Improper Payroll Calculation
Federal Agency: U.S. Department of Education
Federal Program Name: Education Stabilization Fund
Assistance Listing Number: 84.425F
Federal Award Identification Number: P425F200181‐20B
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non‐Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Compliance – Per 2 CFR § 200.403, except where otherwise authorized by statute, costs must meet the following general criteria to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award to be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award regarding types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally‐financed and other activities of the non‐Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not be included
as a cost or used to meet cost sharing or matching requirements of any other federally‐financed program in either the current or a prior period. (g) Be adequately documented.
Condition: The University incorrectly calculated payroll costs charged to the grant. The employee’s position changed from hourly to salary, and the change in pay was not reflected in the payroll calculation resulting in an error of $47.
Questioned costs: None
Context: This condition occurred for 1 out of 40 samples selected for testing.
Cause: The interface program looked at the employee's status on the day of upload, as opposed to their status on the last day of the pay period. Therefore, the program uploaded hours to the new job instead of the former hourly job. This error was not caught by the department during or after payroll processing resulting in an overpayment.
Effect: Expenditures may be incorrectly charged to the program.
Repeat Finding: No
Recommendation: We recommend that the University review policies and procedures to ensure that changes in pay rates are being reflected in payroll calculations and reviews are in place to detect any errors on a timely basis.
Views of responsible officials: There is no disagreement with the audit finding.
Review over Cash Drawdowns
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.033, 84.408, 84.063, 84.007, 84.379, 84.268
Federal Award Identification Number and Year: P033A223771 (CWS 22‐23), P408A220377 (Iraq Afgan Service), P063P220377 (Pell 22‐23), P007A223771 (SEOG 22‐23), P379T230377 (Teach 22‐23), P268K230377 (Direct Loan 2023)
Pass‐Through Agency: N/A
Pass‐Through Number(s): N/A
Award Period: 7/1/22 – 6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non‐Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: The University did not perform a control review of amounts requested for drawdown from G5 at, or prior to, draw.
Questioned costs: None
Context: This condition occurred for 7 out of 7 draws selected for testing.
Cause: The federal G5 system does not have a workflow component to route transactions for approval. The University’s Director of Financial Compliance reviews all awarded amounts, calculates a percentage to allow for award adjustments to mitigate the risk of overdraw, and initiates the draw of federal scholarship funding from the G5 system.
Effect: This condition may lead to errors in the calculation or amounts drawn in excess of amounts disbursed.
Repeat Finding: No
Recommendation: As an opportunity to enhance the current control environment and reduce the likelihood of errors, the University should implement a drawdown review and approval process prior to requesting federal funds.
Views of responsible officials: There is no disagreement with the audit finding.
Review over Cash Drawdowns
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.033, 84.408, 84.063, 84.007, 84.379, 84.268
Federal Award Identification Number and Year: P033A223771 (CWS 22‐23), P408A220377 (Iraq Afgan Service), P063P220377 (Pell 22‐23), P007A223771 (SEOG 22‐23), P379T230377 (Teach 22‐23), P268K230377 (Direct Loan 2023)
Pass‐Through Agency: N/A
Pass‐Through Number(s): N/A
Award Period: 7/1/22 – 6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non‐Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: The University did not perform a control review of amounts requested for drawdown from G5 at, or prior to, draw.
Questioned costs: None
Context: This condition occurred for 7 out of 7 draws selected for testing.
Cause: The federal G5 system does not have a workflow component to route transactions for approval. The University’s Director of Financial Compliance reviews all awarded amounts, calculates a percentage to allow for award adjustments to mitigate the risk of overdraw, and initiates the draw of federal scholarship funding from the G5 system.
Effect: This condition may lead to errors in the calculation or amounts drawn in excess of amounts disbursed.
Repeat Finding: No
Recommendation: As an opportunity to enhance the current control environment and reduce the likelihood of errors, the University should implement a drawdown review and approval process prior to requesting federal funds.
