2023-001: SEFA Reporting – R&D Classification
Federal Agency: Department of Health and Human Services
Federal Program Title: Medical Student Education Program, Prevention of Disease, Disability, and Death by Infection Diseases, and Postdoctoral Training in General Dentistry
Assistance Listing Number: 93.680, 93.084, 93.059
Award Number and Year: T99HP39200 (July 1, 2020 – June 30, 2024), NU2GGH002319 (September 30, 2020 – September 29, 2024), D88HP375559200 (July 1, 2020 – June 30, 2024)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters
Applicable Institution: University of Mississippi Medical Center (UMMC)
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 – 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with §200.502.
Condition: The Schedule of Expenditures of Federal Awards (SEFA) contained errors and incorrect information which affected the major program determination.
Questioned Costs: None noted as the reporting requirement does not affect the allowability of costs and/or activities.
Context: The following SEFA errors were noted:
• Amounts provided by UMMC incorrectly reported $4,558,549 in the Research & Development Cluster that should have been classified as expenditures for the Medical Student Education program (Assistance Listing 93.680).
• Amounts provided by UMMC incorrectly reported $622,758 in the Research & Development Cluster that should have been classified as expenditures for the Prevention of Disease, Disability, and Death by Infection Diseases Program (Assistance Listing 93.084).
• Amounts provided by UMMC incorrectly reported $383,695 in the Research & Development Cluster that should have been classified as expenditures for the Postdoctoral Training in General Dentistry Program (Assistance Listing 93.059).
Cause: Awards were incorrectly coded as Research & Development during the award set-up process.
Effect: The SEFA was not prepared in accordance with OMB requirements which affects the major program risk assessment.
Repeat Finding: 2022-002
Recommendation: We recommend the institution review and revise its current reporting procedures and review requirements to ensure that federal expenditures are properly identified and classified.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-001: SEFA Reporting – R&D Classification
Federal Agency: Department of Health and Human Services
Federal Program Title: Medical Student Education Program, Prevention of Disease, Disability, and Death by Infection Diseases, and Postdoctoral Training in General Dentistry
Assistance Listing Number: 93.680, 93.084, 93.059
Award Number and Year: T99HP39200 (July 1, 2020 – June 30, 2024), NU2GGH002319 (September 30, 2020 – September 29, 2024), D88HP375559200 (July 1, 2020 – June 30, 2024)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters
Applicable Institution: University of Mississippi Medical Center (UMMC)
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 – 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with §200.502.
Condition: The Schedule of Expenditures of Federal Awards (SEFA) contained errors and incorrect information which affected the major program determination.
Questioned Costs: None noted as the reporting requirement does not affect the allowability of costs and/or activities.
Context: The following SEFA errors were noted:
• Amounts provided by UMMC incorrectly reported $4,558,549 in the Research & Development Cluster that should have been classified as expenditures for the Medical Student Education program (Assistance Listing 93.680).
• Amounts provided by UMMC incorrectly reported $622,758 in the Research & Development Cluster that should have been classified as expenditures for the Prevention of Disease, Disability, and Death by Infection Diseases Program (Assistance Listing 93.084).
• Amounts provided by UMMC incorrectly reported $383,695 in the Research & Development Cluster that should have been classified as expenditures for the Postdoctoral Training in General Dentistry Program (Assistance Listing 93.059).
Cause: Awards were incorrectly coded as Research & Development during the award set-up process.
Effect: The SEFA was not prepared in accordance with OMB requirements which affects the major program risk assessment.
Repeat Finding: 2022-002
Recommendation: We recommend the institution review and revise its current reporting procedures and review requirements to ensure that federal expenditures are properly identified and classified.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-001: SEFA Reporting – R&D Classification
Federal Agency: Department of Health and Human Services
Federal Program Title: Medical Student Education Program, Prevention of Disease, Disability, and Death by Infection Diseases, and Postdoctoral Training in General Dentistry
Assistance Listing Number: 93.680, 93.084, 93.059
Award Number and Year: T99HP39200 (July 1, 2020 – June 30, 2024), NU2GGH002319 (September 30, 2020 – September 29, 2024), D88HP375559200 (July 1, 2020 – June 30, 2024)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters
Applicable Institution: University of Mississippi Medical Center (UMMC)
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 – 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with §200.502.
