect total expenditures of $3,608,222, which surpassed the Type A threshold and was required to be tested as a major program. The University conducted a full review of ALNs and as a result, 51 ALNs were adjusted. No additional cluster changes were identified. Cause and Effect Purdue University did not have adequate processes and internal control structure in place to ensure appropriate ALNs were ultimately assigned to all grants and that all grants were included in the appropriate cluster. As a result, the TRIO cluster on the SEFA was updated to reflect total expenditures of $3,608,222, which surpassed the Type A threshold and was required to be tested as a major program. Recommendation We recommend that the Univerisy refine their processes and modify their existing internal control structure in place to ensure appropriate ALNs are assigned to all grants and that all grants are included in the appropriate cluster. Views of Responsible Officials and Corrective Action Plan ? A report has been created to identify all grants assigned a placeholder ALN. ? This ALN report will be reviewed monthly by the Senior Manager of the Award Set-Up Team in Post Award to ensure all placeholder ALNs are appropriately and timely corrected once the proper ALN is known. ? Annually, as the SEFA is prepared, a full review of all grants assigned a placeholder ALN will be conducted by the Assistant Director of Post Award and the Assistant Director of Research Quality Assurance and any mis-assigned ALNs will be appropriately corrected before the SEFA is created.
Finding 2022-001 Assistance Listing Number, Federal Agency, and Program Name Federal Agency: Department of Education Federal Programs: Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Numbers: 84.007, 84.063, 84.268 Finding Type: Significant Deficiency Repeat Finding: Yes 2021-004 Criteria 34 CFR 668.173 states in part that there is a timely return of title IV, HEA program funds in accordance with procedures established by the Secretary or FFEL Program lender, if an institution initiates an electronic funds transfer (EFT) or issues a check no later than 45 days after the date it determines that the student withdrew. Condition Special Tests and Provisions - Return of Title IV Funds The Purdue Fort Wayne campus did not properly design or implement an effective internal control system to ensure compliance with requirement for timely return of funds related to the Special Tests and Provisions - Return of Title IV Funds. Specifically, there was a lack of timeliness in initiating a return of Title IV funds, causing a return to be issued more than 45 days after the date the University became aware of student's withdrawal date. Questioned Costs There were no questioned costs identified. Context During our testing of the University's return of Title IV calculations, we noted 1 out of 13 students tested at the Purdue Fort Wayne campus (1 out of 40 students total tested) that had return of Title IV funds that were returned outside of the timeliness requirement. Cause and Effect The Purdue Fort Wayne campus experienced turnover in the Student Financial Aid Director position in Fall 2021. The temporary lack of staff resources caused the campus to have a failure in following internal policies and resulted in an untimely return of Title IV funds exceeding 45 days after the date the University became aware of student's withdrawal date, which was not in compliance with the established Return of Title IV policy. Recommendation We recommend that the Purdue Fort Wayne campus modify its existing internal control structure to ensure returns of Title IV funds are initiated timely, regardless of staff resource constraints, to ensure compliance with the Special Tests and Provisions - Return of Title IV Funds compliance requirements. Views of Responsible Officials and Corrective Action Plan The PFW Office of Financial Aid has an established Return of Title Four Aid (R2T4) policy and underlying control structure in place to ensure compliance with the R2T4 requirements. The PFW Office of Financial Aid will enhance its current R2T4 policy and procedure to include a step-by-step process to completing an R2T4. This will ensure that in the absence of the Assistant Director of Loans (who is currently responsible for R2T4 calculation completion) a succession list determining who is next in line to complete R2T4 calculations will be established to ensure these are completed in the 45-day window.