Views of responsible officials: There is no disagreement with the audit finding.
Review over Cash Drawdowns
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.033, 84.408, 84.063, 84.007, 84.379, 84.268
Federal Award Identification Number and Year: P033A223771 (CWS 22‐23), P408A220377 (Iraq Afgan Service), P063P220377 (Pell 22‐23), P007A223771 (SEOG 22‐23), P379T230377 (Teach 22‐23), P268K230377 (Direct Loan 2023)
Pass‐Through Agency: N/A
Pass‐Through Number(s): N/A
Award Period: 7/1/22 – 6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non‐Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: The University did not perform a control review of amounts requested for drawdown from G5 at, or prior to, draw.
Questioned costs: None
Context: This condition occurred for 7 out of 7 draws selected for testing.
Cause: The federal G5 system does not have a workflow component to route transactions for approval. The University’s Director of Financial Compliance reviews all awarded amounts, calculates a percentage to allow for award adjustments to mitigate the risk of overdraw, and initiates the draw of federal scholarship funding from the G5 system.
Effect: This condition may lead to errors in the calculation or amounts drawn in excess of amounts disbursed.
Repeat Finding: No
Recommendation: As an opportunity to enhance the current control environment and reduce the likelihood of errors, the University should implement a drawdown review and approval process prior to requesting federal funds.
Views of responsible officials: There is no disagreement with the audit finding.
Review over Cash Drawdowns
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.033, 84.408, 84.063, 84.007, 84.379, 84.268
Federal Award Identification Number and Year: P033A223771 (CWS 22‐23), P408A220377 (Iraq Afgan Service), P063P220377 (Pell 22‐23), P007A223771 (SEOG 22‐23), P379T230377 (Teach 22‐23), P268K230377 (Direct Loan 2023)
Pass‐Through Agency: N/A
Pass‐Through Number(s): N/A
Award Period: 7/1/22 – 6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non‐Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: The University did not perform a control review of amounts requested for drawdown from G5 at, or prior to, draw.
Questioned costs: None
Context: This condition occurred for 7 out of 7 draws selected for testing.
Cause: The federal G5 system does not have a workflow component to route transactions for approval. The University’s Director of Financial Compliance reviews all awarded amounts, calculates a percentage to allow for award adjustments to mitigate the risk of overdraw, and initiates the draw of federal scholarship funding from the G5 system.
Effect: This condition may lead to errors in the calculation or amounts drawn in excess of amounts disbursed.
Repeat Finding: No
Recommendation: As an opportunity to enhance the current control environment and reduce the likelihood of errors, the University should implement a drawdown review and approval process prior to requesting federal funds.
Views of responsible officials: There is no disagreement with the audit finding.
Review over Cash Drawdowns
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.033, 84.408, 84.063, 84.007, 84.379, 84.268
Federal Award Identification Number and Year: P033A223771 (CWS 22‐23), P408A220377 (Iraq Afgan Service), P063P220377 (Pell 22‐23), P007A223771 (SEOG 22‐23), P379T230377 (Teach 22‐23), P268K230377 (Direct Loan 2023)
Pass‐Through Agency: N/A
Pass‐Through Number(s): N/A
Award Period: 7/1/22 – 6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non‐Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: The University did not perform a control review of amounts requested for drawdown from G5 at, or prior to, draw.
Questioned costs: None
Context: This condition occurred for 7 out of 7 draws selected for testing.
Cause: The federal G5 system does not have a workflow component to route transactions for approval. The University’s Director of Financial Compliance reviews all awarded amounts, calculates a percentage to allow for award adjustments to mitigate the risk of overdraw, and initiates the draw of federal scholarship funding from the G5 system.
Effect: This condition may lead to errors in the calculation or amounts drawn in excess of amounts disbursed.
Repeat Finding: No
Recommendation: As an opportunity to enhance the current control environment and reduce the likelihood of errors, the University should implement a drawdown review and approval process prior to requesting federal funds.
