Criteria or specific requirement: Per the Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. In accordance with section 2003 of the American Rescue Plan Act of 2021 (ARPA) (Pub. L. 117-2) (supplemental award or grant) by the U.S. Department of Education and section 2003 of the ARPA and section 314 of the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA) (Pub. L. 116-260), recipients must promptly and timely provide a detailed accounting of the use and expenditure of the funds provided by these supplemental award in such manner and with such frequency as the Secretary may require. There are three required components: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition: During our reporting testing, we noted that there were elements of the student quarterly reporting, institutional quarterly reporting, and annual reporting that were not accurate. Questioned costs: N/A Context: We tested two of the four required quarterly student reports, two of the four required quarterly institutional reports, and the required annual report. Noncompliance on each report is below: Student Quarterly Reporting ? On both reports tested, the University reported total amount and count of emergency financial aid grants distributed cumulatively based on appropriation, not on a quarterly basis, as prescribed. Non-Compliant Institutional Quarterly Reporting. ? One of the two reports tested was an estimate of expenses incurred instead of being updated for actual expenses in the preceding quarter. Non-Compliant Annual Reporting ? The total amounts of emergency financial aid grants disbursed directly to students and applied to satisfy student's outstanding account balances on the 2021 Annual Report were incorrect. Cause: The policies and procedures of the University did not ensure that grant reporting requirements were accurately met. Effect: The University was not in compliance with HEERF reporting requirements. Repeat finding: No Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.beta.sam.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: We sampled four covered transactions that lacked documentation supporting that the vendor was not suspended or debarred. Management had historically elected to verify the vendor was not suspended or debarred by checking the SAM exclusion list as maintained by the GSA; however, no evidence was retained by the University to support the list was checked prior to entering into the covered transaction. Questioned costs: N/A Context: All four covered transactions tested for suspension and debarment compliance lacked documentation supporting that the University verified the vendor was not suspended or debarred prior to entering into the covered transactions. Cause: Management did not retain evidence demonstrating they verified the vendors were not suspended or debarred prior to entering into the covered transaction. Effect: By not retaining evidence that management verified vendors were not suspended or debarred, Management may erroneously enter into a covered transaction with vendors that were suspended or debarred. Repeat finding: Yes 2021-004 Recommendation: As part of the June 30, 2021 compliance audit, we recommended management adopt a policy to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the GSA website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. Management has indicated this policy was implemented in March 2023. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Under section 2003(5) of the American Rescue Plan Act (ARPA) of 2021 (ARP) (Pub. L. 117-2) (supplemental award or grant) by the U.S. Department of Education, Recipient must use a portion of their institutional funds received under this supplemental award to (a) to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the Higher Education Act of 1965, as amended (HEA) (20 USC ? 1087tt). Condition: During our testing, we noted that the University only met the earmarking requirement to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines. The University did not meet the requirement to conduct direct outreach to financial aid applicants. Questioned costs: Unknown. Context: During our testing, we noted that the University was not in compliance with the ARPA Earmarking requirements. Cause: The policies and procedures of the University did not ensure that grant earmarking requirements were accurately met. Effect: Non-compliance with federal regulations could lead to funds being required to be returned or reallocated in order to meet the earmarking requirement. Repeat finding: No Recommendation: We recommend that the University understand and monitor the earmarking requirements of all grants to ensure compliance requirements are met. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per the Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. In accordance with section 2003 of the American Rescue Plan Act of 2021 (ARPA) (Pub. L. 117-2) (supplemental award or grant) by the U.S. Department of Education and section 2003 of the ARPA and section 314 of the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA) (Pub. L. 116-260), recipients must promptly and timely provide a detailed accounting of the use and expenditure of the funds provided by these supplemental award in such manner and with such frequency as the Secretary may require. There are three required components: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition: During our reporting testing, we noted that there were elements of the student quarterly reporting, institutional quarterly reporting, and annual reporting that were not accurate. Questioned costs: N/A Context: We tested two of the four required quarterly student reports, two of the four required quarterly institutional reports, and the required annual report. Noncompliance on each report is below: Student Quarterly Reporting ? On both reports tested, the University reported total amount and count of emergency financial aid grants distributed cumulatively based on appropriation, not on a quarterly basis, as prescribed. Non-Compliant Institutional Quarterly Reporting. ? One of the two reports tested was an estimate of expenses incurred instead of being updated for actual expenses in the preceding quarter. Non-Compliant Annual Reporting ? The total amounts of emergency financial aid grants disbursed directly to students and applied to satisfy student's outstanding account balances on the 2021 Annual Report were incorrect. Cause: The policies and procedures of the University did not ensure that grant reporting requirements were accurately met. Effect: The University was not in compliance with HEERF reporting requirements. Repeat finding: No Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per the Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. In