Finding 2022-001 Assistance Listing Number, Federal Agency, and Program Name Federal Agency: Department of Education Federal Programs: Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Numbers: 84.007, 84.063, 84.268 Finding Type: Significant Deficiency Repeat Finding: Yes 2021-004 Criteria 34 CFR 668.173 states in part that there is a timely return of title IV, HEA program funds in accordance with procedures established by the Secretary or FFEL Program lender, if an institution initiates an electronic funds transfer (EFT) or issues a check no later than 45 days after the date it determines that the student withdrew. Condition Special Tests and Provisions - Return of Title IV Funds The Purdue Fort Wayne campus did not properly design or implement an effective internal control system to ensure compliance with requirement for timely return of funds related to the Special Tests and Provisions - Return of Title IV Funds. Specifically, there was a lack of timeliness in initiating a return of Title IV funds, causing a return to be issued more than 45 days after the date the University became aware of student's withdrawal date. Questioned Costs There were no questioned costs identified. Context During our testing of the University's return of Title IV calculations, we noted 1 out of 13 students tested at the Purdue Fort Wayne campus (1 out of 40 students total tested) that had return of Title IV funds that were returned outside of the timeliness requirement. Cause and Effect The Purdue Fort Wayne campus experienced turnover in the Student Financial Aid Director position in Fall 2021. The temporary lack of staff resources caused the campus to have a failure in following internal policies and resulted in an untimely return of Title IV funds exceeding 45 days after the date the University became aware of student's withdrawal date, which was not in compliance with the established Return of Title IV policy. Recommendation We recommend that the Purdue Fort Wayne campus modify its existing internal control structure to ensure returns of Title IV funds are initiated timely, regardless of staff resource constraints, to ensure compliance with the Special Tests and Provisions - Return of Title IV Funds compliance requirements. Views of Responsible Officials and Corrective Action Plan The PFW Office of Financial Aid has an established Return of Title Four Aid (R2T4) policy and underlying control structure in place to ensure compliance with the R2T4 requirements. The PFW Office of Financial Aid will enhance its current R2T4 policy and procedure to include a step-by-step process to completing an R2T4. This will ensure that in the absence of the Assistant Director of Loans (who is currently responsible for R2T4 calculation completion) a succession list determining who is next in line to complete R2T4 calculations will be established to ensure these are completed in the 45-day window.
Finding 2022-001 Assistance Listing Number, Federal Agency, and Program Name Federal Agency: Department of Education Federal Programs: Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Numbers: 84.007, 84.063, 84.268 Finding Type: Significant Deficiency Repeat Finding: Yes 2021-004 Criteria 34 CFR 668.173 states in part that there is a timely return of title IV, HEA program funds in accordance with procedures established by the Secretary or FFEL Program lender, if an institution initiates an electronic funds transfer (EFT) or issues a check no later than 45 days after the date it determines that the student withdrew. Condition Special Tests and Provisions - Return of Title IV Funds The Purdue Fort Wayne campus did not properly design or implement an effective internal control system to ensure compliance with requirement for timely return of funds related to the Special Tests and Provisions - Return of Title IV Funds. Specifically, there was a lack of timeliness in initiating a return of Title IV funds, causing a return to be issued more than 45 days after the date the University became aware of student's withdrawal date. Questioned Costs There were no questioned costs identified. Context During our testing of the University's return of Title IV calculations, we noted 1 out of 13 students tested at the Purdue Fort Wayne campus (1 out of 40 students total tested) that had return of Title IV funds that were returned outside of the timeliness requirement. Cause and Effect The Purdue Fort Wayne campus experienced turnover in the Student Financial Aid Director position in Fall 2021. The temporary lack of staff resources caused the campus to have a failure in following internal policies and resulted in an untimely return of Title IV funds exceeding 45 days after the date the University became aware of student's withdrawal date, which was not in compliance with the established Return of Title IV policy. Recommendation We recommend that the Purdue Fort Wayne campus modify its existing internal control structure to ensure returns of Title IV funds are initiated timely, regardless of staff resource constraints, to ensure compliance with the Special Tests and Provisions - Return of Title IV Funds compliance requirements. Views of Responsible Officials and Corrective Action Plan The PFW Office of Financial Aid has an established Return of Title Four Aid (R2T4) policy and underlying control structure in place to ensure compliance with the R2T4 requirements. The PFW Office of Financial Aid will enhance its current R2T4 policy and procedure to include a step-by-step process to completing an R2T4. This will ensure that in the absence of the Assistant Director of Loans (who is currently responsible for R2T4 calculation completion) a succession list determining who is next in line to complete R2T4 calculations will be established to ensure these are completed in the 45-day window.