Views of responsible officials: There is no disagreement with the audit finding.
Review over Cash Drawdowns
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.033, 84.408, 84.063, 84.007, 84.379, 84.268
Federal Award Identification Number and Year: P033A223771 (CWS 22‐23), P408A220377 (Iraq Afgan Service), P063P220377 (Pell 22‐23), P007A223771 (SEOG 22‐23), P379T230377 (Teach 22‐23), P268K230377 (Direct Loan 2023)
Pass‐Through Agency: N/A
Pass‐Through Number(s): N/A
Award Period: 7/1/22 – 6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non‐Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: The University did not perform a control review of amounts requested for drawdown from G5 at, or prior to, draw.
Questioned costs: None
Context: This condition occurred for 7 out of 7 draws selected for testing.
Cause: The federal G5 system does not have a workflow component to route transactions for approval. The University’s Director of Financial Compliance reviews all awarded amounts, calculates a percentage to allow for award adjustments to mitigate the risk of overdraw, and initiates the draw of federal scholarship funding from the G5 system.
Effect: This condition may lead to errors in the calculation or amounts drawn in excess of amounts disbursed.
Repeat Finding: No
Recommendation: As an opportunity to enhance the current control environment and reduce the likelihood of errors, the University should implement a drawdown review and approval process prior to requesting federal funds.
Views of responsible officials: There is no disagreement with the audit finding.
Late COD Reporting
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063
Federal Award Identification Number and Year: P063P220377 (Pell 22‐23)
Pass‐Through Agency: N/A
Pass‐Through Number(s): N/A
Award Period: 7/1/22 – 6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non‐Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Compliance – Per 34 CFR 690.83(b)(2), the University is required to report the disbursement dates and amounts awarded for Pell awards to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell funds to a student.
Condition: The University did not report certain Pell disbursements within 15 days to COD.
Questioned costs: None
Context: For four out of eight Pell disbursements tested across a sample of twelve students receiving Pell awards, the University did not report disbursements until 47 days after disbursement.
Cause: Some Pell disbursements were reported late because of a Banner system defect. This defect prevented the disbursements from sending and did not provide any error acknowledgement on the extract reports.
Effect: The University is not in compliance with required reporting to the Department of Education.
Repeat Finding: No
Recommendation: We recommend the University ensure that a process is in place to report within 15 days, including a process to respond and report timely when there are system irregularities.
Views of responsible officials: There is no disagreement with the audit finding.
Incorrect Fiscal Operations Report and Application to Participate (FISAP) Reporting
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.033
Federal Award Identification Number and Year: P033A223771 (CWS 22‐23)
Pass‐Through Agency: N/A
Pass‐Through Number(s): N/A
Award Period: 7/1/22 – 6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non‐Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Compliance ‐ The Code of Federal Regulations, 34 CFR 668.24(e)(i) requires an institution to maintain records to support the data contained in the FISAP.
Condition: The documents retained by the University to support amounts included in the FISAP did not agree to the FISAP.
Questioned costs: None
Context: The amounts reported in the FISAP did not agree to supporting documentation
Cause: Part III, line 9.2 was a human error in transferring numbers from the supporting document to the FISAP. A line was left blank, and this blank did not cause a validation error. Usually, the FISAP will not let you submit if it is out of balance or if a question is skipped. However, we did not receive an error for this one. Part V, line 24 was a difference in interpretation whether America Reads and other community service students should be added together. After consultation and research, we decided they should be added together in the future.
Effect: The information in the FISAP is utilized to assist in the awarding of future awards and incorrect data could negatively impact future awards.
Repeat Finding: No
Recommendation: We recommend the University create a formalized review process for the FISAP and ensure all supporting schedules used to populate the form are centrally stored.
Views of responsible officials: There is no disagreement with the audit finding.