Condition: The Schedule of Expenditures of Federal Awards (SEFA) contained errors and incorrect information which affected the major program determination.
Questioned Costs: None noted as the reporting requirement does not affect the allowability of costs and/or activities.
Context: The following SEFA errors were noted:
• Amounts provided by UMMC incorrectly reported $4,558,549 in the Research & Development Cluster that should have been classified as expenditures for the Medical Student Education program (Assistance Listing 93.680).
• Amounts provided by UMMC incorrectly reported $622,758 in the Research & Development Cluster that should have been classified as expenditures for the Prevention of Disease, Disability, and Death by Infection Diseases Program (Assistance Listing 93.084).
• Amounts provided by UMMC incorrectly reported $383,695 in the Research & Development Cluster that should have been classified as expenditures for the Postdoctoral Training in General Dentistry Program (Assistance Listing 93.059).
Cause: Awards were incorrectly coded as Research & Development during the award set-up process.
Effect: The SEFA was not prepared in accordance with OMB requirements which affects the major program risk assessment.
Repeat Finding: 2022-002
Recommendation: We recommend the institution review and revise its current reporting procedures and review requirements to ensure that federal expenditures are properly identified and classified.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-002: SEFA Reporting- Incorrect Assistance Listing Numbers, Non-Federal Amounts on SEFA
Federal Agency: Department of Education
Federal Program Title: Title I, Special Education Grants to States, Career and Technical Education
Assistance Listing Number: 84.010, 84.027, 84.048
Award Number and Year: VS010A0180024 (July 1, 2020 – June 30, 2023), H027A190108 (July 1, 2020 – June 30, 2023), V048A190024 (July 1, 2020 – June 30, 2023)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters
Applicable Institution: Mississippi State University (MSU)
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 – 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with §200.502.
Condition:
The Schedule of Expenditures of Federal Awards (SEFA) contained errors and incorrect information which affected the major program determination.
Questioned Costs: None noted as the reporting requirement does not affect the allowability of costs and/or activities.
Context:
The following SEFA errors were noted:
• Amounts provided by MSU incorrectly reported $371,067 in the Title I Program (Assistance Listing 84.010) that should have been reported in Special Education Grants to States (Assistance Listing Number 84.027).
• Amounts provided by MSU incorrectly reported $902,101 in the Title I Program (Assistance Listing 84.010) that should have been reported in Career and Technical Education (Assistance Listing Number 84.048).
• Amounts provided by MSU incorrectly reported $2,011,409 in the Title I Program (Assistance Listing 84.010) that were State Grants and not reportable on the SEFA.
Cause: Mississippi State University did not have a process in place for awards that includes multiple ALNs and sources of funding.
Effect: The SEFA was not prepared in accordance with OMB requirements which affects the major program risk assessment.
Repeat Finding: 2022-002
Recommendation: We recommend the institution review and revise its current reporting procedures and review requirements to ensure that federal expenditures are properly identified and classified.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-002: SEFA Reporting- Incorrect Assistance Listing Numbers, Non-Federal Amounts on SEFA
Federal Agency: Department of Education
Federal Program Title: Title I, Special Education Grants to States, Career and Technical Education
Assistance Listing Number: 84.010, 84.027, 84.048
Award Number and Year: VS010A0180024 (July 1, 2020 – June 30, 2023), H027A190108 (July 1, 2020 – June 30, 2023), V048A190024 (July 1, 2020 – June 30, 2023)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters
Applicable Institution: Mississippi State University (MSU)
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 – 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with §200.502.
Condition:
The Schedule of Expenditures of Federal Awards (SEFA) contained errors and incorrect information which affected the major program determination.
Questioned Costs: None noted as the reporting requirement does not affect the allowability of costs and/or activities.
Context:
The following SEFA errors were noted:
• Amounts provided by MSU incorrectly reported $371,067 in the Title I Program (Assistance Listing 84.010) that should have been reported in Special Education Grants to States (Assistance Listing Number 84.027).
• Amounts provided by MSU incorrectly reported $902,101 in the Title I Program (Assistance Listing 84.010) that should have been reported in Career and Technical Education (Assistance Listing Number 84.048).
• Amounts provided by MSU incorrectly reported $2,011,409 in the Title I Program (Assistance Listing 84.010) that were State Grants and not reportable on the SEFA.