Finding 2022-002 Assistance Listing Number, Federal Agency, and Program Name Federal Agency: Department of Education Federal Program: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425F Finding Type: Significant Deficiency Repeat Finding: No Criteria Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure expenses are recorded only when purchased goods or services have been received. Costs should be determined in accordance with generally accepted accounting principles (GAAP) as described in 2 CFR Part 200. Condition The Purdue Fort Wayne campus did not have adequate controls in place to ensure invoices related to technology services were properly recorded in accordance with GAAP. Questioned Costs There were no questioned costs identified. Context During our testing of expenditures, we noted 2 out of 32 HEERF institutional portion expenditure samples tested included expenses initially recorded in the improper period and improperly included on the SEFA. The identified error was $301,717 and was removed from the SEFA as of June 30, 2022. Cause and Effect The failure to establish an effective internal control to review technology services expenditures caused the Purdue Fort Wayne campus to improperly include expenses related to fiscal year 2023 in fiscal year 2022, which was not in compliance with generally accepting accounting principles. Recommendation We recommend that the Purdue Fort Wayne campus ensure employees receive proper training to ensure policies and procedures are followed and expenditures are recorded in the proper period. Views of Responsible Officials and Corrective Action Plan The University system, including the Purdue Fort Wayne (PFW) Campus, has internal controls and training in place related to non-catalog purchases and the review of Goods Receipt/Invoice Receipt (GRIR) discrepancies. In the case of these two purchase orders, it appears these were isolated instances where established controls were not fully implemented as designed. These processes will be covered in staff meetings on all campuses and Procurement Services will review and update non-catalog order instructions and GRIR report documentation to ensure clear guidance is given.
Finding 2022-003 Assistance Listing Number, Federal Agency, and Program Name Federal Agency: Department of Education Federal Program: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425F Finding Type: Material Weakness Repeat Finding: Yes 2021-003 Criteria The Coronavirus Aid, Relief, and Economic Security (CARES) Act Section 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 section 314(e) require an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time and in such a manner as the secretary may require. American Rescue Plan Section 2003 specifies that the same terms and conditions of CRRSAA Section 314 apply to HEERF III funds. While the acts do not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, pursuant to these requirements, the Department of Education required quarterly public reporting of student portion and institutional portion awards. Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure reports include accurate and complete information and are submitted timely. Condition The University did not properly design or implement an effective internal control system to ensure HEERF reports were properly completed and posted. Questioned Costs There were no questioned costs identified. Context During our testing, we tested one annual report and six quarterly reports submitted by the University. The Purdue Northwest (PNW) campus and Purdue Fort Wayne (PFW) campuses did not comply with the HEERF student portion reporting requirement for quarter ended December 31, 2021 and quarter ended March 31, 2022, failing to complete quarterly reporting on their website related to the HEERF student portion. PNW subsequently updated their website on April 10, 2022 and PFW subsequently updated their website on September 30, 2022 to report cumulative information for the HEERF student portion. Cause and Effect PNW and PFW campuses had not developed a system of internal controls to ensure reports are completed timely, reviewed and submitted in accordance with HEERF reporting requirements. The failure to establish an effective internal control caused required reports to not be completed for PNW and PFW campuses. Recommendation We recommend the PNW and PFW campuses modify existing internal control structures to include internal controls that would ensure compliance with HEERF reporting requirements. Views of Responsible Officials and Corrective Action Plan The PFW Office of Financial Aid Director will complete the quarterly reports and a dual review process will be implemented to ensure accuracy. The quarterly report will be updated on the HEERF site and sent to the Assistant Director of Enrollment and Institutional Scholarships to post. The information posted will be compared to the reports submitted quarterly. PNW acknowledges that, while it had the appropriate Institutional HERF reporting completed, they missed updating the required student portion questions and answers that get posted to the reporting webpage. Once that was discovered, it was corrected in April 2022. PNW has ensured that the process now identifies looking at both the combined (updated) reporting PDF and the questions and answers that are required to be posted to the reporting webpage.