Late Return of Checks Outstanding Greater than 240 Days
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.268
Federal Award Identification Number and Year: P268K230377 (Direct Loan 2023)
Pass‐Through Agency: N/A
Pass‐Through Number(s): N/A
Award Period: 7/1/22 – 6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non‐Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Compliance ‐ The Code of Federal Regulations, 34 CFR 668.164(l) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: A check related to Title IV disbursements was never cashed and outstanding greater than 240 days.
Questioned costs: None
Context: The University had 23 checks outstanding for greater than 240 days. One of the 23 checks was related to Title IV funds that were never cashed and should have been returned to the Department of Education. The check was originally dated and issued in March 2021. A replacement check was issued and cashed by the student.
Cause: Stale‐dated check reconciliations were not received in a timely manner and staff training was deficient.
Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department.
Repeat Finding: No
Recommendation: We recommend the University establish a process to monitor the bank reconciliation for outstanding Title IV checks to adhere to the 240‐day requirement.
Views of responsible officials: There is no disagreement with the audit finding.
NSLDS Program Level Reporting
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.268
Federal Award Identification Number and Year: P063P220377 (Pell 22‐23), P268K230377 (Direct Loan 2023)
Pass‐Through Agency: N/A
Pass‐Through Number(s): N/A
Award Period: 7/1/22 – 6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non‐Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Compliance ‐ Per the National Student Loan Data System (NSLDS) Enrollment Reporting Guide, schools are required to report enrollment at both the Program‐Level and the Campus‐Level. Included in this required reporting is an Enrollment Effective Date for each program which a student is enrolled. The Enrollment Status Effective Date is defined as “the date that the current enrollment status reported for a student was first effective.”
Condition: A student was not reported with the correct enrollment effective dates within the Program‐Level enrollment reporting in NSLDS.
Questioned costs: None
Context: For one out of 40 students selected for testing, the Program‐Level enrollment effective date of 5/19/23 did not match the Campus‐Level enrollment effective date of 5/16/23.
Cause: Clemson University reported to the National Clearinghouse (NCH) that the student dropped and added classes on 5/19/23, which resulted in the same enrollment level that was reported for the Campus‐Level enrollment effective date of 5/16/23.
Effect: Enrollment effective dates are not reported accurately at the Program‐Level reporting in NSLDS.
Repeat Finding: No
Recommendation: We recommend the University review its reporting procedures to ensure that students’ enrollment effective dates are accurately reported within the Program‐Level enrollment reporting to NSLDS as required by regulations.
Views of responsible officials: There is no disagreement with the audit finding.
NSLDS Program Level Reporting
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.268
Federal Award Identification Number and Year: P063P220377 (Pell 22‐23), P268K230377 (Direct Loan 2023)
Pass‐Through Agency: N/A
Pass‐Through Number(s): N/A
Award Period: 7/1/22 – 6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non‐Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Compliance ‐ Per the National Student Loan Data System (NSLDS) Enrollment Reporting Guide, schools are required to report enrollment at both the Program‐Level and the Campus‐Level. Included in this required reporting is an Enrollment Effective Date for each program which a student is enrolled. The Enrollment Status Effective Date is defined as “the date that the current enrollment status reported for a student was first effective.”
Condition: A student was not reported with the correct enrollment effective dates within the Program‐Level enrollment reporting in NSLDS.
Questioned costs: None
Context: For one out of 40 students selected for testing, the Program‐Level enrollment effective date of 5/19/23 did not match the Campus‐Level enrollment effective date of 5/16/23.
Cause: Clemson University reported to the National Clearinghouse (NCH) that the student dropped and added classes on 5/19/23, which resulted in the same enrollment level that was reported for the Campus‐Level enrollment effective date of 5/16/23.
Effect: Enrollment effective dates are not reported accurately at the Program‐Level reporting in NSLDS.
Repeat Finding: No
Recommendation: We recommend the University review its reporting procedures to ensure that students’ enrollment effective dates are accurately reported within the Program‐Level enrollment reporting to NSLDS as required by regulations.
Views of responsible officials: There is no disagreement with the audit finding.