Cause: Mississippi State University did not have a process in place for awards that includes multiple ALNs and sources of funding.
Effect: The SEFA was not prepared in accordance with OMB requirements which affects the major program risk assessment.
Repeat Finding: 2022-002
Recommendation: We recommend the institution review and revise its current reporting procedures and review requirements to ensure that federal expenditures are properly identified and classified.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-002: SEFA Reporting- Incorrect Assistance Listing Numbers, Non-Federal Amounts on SEFA
Federal Agency: Department of Education
Federal Program Title: Title I, Special Education Grants to States, Career and Technical Education
Assistance Listing Number: 84.010, 84.027, 84.048
Award Number and Year: VS010A0180024 (July 1, 2020 – June 30, 2023), H027A190108 (July 1, 2020 – June 30, 2023), V048A190024 (July 1, 2020 – June 30, 2023)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters
Applicable Institution: Mississippi State University (MSU)
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 – 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with §200.502.
Condition:
The Schedule of Expenditures of Federal Awards (SEFA) contained errors and incorrect information which affected the major program determination.
Questioned Costs: None noted as the reporting requirement does not affect the allowability of costs and/or activities.
Context:
The following SEFA errors were noted:
• Amounts provided by MSU incorrectly reported $371,067 in the Title I Program (Assistance Listing 84.010) that should have been reported in Special Education Grants to States (Assistance Listing Number 84.027).
• Amounts provided by MSU incorrectly reported $902,101 in the Title I Program (Assistance Listing 84.010) that should have been reported in Career and Technical Education (Assistance Listing Number 84.048).
• Amounts provided by MSU incorrectly reported $2,011,409 in the Title I Program (Assistance Listing 84.010) that were State Grants and not reportable on the SEFA.
Cause: Mississippi State University did not have a process in place for awards that includes multiple ALNs and sources of funding.
Effect: The SEFA was not prepared in accordance with OMB requirements which affects the major program risk assessment.
Repeat Finding: 2022-002
Recommendation: We recommend the institution review and revise its current reporting procedures and review requirements to ensure that federal expenditures are properly identified and classified.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003: SEFA Reporting –Expenditures Recorded in the Incorrect Period
Federal Agency: Department of Health and Human Services
Federal Program Title: Telehealth Center of Excellence
Assistance Listing Number: 93.211
Award Number and Year: U6631459 (September 1, 2021 – September 29, 2026)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: University of Mississippi Medical Center (UMMC)
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 – 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with §200.502.
Condition: Schedule of Expenditures of Federal Awards (SEFA) contained salary expenses of $1,175 that were not allowable and should have been removed from the SEFA.
Questioned Costs: None.
Context: For 1 out of 60 payroll expenditures selected for testing, the amount was not allowable and should not have been charged to the grant.
Cause: Transfer of project expenditures occurred late and resulted in effort not being certified for salary amount in question. As a result, the salary was not reported to the sponsor via an invoice or financial report. However, the department did not remove the salary expenditure from the project in a timely manner.
Effect: The SEFA does not reflect the accurate amount of federal expenditures for the year.
Repeat Finding: 2022-002
Recommendation: We recommend the institutions review and revise its current reporting procedures and review requirements to ensure that federal expenditures are properly identified, recorded, and classified in the accurate year.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004: Procurement
Federal Agency: Department of Education, United States Department of Agriculture, Federal Aviation Administration
Federal Program Title: GEAR UP Mississippi, Improving Efficiency in Catfish Aquaculture, ASSURE
Assistance Listing Number: 84.334, 10.001, 20.109
Award Number and Year: P334S190003 (August 23, 2019 – August 22, 2026), 58-6066-0-031 (April 1, 2020 – March 31, 2025), 15-C-UAS-MSU-A (May 8, 2015 – May 7, 2025)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: Mississippi State University (MSU)
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 200.320: Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following:
(A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit;
(B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or,
(C) For public institutions, a higher threshold consistent with State law.
Micro-purchase thresholds higher than $50,000 must be approved by the cognizant agency for indirect costs. The non-federal entity must submit a request with the requirements included in paragraph (a)(1)(iv) of this section. The increased threshold is valid until there is a change in status in which the justification was approved.