Finding 2022-004 Assistance Listing Number, Federal Agency, and Program Name Federal Agency: Department of Education Federal Programs: TRIO Student Support Services, TRIO Talent Search, TRIO Upward Bound, and TRIO McNair Post-Baccalaureate Achievement Assistance Listing Numbers: 84.042, 84.044, 84.047, and 84.217 Finding Type: Significant Deficiency Repeat Finding: No Criteria Uniform Guidance (2 CFR 200.510(b)) requires a schedule of expenditures of Federal awards that must provide total Federal awards expended for each individual Federal program and the Assistance Listings Number (ALN) or other identifying number when the Assistance Listings information is not available. For a cluster of programs, schedule of expenditures of Federal awards must also provide the total for the cluster. Condition Purdue did not have adequate controls in place to ensure the SEFA was prepared to include appropriate ALN's for each federal program and federal programs were included in the appropriate cluster. Questioned Costs There were no questioned costs identified. Context During our review of the University's SEFA, we noted 1 TRIO grant with expenditures of $275,851 that was improperly included within the Research and Development Cluster, rather than the TRIO cluster. The University completed an additional review of the SEFA identifying an additional TRIO grant with expenditures of $352,099 that was being presented under a placeholder Department of Education ALN and not properly adjusted to the proper ALN. As a result, the TRIO cluster on the SEFA was updated to reflect total expenditures of $3,608,222, which surpassed the Type A threshold and was required to be tested as a major program. The University conducted a full review of ALNs and as a result, 51 ALNs were adjusted. No additional cluster changes were identified. Cause and Effect Purdue University did not have adequate processes and internal control structure in place to ensure appropriate ALNs were ultimately assigned to all grants and that all grants were included in the appropriate cluster. As a result, the TRIO cluster on the SEFA was updated to reflect total expenditures of $3,608,222, which surpassed the Type A threshold and was required to be tested as a major program. Recommendation We recommend that the Univerisy refine their processes and modify their existing internal control structure in place to ensure appropriate ALNs are assigned to all grants and that all grants are included in the appropriate cluster. Views of Responsible Officials and Corrective Action Plan ? A report has been created to identify all grants assigned a placeholder ALN. ? This ALN report will be reviewed monthly by the Senior Manager of the Award Set-Up Team in Post Award to ensure all placeholder ALNs are appropriately and timely corrected once the proper ALN is known. ? Annually, as the SEFA is prepared, a full review of all grants assigned a placeholder ALN will be conducted by the Assistant Director of Post Award and the Assistant Director of Research Quality Assurance and any mis-assigned ALNs will be appropriately corrected before the SEFA is created.
Finding 2022-004 Assistance Listing Number, Federal Agency, and Program Name Federal Agency: Department of Education Federal Programs: TRIO Student Support Services, TRIO Talent Search, TRIO Upward Bound, and TRIO McNair Post-Baccalaureate Achievement Assistance Listing Numbers: 84.042, 84.044, 84.047, and 84.217 Finding Type: Significant Deficiency Repeat Finding: No Criteria Uniform Guidance (2 CFR 200.510(b)) requires a schedule of expenditures of Federal awards that must provide total Federal awards expended for each individual Federal program and the Assistance Listings Number (ALN) or other identifying number when the Assistance Listings information is not available. For a cluster of programs, schedule of expenditures of Federal awards must also provide the total for the cluster. Condition Purdue did not have adequate controls in place to ensure the SEFA was prepared to include appropriate ALN's for each federal program and federal programs were included in the appropriate cluster. Questioned Costs There were no questioned costs identified. Context During our review of the University's SEFA, we noted 1 TRIO grant with expenditures of $275,851 that was improperly included within the Research and Development Cluster, rather than the TRIO cluster. The University completed an additional review of the SEFA identifying an additional TRIO grant with expenditures of $352,099 that was being presented under a placeholder Department of Education ALN and not properly adjusted to the proper ALN. As a result, the TRIO cluster on the SEFA was updated to reflect total expenditures of $3,608,222, which surpassed the Type A threshold and was required to be tested as a major program. The University conducted a full review of ALNs and as a result, 51 ALNs were adjusted. No additional cluster changes were identified. Cause and Effect Purdue University did not have adequate processes and internal control structure in place to ensure appropriate ALNs were ultimately assigned to all grants and that all grants were included in the appropriate cluster. As a result, the TRIO cluster on the SEFA was updated to reflect total expenditures of $3,608,222, which surpassed the Type A threshold and was required to be tested as a major program. Recommendation We recommend that the Univerisy refine their processes and modify their existing internal control structure in place to ensure appropriate ALNs are assigned to all grants and that all grants are included in the appropriate cluster. Views of Responsible Officials and Corrective Action Plan ? A report has been created to identify all grants assigned a placeholder ALN. ? This ALN report will be reviewed monthly by the Senior Manager of the Award Set-Up Team in Post Award to ensure all placeholder ALNs are appropriately and timely corrected once the proper ALN is known. ? Annually, as the SEFA is prepared, a full review of all grants assigned a placeholder ALN will be conducted by the Assistant Director of Post Award and the Assistant Director of Research Quality Assurance and any mis-assigned ALNs will be appropriately corrected before the SEFA is created.