Improper Payroll Calculation
Federal Agency: U.S. Department of Education
Federal Program Name: Education Stabilization Fund
Assistance Listing Number: 84.425F
Federal Award Identification Number: P425F200181‐20B
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non‐Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Compliance – Per 2 CFR § 200.403, except where otherwise authorized by statute, costs must meet the following general criteria to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award to be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award regarding types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally‐financed and other activities of the non‐Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not be included
as a cost or used to meet cost sharing or matching requirements of any other federally‐financed program in either the current or a prior period. (g) Be adequately documented.
Condition: The University incorrectly calculated payroll costs charged to the grant. The employee’s position changed from hourly to salary, and the change in pay was not reflected in the payroll calculation resulting in an error of $47.
Questioned costs: None
Context: This condition occurred for 1 out of 40 samples selected for testing.
Cause: The interface program looked at the employee's status on the day of upload, as opposed to their status on the last day of the pay period. Therefore, the program uploaded hours to the new job instead of the former hourly job. This error was not caught by the department during or after payroll processing resulting in an overpayment.
Effect: Expenditures may be incorrectly charged to the program.
Repeat Finding: No
Recommendation: We recommend that the University review policies and procedures to ensure that changes in pay rates are being reflected in payroll calculations and reviews are in place to detect any errors on a timely basis.
Views of responsible officials: There is no disagreement with the audit finding.
Review over Cash Drawdowns
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.033, 84.408, 84.063, 84.007, 84.379, 84.268
Federal Award Identification Number and Year: P033A223771 (CWS 22‐23), P408A220377 (Iraq Afgan Service), P063P220377 (Pell 22‐23), P007A223771 (SEOG 22‐23), P379T230377 (Teach 22‐23), P268K230377 (Direct Loan 2023)
Pass‐Through Agency: N/A
Pass‐Through Number(s): N/A
Award Period: 7/1/22 – 6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non‐Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: The University did not perform a control review of amounts requested for drawdown from G5 at, or prior to, draw.
Questioned costs: None
Context: This condition occurred for 7 out of 7 draws selected for testing.
Cause: The federal G5 system does not have a workflow component to route transactions for approval. The University’s Director of Financial Compliance reviews all awarded amounts, calculates a percentage to allow for award adjustments to mitigate the risk of overdraw, and initiates the draw of federal scholarship funding from the G5 system.
Effect: This condition may lead to errors in the calculation or amounts drawn in excess of amounts disbursed.
Repeat Finding: No
Recommendation: As an opportunity to enhance the current control environment and reduce the likelihood of errors, the University should implement a drawdown review and approval process prior to requesting federal funds.
Views of responsible officials: There is no disagreement with the audit finding.
Review over Cash Drawdowns
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.033, 84.408, 84.063, 84.007, 84.379, 84.268
Federal Award Identification Number and Year: P033A223771 (CWS 22‐23), P408A220377 (Iraq Afgan Service), P063P220377 (Pell 22‐23), P007A223771 (SEOG 22‐23), P379T230377 (Teach 22‐23), P268K230377 (Direct Loan 2023)
Pass‐Through Agency: N/A
Pass‐Through Number(s): N/A
Award Period: 7/1/22 – 6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non‐Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: The University did not perform a control review of amounts requested for drawdown from G5 at, or prior to, draw.
Questioned costs: None
Context: This condition occurred for 7 out of 7 draws selected for testing.
Cause: The federal G5 system does not have a workflow component to route transactions for approval. The University’s Director of Financial Compliance reviews all awarded amounts, calculates a percentage to allow for award adjustments to mitigate the risk of overdraw, and initiates the draw of federal scholarship funding from the G5 system.
Effect: This condition may lead to errors in the calculation or amounts drawn in excess of amounts disbursed.
Repeat Finding: No
Recommendation: As an opportunity to enhance the current control environment and reduce the likelihood of errors, the University should implement a drawdown review and approval process prior to requesting federal funds.
