Audit 22802

FY End
2022-06-30
Total Expended
$17.04M
Findings
2
Programs
19
Organization: The Reed Institute (OR)
Year: 2022 Accepted: 2022-11-15
Auditor: Kpmg LLP

Organization Exclusion Status:

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Findings

ID Ref Severity Repeat Requirement
24396 2022-001 Significant Deficiency Yes L
600838 2022-001 Significant Deficiency Yes L

Contacts

Name Title Type
CMNJCKH6LTK6 Rob Tust Auditee
5037777505 Sarah Opfer Auditor
No contacts on file

Notes to SEFA

Title: Loan/loan guarantee outstanding balances Accounting Policies: (1) Basis of PresentationThe accompanying schedule of expenditures of federal awards (the Schedule) includes the federal award activity of The Reed Institute (the College) under programs of the federal government for the year ended June 30, 2022. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the College, it is not intended to and does not presentthe financial position, changes in net assets, or cash flows of the College.(2) Summary of Significant Accounting PoliciesExpenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. PERKINS (84.038) - Balances outstanding at the end of the audit period were 1104458. FEDERAL DIRECT STUDENT LOANS (84.268) - Balances outstanding at the end of the audit period were 4936120.

Finding Details

Federal program and specific federal award identification Federal program: COVID-19-Education Stabilization Fund-Higher Education Emergency Relief Fund (HEERF) Assistance listing number: 84.425E ? Student Aid Portion Federal Agency: United States Department of Education Pass-through entity: None Grant ID number: P425E202283 Federal Award Year ended: June 30, 2022 Criteria or specific requirement Quarterly Public Reporting for Student Aid Portion (Assistance Listings 84.425E) Section 18004(e) of the CARES Act requires each institution that received funds under Section 18004 to ?submit a report to the Secretary, at such time and in such manner as the Secretary may require.? For the year ended June 30, 2022, institutions were required to post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. 2 CFR 200.303(a) requires that non-Federal entities receiving Federal awards establish and maintain effective internal control over the Federal award to provide reasonable assurance that they are managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition found For one of the four quarters inspected (Q1 - 2022), the College did not have the required control procedures to ensure the HEERF student aid portion reporting was reviewed and posted to the College?s website timely. The College did not document when student aid reporting was reviewed and posted to the College?s website, so we are unable to determine the timeliness of the submission. Cause The College did not have adequate internal controls in place related to reporting requirements for the HEERF program student award portion. Possible effect Federal oversight agencies, including the Department of Education, depend on accurate reports to measure program results and institutional compliance with federal requirements. By failing to have an appropriately designed and implemented review control over the HEERF student aid portion reporting in place, the College could have material non-compliance with the requirements of the HEERF Certification and agreement. Identification of questioned costs and how they were computed None. Whether the sampling was a statistically valid sample The sample was not intended to be, and was not, a statistically valid sample. Identification of whether the audit finding is a repeat of a finding in the immediately prior audit and, if so, the applicable prior year finding number Yes. Finding 2021-001. Finding 2022-001 had already occurred when finding 2021-001 was identified. Recommendations The College should strengthen its internal controls over HEERF reporting requirements for the Student Aid portion of the grant by developing and documenting a formalized review process, including documentation of the date reporting was uploaded to the College?s website, for the student award reporting. Views of responsible officials The following corrective measures have been implemented: The Director of Financial Aid requests the amounts and number of students who received HEERF funding from the Business Office at the end of each quarter and reviews, confirms, and documents the date of request and review. A log of the website updates is maintained to document timely submission of data. The website was revamped to include all necessary reporting requirements including the number of eligible students for CRSSA HEERF II and ARP HEERF III. This updated process was implemented upon identification of the prior year finding, which occurred after the first quarterly report for fiscal year 2022 was posted."
Federal program and specific federal award identification Federal program: COVID-19-Education Stabilization Fund-Higher Education Emergency Relief Fund (HEERF) Assistance listing number: 84.425E ? Student Aid Portion Federal Agency: United States Department of Education Pass-through entity: None Grant ID number: P425E202283 Federal Award Year ended: June 30, 2022 Criteria or specific requirement Quarterly Public Reporting for Student Aid Portion (Assistance Listings 84.425E) Section 18004(e) of the CARES Act requires each institution that received funds under Section 18004 to ?submit a report to the Secretary, at such time and in such manner as the Secretary may require.? For the year ended June 30, 2022, institutions were required to post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. 2 CFR 200.303(a) requires that non-Federal entities receiving Federal awards establish and maintain effective internal control over the Federal award to provide reasonable assurance that they are managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition found For one of the four quarters inspected (Q1 - 2022), the College did not have the required control procedures to ensure the HEERF student aid portion reporting was reviewed and posted to the College?s website timely. The College did not document when student aid reporting was reviewed and posted to the College?s website, so we are unable to determine the timeliness of the submission. Cause The College did not have adequate internal controls in place related to reporting requirements for the HEERF program student award portion. Possible effect Federal oversight agencies, including the Department of Education, depend on accurate reports to measure program results and institutional compliance with federal requirements. By failing to have an appropriately designed and implemented review control over the HEERF student aid portion reporting in place, the College could have material non-compliance with the requirements of the HEERF Certification and agreement. Identification of questioned costs and how they were computed None. Whether the sampling was a statistically valid sample The sample was not intended to be, and was not, a statistically valid sample. Identification of whether the audit finding is a repeat of a finding in the immediately prior audit and, if so, the applicable prior year finding number Yes. Finding 2021-001. Finding 2022-001 had already occurred when finding 2021-001 was identified. Recommendations The College should strengthen its internal controls over HEERF reporting requirements for the Student Aid portion of the grant by developing and documenting a formalized review process, including documentation of the date reporting was uploaded to the College?s website, for the student award reporting. Views of responsible officials The following corrective measures have been implemented: The Director of Financial Aid requests the amounts and number of students who received HEERF funding from the Business Office at the end of each quarter and reviews, confirms, and documents the date of request and review. A log of the website updates is maintained to document timely submission of data. The website was revamped to include all necessary reporting requirements including the number of eligible students for CRSSA HEERF II and ARP HEERF III. This updated process was implemented upon identification of the prior year finding, which occurred after the first quarterly report for fiscal year 2022 was posted."