accordance with section 2003 of the American Rescue Plan Act of 2021 (ARPA) (Pub. L. 117-2) (supplemental award or grant) by the U.S. Department of Education and section 2003 of the ARPA and section 314 of the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA) (Pub. L. 116-260), recipients must promptly and timely provide a detailed accounting of the use and expenditure of the funds provided by these supplemental award in such manner and with such frequency as the Secretary may require. There are three required components: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition: During our reporting testing, we noted that there were elements of the student quarterly reporting, institutional quarterly reporting, and annual reporting that were not accurate. Questioned costs: N/A Context: We tested two of the four required quarterly student reports, two of the four required quarterly institutional reports, and the required annual report. Noncompliance on each report is below: Student Quarterly Reporting ? On both reports tested, the University reported total amount and count of emergency financial aid grants distributed cumulatively based on appropriation, not on a quarterly basis, as prescribed. Non-Compliant Institutional Quarterly Reporting. ? One of the two reports tested was an estimate of expenses incurred instead of being updated for actual expenses in the preceding quarter. Non-Compliant Annual Reporting ? The total amounts of emergency financial aid grants disbursed directly to students and applied to satisfy student's outstanding account balances on the 2021 Annual Report were incorrect. Cause: The policies and procedures of the University did not ensure that grant reporting requirements were accurately met. Effect: The University was not in compliance with HEERF reporting requirements. Repeat finding: No Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.beta.sam.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: We sampled four covered transactions that lacked documentation supporting that the vendor was not suspended or debarred. Management had historically elected to verify the vendor was not suspended or debarred by checking the SAM exclusion list as maintained by the GSA; however, no evidence was retained by the University to support the list was checked prior to entering into the covered transaction. Questioned costs: N/A Context: All four covered transactions tested for suspension and debarment compliance lacked documentation supporting that the University verified the vendor was not suspended or debarred prior to entering into the covered transactions. Cause: Management did not retain evidence demonstrating they verified the vendors were not suspended or debarred prior to entering into the covered transaction. Effect: By not retaining evidence that management verified vendors were not suspended or debarred, Management may erroneously enter into a covered transaction with vendors that were suspended or debarred. Repeat finding: Yes 2021-004 Recommendation: As part of the June 30, 2021 compliance audit, we recommended management adopt a policy to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the GSA website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. Management has indicated this policy was implemented in March 2023. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Under section 2003(5) of the American Rescue Plan Act (ARPA) of 2021 (ARP) (Pub. L. 117-2) (supplemental award or grant) by the U.S. Department of Education, Recipient must use a portion of their institutional funds received under this supplemental award to (a) to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the Higher Education Act of 1965, as amended (HEA) (20 USC ? 1087tt). Condition: During our testing, we noted that the University only met the earmarking requirement to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines. The University did not meet the requirement to conduct direct outreach to financial aid applicants. Questioned costs: Unknown. Context: During our testing, we noted that the University was not in compliance with the ARPA Earmarking requirements. Cause: The policies and procedures of the University did not ensure that grant earmarking requirements were accurately met. Effect: Non-compliance with federal regulations could lead to funds being required to be returned or reallocated in order to meet the earmarking requirement. Repeat finding: No Recommendation: We recommend that the University understand and monitor the earmarking requirements of all grants to ensure compliance requirements are met. View of responsible official: The University agrees with the finding.
Criteria or specific requirement: Per the Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. In accordance with section 2003 of the American Rescue Plan Act of 2021 (ARPA) (Pub. L. 117-2) (supplemental award or grant) by the U.S. Department of Education and section 2003 of the ARPA and section 314 of the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA) (Pub. L. 116-260), recipients must promptly and timely provide a detailed accounting of the use and expenditure of the funds provided by these supplemental award in such manner and with such frequency as the Secretary may require. There are three required components: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition: During our reporting testing, we noted that there were elements of the student quarterly reporting, institutional quarterly reporting, and annual reporting that were not accurate. Questioned costs: N/A Context: We tested two of the four required quarterly student reports, two of the four required quarterly institutional reports, and the required annual report. Noncompliance on each report is below: Student Quarterly Reporting ? On both reports tested, the University reported total amount and count of emergency financial aid grants distributed cumulatively based on appropriation, not on a quarterly basis, as prescribed. Non-Compliant Institutional Quarterly Reporting. ? One of the two reports tested was an estimate of expenses incurred instead of being updated for actual expenses in the preceding quarter. Non-Compliant Annual Reporting ? The total amounts of emergency financial aid grants disbursed directly to students and applied to satisfy student's outstanding account balances on the 2021 Annual Report were incorrect. Cause: The policies and procedures of the University did not ensure that grant reporting requirements were accurately met. Effect: The University was not in compliance with HEERF reporting requirements. Repeat finding: No Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. View of responsible official: The University agrees with the finding.