Views of responsible officials: There is no disagreement with the audit finding.
Review over Cash Drawdowns
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.033, 84.408, 84.063, 84.007, 84.379, 84.268
Federal Award Identification Number and Year: P033A223771 (CWS 22‐23), P408A220377 (Iraq Afgan Service), P063P220377 (Pell 22‐23), P007A223771 (SEOG 22‐23), P379T230377 (Teach 22‐23), P268K230377 (Direct Loan 2023)
Pass‐Through Agency: N/A
Pass‐Through Number(s): N/A
Award Period: 7/1/22 – 6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non‐Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: The University did not perform a control review of amounts requested for drawdown from G5 at, or prior to, draw.
Questioned costs: None
Context: This condition occurred for 7 out of 7 draws selected for testing.
Cause: The federal G5 system does not have a workflow component to route transactions for approval. The University’s Director of Financial Compliance reviews all awarded amounts, calculates a percentage to allow for award adjustments to mitigate the risk of overdraw, and initiates the draw of federal scholarship funding from the G5 system.
Effect: This condition may lead to errors in the calculation or amounts drawn in excess of amounts disbursed.
Repeat Finding: No
Recommendation: As an opportunity to enhance the current control environment and reduce the likelihood of errors, the University should implement a drawdown review and approval process prior to requesting federal funds.
Views of responsible officials: There is no disagreement with the audit finding.
Review over Cash Drawdowns
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.033, 84.408, 84.063, 84.007, 84.379, 84.268
Federal Award Identification Number and Year: P033A223771 (CWS 22‐23), P408A220377 (Iraq Afgan Service), P063P220377 (Pell 22‐23), P007A223771 (SEOG 22‐23), P379T230377 (Teach 22‐23), P268K230377 (Direct Loan 2023)
Pass‐Through Agency: N/A
Pass‐Through Number(s): N/A
Award Period: 7/1/22 – 6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non‐Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: The University did not perform a control review of amounts requested for drawdown from G5 at, or prior to, draw.
Questioned costs: None
Context: This condition occurred for 7 out of 7 draws selected for testing.
Cause: The federal G5 system does not have a workflow component to route transactions for approval. The University’s Director of Financial Compliance reviews all awarded amounts, calculates a percentage to allow for award adjustments to mitigate the risk of overdraw, and initiates the draw of federal scholarship funding from the G5 system.
Effect: This condition may lead to errors in the calculation or amounts drawn in excess of amounts disbursed.
Repeat Finding: No
Recommendation: As an opportunity to enhance the current control environment and reduce the likelihood of errors, the University should implement a drawdown review and approval process prior to requesting federal funds.
Views of responsible officials: There is no disagreement with the audit finding.
Review over Cash Drawdowns
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.033, 84.408, 84.063, 84.007, 84.379, 84.268
Federal Award Identification Number and Year: P033A223771 (CWS 22‐23), P408A220377 (Iraq Afgan Service), P063P220377 (Pell 22‐23), P007A223771 (SEOG 22‐23), P379T230377 (Teach 22‐23), P268K230377 (Direct Loan 2023)
Pass‐Through Agency: N/A
Pass‐Through Number(s): N/A
Award Period: 7/1/22 – 6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non‐Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: The University did not perform a control review of amounts requested for drawdown from G5 at, or prior to, draw.
Questioned costs: None
Context: This condition occurred for 7 out of 7 draws selected for testing.
Cause: The federal G5 system does not have a workflow component to route transactions for approval. The University’s Director of Financial Compliance reviews all awarded amounts, calculates a percentage to allow for award adjustments to mitigate the risk of overdraw, and initiates the draw of federal scholarship funding from the G5 system.
Effect: This condition may lead to errors in the calculation or amounts drawn in excess of amounts disbursed.
Repeat Finding: No
Recommendation: As an opportunity to enhance the current control environment and reduce the likelihood of errors, the University should implement a drawdown review and approval process prior to requesting federal funds.
