Audit 291876

FY End
2023-06-30
Total Expended
$7.48M
Findings
2
Programs
5
Year: 2023 Accepted: 2024-02-23

Organization Exclusion Status:

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Findings

ID Ref Severity Repeat Requirement
370261 2023-002 Significant Deficiency - L
946703 2023-002 Significant Deficiency - L

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $5.59M Yes 0
84.063 Federal Pell Grant Program $1.51M Yes 0
84.425 Education Stabilization Fund $283,415 Yes 1
84.007 Federal Supplemental Educational Opportunity Grants $51,499 Yes 0
84.033 Federal Work-Study Program $36,559 Yes 0

Contacts

Name Title Type
J8LJEM6B33Q3 Eugene Munin Auditee
2393047998 Darby Beaverson, CPA Auditor
No contacts on file

Notes to SEFA

Title: Note A - Basis of Presentation and Significant Accounting Policies Accounting Policies: The accompanying schedule of expenditures of federal awards and state awards (the “Schedule”) includes the federal and state grant activity of Ave Maria University, Inc. and Subsidiaries (the “University”) under programs of the federal government and the State of Florida for the year ended June 30, 2023. Expenditures reported on the Schedule are reported on the accrual basis of accounting, although the basis for determining when federal and state awards are expended is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 215.97, Florida Statutes, and Chapter 10.650, Rules of the Florida Auditor General. In addition, expenditures reported on the Schedule are recognized following the cost principles contained in the Uniform Guidance. Therefore, some amounts presented in this Schedule may differ from amounts presented in, or used in the preparation of, the basic consolidated financial statements. Because the Schedule presents only a selected portion of the operations of the University, it is not intended to and does not present the consolidated financial position, changes in net assets, or cash flows, if applicable, of the University. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The accompanying schedule of expenditures of federal awards and state awards (the “Schedule”) includes the federal and state grant activity of Ave Maria University, Inc. and Subsidiaries (the “University”) under programs of the federal government and the State of Florida for the year ended June 30, 2023. Expenditures reported on the Schedule are reported on the accrual basis of accounting, although the basis for determining when federal and state awards are expended is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 215.97, Florida Statutes, and Chapter 10.650, Rules of the Florida Auditor General. In addition, expenditures reported on the Schedule are recognized following the cost principles contained in the Uniform Guidance. Therefore, some amounts presented in this Schedule may differ from amounts presented in, or used in the preparation of, the basic consolidated financial statements. Because the Schedule presents only a selected portion of the operations of the University, it is not intended to and does not present the consolidated financial position, changes in net assets, or cash flows, if applicable, of the University.
Title: Note B - 10-Percent De Minimis Election Accounting Policies: The accompanying schedule of expenditures of federal awards and state awards (the “Schedule”) includes the federal and state grant activity of Ave Maria University, Inc. and Subsidiaries (the “University”) under programs of the federal government and the State of Florida for the year ended June 30, 2023. Expenditures reported on the Schedule are reported on the accrual basis of accounting, although the basis for determining when federal and state awards are expended is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 215.97, Florida Statutes, and Chapter 10.650, Rules of the Florida Auditor General. In addition, expenditures reported on the Schedule are recognized following the cost principles contained in the Uniform Guidance. Therefore, some amounts presented in this Schedule may differ from amounts presented in, or used in the preparation of, the basic consolidated financial statements. Because the Schedule presents only a selected portion of the operations of the University, it is not intended to and does not present the consolidated financial position, changes in net assets, or cash flows, if applicable, of the University. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. Ave Maria University has elected not to use the 10-percent de minimis indirect cost rate allowed under Uniform Guidance.

Finding Details

Finding: 2023-002 Program Affected: COVID-19 Higher Education Emergency Relief Fund (HEERF) (AL Number 84.425E) Finding Type: Significant deficiency on internal control Criteria: The HEERF I, II, and III funding came with various requirements instituted by the CARES Act, CRRSAA, and ARP and then further defined by the US Department of Education (ED). The ED exercised its reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329 to define three reporting requirements for the HEERF program funds, which include 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. These reporting requirements stipulate specific guidelines regarding when, how, and what information is to be reported on quarterly and the annual reports. Condition: Per review of the University’s annual report, we noted three instances where the amounts and information reported did not agree to the internal records. Issues noted included incorrect amounts and information posted for the Emergency Financial Aid grants, monitoring and suppressing coronavirus, and total of institutional annual expenditures. Cause: Reporting requirements posted by the Department of Education for HEERF program funds have continuously changed with the intent to be made clearer with each subsequent revision. However, it is difficult to draw conclusions on some of the reporting guidance. There were not adequate controls nor review processes in place to monitor the reporting requirements issued by the Department of Education to ensure the annual report was posted accurately. Effect: The effect or possible effect is that the University may be determined ineligible to receive future HEERF program funding. Additionally, the program does not have accurate information regarding how HEERF program funds were expended by the University. Questioned Costs: None Recommendation: Controls should be established to allow for a second detailed review of all reporting of HEERF program funds by an official extensively familiar with the reporting requirements published by the Department of Education and other regulators. Auditee's Response: The reports will be monitored more closely going forward. See attached corrective action plan.
Finding: 2023-002 Program Affected: COVID-19 Higher Education Emergency Relief Fund (HEERF) (AL Number 84.425E) Finding Type: Significant deficiency on internal control Criteria: The HEERF I, II, and III funding came with various requirements instituted by the CARES Act, CRRSAA, and ARP and then further defined by the US Department of Education (ED). The ED exercised its reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329 to define three reporting requirements for the HEERF program funds, which include 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. These reporting requirements stipulate specific guidelines regarding when, how, and what information is to be reported on quarterly and the annual reports. Condition: Per review of the University’s annual report, we noted three instances where the amounts and information reported did not agree to the internal records. Issues noted included incorrect amounts and information posted for the Emergency Financial Aid grants, monitoring and suppressing coronavirus, and total of institutional annual expenditures. Cause: Reporting requirements posted by the Department of Education for HEERF program funds have continuously changed with the intent to be made clearer with each subsequent revision. However, it is difficult to draw conclusions on some of the reporting guidance. There were not adequate controls nor review processes in place to monitor the reporting requirements issued by the Department of Education to ensure the annual report was posted accurately. Effect: The effect or possible effect is that the University may be determined ineligible to receive future HEERF program funding. Additionally, the program does not have accurate information regarding how HEERF program funds were expended by the University. Questioned Costs: None Recommendation: Controls should be established to allow for a second detailed review of all reporting of HEERF program funds by an official extensively familiar with the reporting requirements published by the Department of Education and other regulators. Auditee's Response: The reports will be monitored more closely going forward. See attached corrective action plan.