Audit 298611

2023 – 005 Federal Agency: Department of Education Federal Program Name: Higher Education Aid – Title III Assistance Listing Numbers: 84.031 Federal Award Identification Number and Year: P031E200019, P031B170023 and P031B220048, grants were awarded within the 2022-23 award year. Award Period: July 1, 2022, through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters 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 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: During our testing of suspension and debarment, we noted the University did not have support for debarment checks two of the six vendors tested. Questioned Costs: N/A Context: During our testing of suspension and debarment, we noted the University did not have support for debarment checks two of the six vendors tested. Cause: The University did not have support to verify debarment checks were completed before entering into agreements or occurring expenditures for two of the six vendors selected. Effect: Suspended or debarred vendors could have been charged to the grant, resulting in unallowable expenditures occurring. Repeat Finding: No. Recommendation: The University should evaluate their procedures surrounding the maintenance of suspension and debarment checks.

2023 – 005 Federal Agency: Department of Education Federal Program Name: Higher Education Aid – Title III Assistance Listing Numbers: 84.031 Federal Award Identification Number and Year: P031E200019, P031B170023 and P031B220048, grants were awarded within the 2022-23 award year. Award Period: July 1, 2022, through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters 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 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: During our testing of suspension and debarment, we noted the University did not have support for debarment checks two of the six vendors tested. Questioned Costs: N/A Context: During our testing of suspension and debarment, we noted the University did not have support for debarment checks two of the six vendors tested. Cause: The University did not have support to verify debarment checks were completed before entering into agreements or occurring expenditures for two of the six vendors selected. Effect: Suspended or debarred vendors could have been charged to the grant, resulting in unallowable expenditures occurring. Repeat Finding: No. Recommendation: The University should evaluate their procedures surrounding the maintenance of suspension and debarment checks.

2023 – 003 Federal Agency: Department of Treasury Federal Program Name: Coronavirus State & Local Fiscal Recovery Fund Assistance Listing Numbers: 21.027 Federal Award Identification Number and Year: SLFRP1746, grants were awarded within the 2022-23. Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: Recipients of Coronavirus State & Local Fiscal Recovery Funds may use payments from SLRFR to replace lost public sector revenue to provide government services. Recipients may use this funding to provide government services to the extent of the reduction in revenue experience due to the pandemic. Under the Final Rule, recipients can elect a one-time “standard allowance” or they can calculate lost revenue based on the formula provide in the Final Rule to determine the amount of funds that can be used for the provision of government services. Condition: The University did not use the formula provided in the Final Rule when determining the amount of funds to claim under lost revenue. Questioned Costs: N/A Context: The University did not use the correct methodology when calculating lost revenue. Cause: The University did not use the correct methodology when calculating lost revenue. Effect: Lost revenue amount calculated could have resulted in more than allowed lost revenue being claimed. Repeat Finding: No. Recommendation: The University should evaluate their procedures and review their policies surrounding earmarking requirements.

2023 – 004 Federal Agency: Department of Treasury Federal Program Name: Coronavirus State & Local Fiscal Recovery Fund Assistance Listing Numbers: 21.027 Federal Award Identification Number and Year: SLFRP1746, grants were awarded within the 2022-23. Award Period: July 1, 2022, through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: 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. There are two components to reporting for Coronavirus State & Local Fiscal Recovery Funds: 1.) Obligation and Expenditures - Quantifiable objective criteria: Reported obligations and expenditures include Current period obligation, Cumulative obligation, Current period expenditure, and Cumulative expenditure. 2.) Capital Expenditures - Quantifiable Objective Criteria: The recipient has the required written justification in their grant file if the total of the capital expenditures costs in a project is greater than or equal to $1 million and less than $10 million. Condition: The University did not have support of the required reports being completed or submitted. Questioned Costs: N/A Context: The University did not have support of the required reports being completed or submitted. Cause: The University’s policies and procedures did not ensure that grant reporting requirements were timely and accurately met. Effect: The University is not complying with awarding requirements, which could affect the amount of Federal funding received. Repeat Finding: No. Recommendation: The University should evaluate their procedures and review their policies surrounding review of grant reporting requirements.