Views of responsible officials: There is no disagreement with the audit finding.
Review over Cash Drawdowns
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.033, 84.408, 84.063, 84.007, 84.379, 84.268
Federal Award Identification Number and Year: P033A223771 (CWS 22‐23), P408A220377 (Iraq Afgan Service), P063P220377 (Pell 22‐23), P007A223771 (SEOG 22‐23), P379T230377 (Teach 22‐23), P268K230377 (Direct Loan 2023)
Pass‐Through Agency: N/A
Pass‐Through Number(s): N/A
Award Period: 7/1/22 – 6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non‐Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: The University did not perform a control review of amounts requested for drawdown from G5 at, or prior to, draw.
Questioned costs: None
Context: This condition occurred for 7 out of 7 draws selected for testing.
Cause: The federal G5 system does not have a workflow component to route transactions for approval. The University’s Director of Financial Compliance reviews all awarded amounts, calculates a percentage to allow for award adjustments to mitigate the risk of overdraw, and initiates the draw of federal scholarship funding from the G5 system.
Effect: This condition may lead to errors in the calculation or amounts drawn in excess of amounts disbursed.
Repeat Finding: No
Recommendation: As an opportunity to enhance the current control environment and reduce the likelihood of errors, the University should implement a drawdown review and approval process prior to requesting federal funds.
Views of responsible officials: There is no disagreement with the audit finding.
Late COD Reporting
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063
Federal Award Identification Number and Year: P063P220377 (Pell 22‐23)
Pass‐Through Agency: N/A
Pass‐Through Number(s): N/A
Award Period: 7/1/22 – 6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non‐Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Compliance – Per 34 CFR 690.83(b)(2), the University is required to report the disbursement dates and amounts awarded for Pell awards to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell funds to a student.
Condition: The University did not report certain Pell disbursements within 15 days to COD.
Questioned costs: None
Context: For four out of eight Pell disbursements tested across a sample of twelve students receiving Pell awards, the University did not report disbursements until 47 days after disbursement.
Cause: Some Pell disbursements were reported late because of a Banner system defect. This defect prevented the disbursements from sending and did not provide any error acknowledgement on the extract reports.
Effect: The University is not in compliance with required reporting to the Department of Education.
Repeat Finding: No
Recommendation: We recommend the University ensure that a process is in place to report within 15 days, including a process to respond and report timely when there are system irregularities.
Views of responsible officials: There is no disagreement with the audit finding.
Incorrect Fiscal Operations Report and Application to Participate (FISAP) Reporting
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.033
Federal Award Identification Number and Year: P033A223771 (CWS 22‐23)
Pass‐Through Agency: N/A
Pass‐Through Number(s): N/A
Award Period: 7/1/22 – 6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non‐Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Compliance ‐ The Code of Federal Regulations, 34 CFR 668.24(e)(i) requires an institution to maintain records to support the data contained in the FISAP.
Condition: The documents retained by the University to support amounts included in the FISAP did not agree to the FISAP.
Questioned costs: None
Context: The amounts reported in the FISAP did not agree to supporting documentation
Cause: Part III, line 9.2 was a human error in transferring numbers from the supporting document to the FISAP. A line was left blank, and this blank did not cause a validation error. Usually, the FISAP will not let you submit if it is out of balance or if a question is skipped. However, we did not receive an error for this one. Part V, line 24 was a difference in interpretation whether America Reads and other community service students should be added together. After consultation and research, we decided they should be added together in the future.
Effect: The information in the FISAP is utilized to assist in the awarding of future awards and incorrect data could negatively impact future awards.
Repeat Finding: No
Recommendation: We recommend the University create a formalized review process for the FISAP and ensure all supporting schedules used to populate the form are centrally stored.
Views of responsible officials: There is no disagreement with the audit finding.