Finding 2022-004 Assistance Listing Number, Federal Agency, and Program Name Federal Agency: Department of Education Federal Programs: TRIO Student Support Services, TRIO Talent Search, TRIO Upward Bound, and TRIO McNair Post-Baccalaureate Achievement Assistance Listing Numbers: 84.042, 84.044, 84.047, and 84.217 Finding Type: Significant Deficiency Repeat Finding: No Criteria Uniform Guidance (2 CFR 200.510(b)) requires a schedule of expenditures of Federal awards that must provide total Federal awards expended for each individual Federal program and the Assistance Listings Number (ALN) or other identifying number when the Assistance Listings information is not available. For a cluster of programs, schedule of expenditures of Federal awards must also provide the total for the cluster. Condition Purdue did not have adequate controls in place to ensure the SEFA was prepared to include appropriate ALN's for each federal program and federal programs were included in the appropriate cluster. Questioned Costs There were no questioned costs identified. Context During our review of the University's SEFA, we noted 1 TRIO grant with expenditures of $275,851 that was improperly included within the Research and Development Cluster, rather than the TRIO cluster. The University completed an additional review of the SEFA identifying an additional TRIO grant with expenditures of $352,099 that was being presented under a placeholder Department of Education ALN and not properly adjusted to the proper ALN. As a result, the TRIO cluster on the SEFA was updated to reflect total expenditures of $3,608,222, which surpassed the Type A threshold and was required to be tested as a major program. The University conducted a full review of ALNs and as a result, 51 ALNs were adjusted. No additional cluster changes were identified. Cause and Effect Purdue University did not have adequate processes and internal control structure in place to ensure appropriate ALNs were ultimately assigned to all grants and that all grants were included in the appropriate cluster. As a result, the TRIO cluster on the SEFA was updated to reflect total expenditures of $3,608,222, which surpassed the Type A threshold and was required to be tested as a major program. Recommendation We recommend that the Univerisy refine their processes and modify their existing internal control structure in place to ensure appropriate ALNs are assigned to all grants and that all grants are included in the appropriate cluster. Views of Responsible Officials and Corrective Action Plan ? A report has been created to identify all grants assigned a placeholder ALN. ? This ALN report will be reviewed monthly by the Senior Manager of the Award Set-Up Team in Post Award to ensure all placeholder ALNs are appropriately and timely corrected once the proper ALN is known. ? Annually, as the SEFA is prepared, a full review of all grants assigned a placeholder ALN will be conducted by the Assistant Director of Post Award and the Assistant Director of Research Quality Assurance and any mis-assigned ALNs will be appropriately corrected before the SEFA is created.