2023 – 005 Federal Agency: Department of Education Federal Program Name: Higher Education Aid – Title III Assistance Listing Numbers: 84.031 Federal Award Identification Number and Year: P031E200019, P031B170023 and P031B220048, grants were awarded within the 2022-23 award year. Award Period: July 1, 2022, through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters 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 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: During our testing of suspension and debarment, we noted the University did not have support for debarment checks two of the six vendors tested. Questioned Costs: N/A Context: During our testing of suspension and debarment, we noted the University did not have support for debarment checks two of the six vendors tested. Cause: The University did not have support to verify debarment checks were completed before entering into agreements or occurring expenditures for two of the six vendors selected. Effect: Suspended or debarred vendors could have been charged to the grant, resulting in unallowable expenditures occurring. Repeat Finding: No. Recommendation: The University should evaluate their procedures surrounding the maintenance of suspension and debarment checks.

2023 – 005 Federal Agency: Department of Education Federal Program Name: Higher Education Aid – Title III Assistance Listing Numbers: 84.031 Federal Award Identification Number and Year: P031E200019, P031B170023 and P031B220048, grants were awarded within the 2022-23 award year. Award Period: July 1, 2022, through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters 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 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: During our testing of suspension and debarment, we noted the University did not have support for debarment checks two of the six vendors tested. Questioned Costs: N/A Context: During our testing of suspension and debarment, we noted the University did not have support for debarment checks two of the six vendors tested. Cause: The University did not have support to verify debarment checks were completed before entering into agreements or occurring expenditures for two of the six vendors selected. Effect: Suspended or debarred vendors could have been charged to the grant, resulting in unallowable expenditures occurring. Repeat Finding: No. Recommendation: The University should evaluate their procedures surrounding the maintenance of suspension and debarment checks.

2023 – 003 Federal Agency: Department of Treasury Federal Program Name: Coronavirus State & Local Fiscal Recovery Fund Assistance Listing Numbers: 21.027 Federal Award Identification Number and Year: SLFRP1746, grants were awarded within the 2022-23. Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: Recipients of Coronavirus State & Local Fiscal Recovery Funds may use payments from SLRFR to replace lost public sector revenue to provide government services. Recipients may use this funding to provide government services to the extent of the reduction in revenue experience due to the pandemic. Under the Final Rule, recipients can elect a one-time “standard allowance” or they can calculate lost revenue based on the formula provide in the Final Rule to determine the amount of funds that can be used for the provision of government services. Condition: The University did not use the formula provided in the Final Rule when determining the amount of funds to claim under lost revenue. Questioned Costs: N/A Context: The University did not use the correct methodology when calculating lost revenue. Cause: The University did not use the correct methodology when calculating lost revenue. Effect: Lost revenue amount calculated could have resulted in more than allowed lost revenue being claimed. Repeat Finding: No. Recommendation: The University should evaluate their procedures and review their policies surrounding earmarking requirements.

2023 – 004 Federal Agency: Department of Treasury Federal Program Name: Coronavirus State & Local Fiscal Recovery Fund Assistance Listing Numbers: 21.027 Federal Award Identification Number and Year: SLFRP1746, grants were awarded within the 2022-23. Award Period: July 1, 2022, through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: 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. There are two components to reporting for Coronavirus State & Local Fiscal Recovery Funds: 1.) Obligation and Expenditures - Quantifiable objective criteria: Reported obligations and expenditures include Current period obligation, Cumulative obligation, Current period expenditure, and Cumulative expenditure. 2.) Capital Expenditures - Quantifiable Objective Criteria: The recipient has the required written justification in their grant file if the total of the capital expenditures costs in a project is greater than or equal to $1 million and less than $10 million. Condition: The University did not have support of the required reports being completed or submitted. Questioned Costs: N/A Context: The University did not have support of the required reports being completed or submitted. Cause: The University’s policies and procedures did not ensure that grant reporting requirements were timely and accurately met. Effect: The University is not complying with awarding requirements, which could affect the amount of Federal funding received. Repeat Finding: No. Recommendation: The University should evaluate their procedures and review their policies surrounding review of grant reporting requirements.