Late Return of Checks Outstanding Greater than 240 Days
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.268
Federal Award Identification Number and Year: P268K230377 (Direct Loan 2023)
Pass‐Through Agency: N/A
Pass‐Through Number(s): N/A
Award Period: 7/1/22 – 6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non‐Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Compliance ‐ The Code of Federal Regulations, 34 CFR 668.164(l) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check.
Condition: A check related to Title IV disbursements was never cashed and outstanding greater than 240 days.
Questioned costs: None
Context: The University had 23 checks outstanding for greater than 240 days. One of the 23 checks was related to Title IV funds that were never cashed and should have been returned to the Department of Education. The check was originally dated and issued in March 2021. A replacement check was issued and cashed by the student.
Cause: Stale‐dated check reconciliations were not received in a timely manner and staff training was deficient.
Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department.
Repeat Finding: No
Recommendation: We recommend the University establish a process to monitor the bank reconciliation for outstanding Title IV checks to adhere to the 240‐day requirement.
Views of responsible officials: There is no disagreement with the audit finding.
NSLDS Program Level Reporting
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.268
Federal Award Identification Number and Year: P063P220377 (Pell 22‐23), P268K230377 (Direct Loan 2023)
Pass‐Through Agency: N/A
Pass‐Through Number(s): N/A
Award Period: 7/1/22 – 6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non‐Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Compliance ‐ Per the National Student Loan Data System (NSLDS) Enrollment Reporting Guide, schools are required to report enrollment at both the Program‐Level and the Campus‐Level. Included in this required reporting is an Enrollment Effective Date for each program which a student is enrolled. The Enrollment Status Effective Date is defined as “the date that the current enrollment status reported for a student was first effective.”
Condition: A student was not reported with the correct enrollment effective dates within the Program‐Level enrollment reporting in NSLDS.
Questioned costs: None
Context: For one out of 40 students selected for testing, the Program‐Level enrollment effective date of 5/19/23 did not match the Campus‐Level enrollment effective date of 5/16/23.
Cause: Clemson University reported to the National Clearinghouse (NCH) that the student dropped and added classes on 5/19/23, which resulted in the same enrollment level that was reported for the Campus‐Level enrollment effective date of 5/16/23.
Effect: Enrollment effective dates are not reported accurately at the Program‐Level reporting in NSLDS.
Repeat Finding: No
Recommendation: We recommend the University review its reporting procedures to ensure that students’ enrollment effective dates are accurately reported within the Program‐Level enrollment reporting to NSLDS as required by regulations.
Views of responsible officials: There is no disagreement with the audit finding.
NSLDS Program Level Reporting
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.268
Federal Award Identification Number and Year: P063P220377 (Pell 22‐23), P268K230377 (Direct Loan 2023)
Pass‐Through Agency: N/A
Pass‐Through Number(s): N/A
Award Period: 7/1/22 – 6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non‐Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Compliance ‐ Per the National Student Loan Data System (NSLDS) Enrollment Reporting Guide, schools are required to report enrollment at both the Program‐Level and the Campus‐Level. Included in this required reporting is an Enrollment Effective Date for each program which a student is enrolled. The Enrollment Status Effective Date is defined as “the date that the current enrollment status reported for a student was first effective.”
Condition: A student was not reported with the correct enrollment effective dates within the Program‐Level enrollment reporting in NSLDS.
Questioned costs: None
Context: For one out of 40 students selected for testing, the Program‐Level enrollment effective date of 5/19/23 did not match the Campus‐Level enrollment effective date of 5/16/23.
Cause: Clemson University reported to the National Clearinghouse (NCH) that the student dropped and added classes on 5/19/23, which resulted in the same enrollment level that was reported for the Campus‐Level enrollment effective date of 5/16/23.
Effect: Enrollment effective dates are not reported accurately at the Program‐Level reporting in NSLDS.
Repeat Finding: No
Recommendation: We recommend the University review its reporting procedures to ensure that students’ enrollment effective dates are accurately reported within the Program‐Level enrollment reporting to NSLDS as required by regulations.
Views of responsible officials: There is no disagreement with the audit finding.