Finding 2022-004 Assistance Listing Number, Federal Agency, and Program Name Federal Agency: Department of Education Federal Programs: TRIO Student Support Services, TRIO Talent Search, TRIO Upward Bound, and TRIO McNair Post-Baccalaureate Achievement Assistance Listing Numbers: 84.042, 84.044, 84.047, and 84.217 Finding Type: Significant Deficiency Repeat Finding: No Criteria Uniform Guidance (2 CFR 200.510(b)) requires a schedule of expenditures of Federal awards that must provide total Federal awards expended for each individual Federal program and the Assistance Listings Number (ALN) or other identifying number when the Assistance Listings information is not available. For a cluster of programs, schedule of expenditures of Federal awards must also provide the total for the cluster. Condition Purdue did not have adequate controls in place to ensure the SEFA was prepared to include appropriate ALN's for each federal program and federal programs were included in the appropriate cluster. Questioned Costs There were no questioned costs identified. Context During our review of the University's SEFA, we noted 1 TRIO grant with expenditures of $275,851 that was improperly included within the Research and Development Cluster, rather than the TRIO cluster. The University completed an additional review of the SEFA identifying an additional TRIO grant with expenditures of $352,099 that was being presented under a placeholder Department of Education ALN and not properly adjusted to the proper ALN. As a result, the TRIO cluster on the SEFA was updated to reflect total expenditures of $3,608,222, which surpassed the Type A threshold and was required to be tested as a major program. The University conducted a full review of ALNs and as a result, 51 ALNs were adjusted. No additional cluster changes were identified. Cause and Effect Purdue University did not have adequate processes and internal control structure in place to ensure appropriate ALNs were ultimately assigned to all grants and that all grants were included in the appropriate cluster. As a result, the TRIO cluster on the SEFA was updated to reflect total expenditures of $3,608,222, which surpassed the Type A threshold and was required to be tested as a major program. Recommendation We recommend that the Univerisy refine their processes and modify their existing internal control structure in place to ensure appropriate ALNs are assigned to all grants and that all grants are included in the appropriate cluster. Views of Responsible Officials and Corrective Action Plan ? A report has been created to identify all grants assigned a placeholder ALN. ? This ALN report will be reviewed monthly by the Senior Manager of the Award Set-Up Team in Post Award to ensure all placeholder ALNs are appropriately and timely corrected once the proper ALN is known. ? Annually, as the SEFA is prepared, a full review of all grants assigned a placeholder ALN will be conducted by the Assistant Director of Post Award and the Assistant Director of Research Quality Assurance and any mis-assigned ALNs will be appropriately corrected before the SEFA is created.
Finding 2022-001 Assistance Listing Number, Federal Agency, and Program Name Federal Agency: Department of Education Federal Programs: Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Numbers: 84.007, 84.063, 84.268 Finding Type: Significant Deficiency Repeat Finding: Yes 2021-004 Criteria 34 CFR 668.173 states in part that there is a timely return of title IV, HEA program funds in accordance with procedures established by the Secretary or FFEL Program lender, if an institution initiates an electronic funds transfer (EFT) or issues a check no later than 45 days after the date it determines that the student withdrew. Condition Special Tests and Provisions - Return of Title IV Funds The Purdue Fort Wayne campus did not properly design or implement an effective internal control system to ensure compliance with requirement for timely return of funds related to the Special Tests and Provisions - Return of Title IV Funds. Specifically, there was a lack of timeliness in initiating a return of Title IV funds, causing a return to be issued more than 45 days after the date the University became aware of student's withdrawal date. Questioned Costs There were no questioned costs identified. Context During our testing of the University's return of Title IV calculations, we noted 1 out of 13 students tested at the Purdue Fort Wayne campus (1 out of 40 students total tested) that had return of Title IV funds that were returned outside of the timeliness requirement. Cause and Effect The Purdue Fort Wayne campus experienced turnover in the Student Financial Aid Director position in Fall 2021. The temporary lack of staff resources caused the campus to have a failure in following internal policies and resulted in an untimely return of Title IV funds exceeding 45 days after the date the University became aware of student's withdrawal date, which was not in compliance with the established Return of Title IV policy. Recommendation We recommend that the Purdue Fort Wayne campus modify its existing internal control structure to ensure returns of Title IV funds are initiated timely, regardless of staff resource constraints, to ensure compliance with the Special Tests and Provisions - Return of Title IV Funds compliance requirements. Views of Responsible Officials and Corrective Action Plan The PFW Office of Financial Aid has an established Return of Title Four Aid (R2T4) policy and underlying control structure in place to ensure compliance with the R2T4 requirements. The PFW Office of Financial Aid will enhance its current R2T4 policy and procedure to include a step-by-step process to completing an R2T4. This will ensure that in the absence of the Assistant Director of Loans (who is currently responsible for R2T4 calculation completion) a succession list determining who is next in line to complete R2T4 calculations will be established to ensure these are completed in the 45-day window.
Finding 2022-001 Assistance Listing Number, Federal Agency, and Program Name Federal Agency: Department of Education Federal Programs: Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Numbers: 84.007, 84.063, 84.268 Finding Type: Significant Deficiency Repeat Finding: Yes 2021-004 Criteria 34 CFR 668.173 states in part that there is a timely return of title IV, HEA program funds in accordance with procedures established by the Secretary or FFEL Program lender, if an institution initiates an electronic funds transfer (EFT) or issues a check no later than 45 days after the date it determines that the student withdrew. Condition Special Tests and Provisions - Return of Title IV Funds The Purdue Fort Wayne campus did not properly design or implement an effective internal control system to ensure compliance with requirement for timely return of funds related to the Special Tests and Provisions - Return of Title IV Funds. Specifically, there was a lack of timeliness in initiating a return of Title IV funds, causing a return to be issued more than 45 days after the date the University became aware of student's withdrawal date. Questioned Costs There were no questioned costs identified. Context During our testing of the University's return of Title IV calculations, we noted 1 out of 13 students tested at the Purdue Fort Wayne campus (1 out of 40 students total tested) that had return of Title IV funds that were returned outside of the timeliness requirement. Cause and Effect The Purdue Fort Wayne campus experienced turnover in the Student Financial Aid Director position in Fall 2021. The temporary lack of staff resources caused the campus to have a failure in following internal policies and resulted in an untimely return of Title IV funds exceeding 45 days after the date the University became aware of student's withdrawal date, which was not in compliance with the established Return of Title IV policy. Recommendation We recommend that the Purdue Fort Wayne campus modify its existing internal control structure to ensure returns of Title IV funds are initiated timely, regardless of staff resource constraints, to ensure compliance with the Special Tests and Provisions - Return of Title IV Funds compliance requirements. Views of Responsible Officials and Corrective Action Plan The PFW Office of Financial Aid has an established Return of Title Four Aid (R2T4) policy and underlying control structure in place to ensure compliance with the R2T4 requirements. The PFW Office of Financial Aid will enhance its current R2T4 policy and procedure to include a step-by-step process to completing an R2T4. This will ensure that in the absence of the Assistant Director of Loans (who is currently responsible for R2T4 calculation completion) a succession list determining who is next in line to complete R2T4 calculations will be established to ensure these are completed in the 45-day window.
Finding 2022-001 Assistance Listing Number, Federal Agency, and Program Name Federal Agency: Department of Education Federal Programs: Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Numbers: 84.007, 84.063, 84.268 Finding Type: Significant Deficiency Repeat Finding: Yes 2021-004 Criteria 34 CFR 668.173 states in part that there is a timely return of title IV, HEA program funds in accordance with procedures established by the Secretary or FFEL Program lender, if an institution initiates an electronic funds transfer (EFT) or issues a check no later than 45 days after the date it determines that the student withdrew. Condition Special Tests and Provisions - Return of Title IV Funds The Purdue Fort Wayne campus did not properly design or implement an effective internal control system to ensure compliance with requirement for timely return of funds related to the Special Tests and Provisions - Return of Title IV Funds. Specifically, there was a lack of timeliness in initiating a return of Title IV funds, causing a return to be issued more than 45 days after the date the University became aware of student's withdrawal date. Questioned Costs There were no questioned costs identified. Context During our testing of the University's return of Title IV calculations, we noted 1 out of 13 students tested at the Purdue Fort Wayne campus (1 out of 40 students total tested) that had return of Title IV funds that were returned outside of the timeliness requirement. Cause and Effect The Purdue Fort Wayne campus experienced turnover in the Student Financial Aid Director position in Fall 2021. The temporary lack of staff resources caused the campus to have a failure in following internal policies and resulted in an untimely return of Title IV funds exceeding 45 days after the date the University became aware of student's withdrawal date, which was not in compliance with the established Return of Title IV policy. Recommendation We recommend that the Purdue Fort Wayne campus modify its existing internal control structure to ensure returns of Title IV funds are initiated timely, regardless of staff resource constraints, to ensure compliance with the Special Tests and Provisions - Return of Title IV Funds compliance requirements. Views of Responsible Officials and Corrective Action Plan The PFW Office of Financial Aid has an established Return of Title Four Aid (R2T4) policy and underlying control structure in place to ensure compliance with the R2T4 requirements. The PFW Office of Financial Aid will enhance its current R2T4 policy and procedure to include a step-by-step process to completing an R2T4. This will ensure that in the absence of the Assistant Director of Loans (who is currently responsible for R2T4 calculation completion) a succession list determining who is next in line to complete R2T4 calculations will be established to ensure these are completed in the 45-day window.
Finding 2022-002 Assistance Listing Number, Federal Agency, and Program Name Federal Agency: Department of Education Federal Program: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425F Finding Type: Significant Deficiency Repeat Finding: No Criteria Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure expenses are recorded only when purchased goods or services have been received. Costs should be determined in accordance with generally accepted accounting principles (GAAP) as described in 2 CFR Part 200. Condition The Purdue Fort Wayne campus did not have adequate controls in place to ensure invoices related to technology services were properly recorded in accordance with GAAP. Questioned Costs There were no questioned costs identified. Context During our testing of expenditures, we noted 2 out of 32 HEERF institutional portion expenditure samples tested included expenses initially recorded in the improper period and improperly included on the SEFA. The identified error was $301,717 and was removed from the SEFA as of June 30, 2022. Cause and Effect The failure to establish an effective internal control to review technology services expenditures caused the Purdue Fort Wayne campus to improperly include expenses related to fiscal year 2023 in fiscal year 2022, which was not in compliance with generally accepting accounting principles. Recommendation We recommend that the Purdue Fort Wayne campus ensure employees receive proper training to ensure policies and procedures are followed and expenditures are recorded in the proper period. Views of Responsible Officials and Corrective Action Plan The University system, including the Purdue Fort Wayne (PFW) Campus, has internal controls and training in place related to non-catalog purchases and the review of Goods Receipt/Invoice Receipt (GRIR) discrepancies. In the case of these two purchase orders, it appears these were isolated instances where established controls were not fully implemented as designed. These processes will be covered in staff meetings on all campuses and Procurement Services will review and update non-catalog order instructions and GRIR report documentation to ensure clear guidance is given.
Finding 2022-003 Assistance Listing Number, Federal Agency, and Program Name Federal Agency: Department of Education Federal Program: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425F Finding Type: Material Weakness Repeat Finding: Yes 2021-003 Criteria The Coronavirus Aid, Relief, and Economic Security (CARES) Act Section 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 section 314(e) require an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time and in such a manner as the secretary may require. American Rescue Plan Section 2003 specifies that the same terms and conditions of CRRSAA Section 314 apply to HEERF III funds. While the acts do not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, pursuant to these requirements, the Department of Education required quarterly public reporting of student portion and institutional portion awards. Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure reports include accurate and complete information and are submitted timely. Condition The University did not properly design or implement an effective internal control system to ensure HEERF reports were properly completed and posted. Questioned Costs There were no questioned costs identified. Context During our testing, we tested one annual report and six quarterly reports submitted by the University. The Purdue Northwest (PNW) campus and Purdue Fort Wayne (PFW) campuses did not comply with the HEERF student portion reporting requirement for quarter ended December 31, 2021 and quarter ended March 31, 2022, failing to complete quarterly reporting on their website related to the HEERF student portion. PNW subsequently updated their website on April 10, 2022 and PFW subsequently updated their website on September 30, 2022 to report cumulative information for the HEERF student portion. Cause and Effect PNW and PFW campuses had not developed a system of internal controls to ensure reports are completed timely, reviewed and submitted in accordance with HEERF reporting requirements. The failure to establish an effective internal control caused required reports to not be completed for PNW and PFW campuses. Recommendation We recommend the PNW and PFW campuses modify existing internal control structures to include internal controls that would ensure compliance with HEERF reporting requirements. Views of Responsible Officials and Corrective Action Plan The PFW Office of Financial Aid Director will complete the quarterly reports and a dual review process will be implemented to ensure accuracy. The quarterly report will be updated on the HEERF site and sent to the Assistant Director of Enrollment and Institutional Scholarships to post. The information posted will be compared to the reports submitted quarterly. PNW acknowledges that, while it had the appropriate Institutional HERF reporting completed, they missed updating the required student portion questions and answers that get posted to the reporting webpage. Once that was discovered, it was corrected in April 2022. PNW has ensured that the process now identifies looking at both the combined (updated) reporting PDF and the questions and answers that are required to be posted to the reporting webpage.