Condition: MSU established a micro-purchase threshold of $75,000 for contracted services and was not able to provide documentation to support this threshold.
Questioned Costs: None.
Context: For 3 out of the 7 contracts tested, the dollar amount of the contract was above the Federally established Micro-Threshold of $10,000, and price or rate quotations were not obtained providing for full and open competition.
Cause: Mississippi State University’s Procurement and Contracts Manual was updated in August 2022; however, the section addressing federal requirements was not properly addressed.
Effect: The institution procured services with a policy not meeting Federal requirements.
Repeat Finding: No
Recommendation: We recommend the institution review and revise their current procurement policy and review requirements to ensure that their policy is meeting Federal requirements.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004: Procurement
Federal Agency: Department of Education, United States Department of Agriculture, Federal Aviation Administration
Federal Program Title: GEAR UP Mississippi, Improving Efficiency in Catfish Aquaculture, ASSURE
Assistance Listing Number: 84.334, 10.001, 20.109
Award Number and Year: P334S190003 (August 23, 2019 – August 22, 2026), 58-6066-0-031 (April 1, 2020 – March 31, 2025), 15-C-UAS-MSU-A (May 8, 2015 – May 7, 2025)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: Mississippi State University (MSU)
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 200.320: Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following:
(A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit;
(B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or,
(C) For public institutions, a higher threshold consistent with State law.
Micro-purchase thresholds higher than $50,000 must be approved by the cognizant agency for indirect costs. The non-federal entity must submit a request with the requirements included in paragraph (a)(1)(iv) of this section. The increased threshold is valid until there is a change in status in which the justification was approved.
Condition: MSU established a micro-purchase threshold of $75,000 for contracted services and was not able to provide documentation to support this threshold.
Questioned Costs: None.
Context: For 3 out of the 7 contracts tested, the dollar amount of the contract was above the Federally established Micro-Threshold of $10,000, and price or rate quotations were not obtained providing for full and open competition.
Cause: Mississippi State University’s Procurement and Contracts Manual was updated in August 2022; however, the section addressing federal requirements was not properly addressed.
Effect: The institution procured services with a policy not meeting Federal requirements.
Repeat Finding: No
Recommendation: We recommend the institution review and revise their current procurement policy and review requirements to ensure that their policy is meeting Federal requirements.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004: Procurement
Federal Agency: Department of Education, United States Department of Agriculture, Federal Aviation Administration
Federal Program Title: GEAR UP Mississippi, Improving Efficiency in Catfish Aquaculture, ASSURE
Assistance Listing Number: 84.334, 10.001, 20.109
Award Number and Year: P334S190003 (August 23, 2019 – August 22, 2026), 58-6066-0-031 (April 1, 2020 – March 31, 2025), 15-C-UAS-MSU-A (May 8, 2015 – May 7, 2025)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: Mississippi State University (MSU)
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 200.320: Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following:
(A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit;
(B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or,
(C) For public institutions, a higher threshold consistent with State law.
Micro-purchase thresholds higher than $50,000 must be approved by the cognizant agency for indirect costs. The non-federal entity must submit a request with the requirements included in paragraph (a)(1)(iv) of this section. The increased threshold is valid until there is a change in status in which the justification was approved.
Condition: MSU established a micro-purchase threshold of $75,000 for contracted services and was not able to provide documentation to support this threshold.
Questioned Costs: None.
Context: For 3 out of the 7 contracts tested, the dollar amount of the contract was above the Federally established Micro-Threshold of $10,000, and price or rate quotations were not obtained providing for full and open competition.
Cause: Mississippi State University’s Procurement and Contracts Manual was updated in August 2022; however, the section addressing federal requirements was not properly addressed.
Effect: The institution procured services with a policy not meeting Federal requirements.
Repeat Finding: No
Recommendation: We recommend the institution review and revise their current procurement policy and review requirements to ensure that their policy is meeting Federal requirements.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-005: Indirect Costs
Federal Agency: U.S. Department of Health and Human Services
Federal Program Title: Value-Based Medical Student Education Training Program
Assistance Listing Number: 93.680
Award Number and Year: T99HP39200 (July 1, 2020 – June 30, 2024)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: University of Mississippi Medical Center (UMMC)
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. See also §200.306 Cost sharing or matching paragraph (b). (g) Be adequately documented. See also §§200.300 Statutory and national policy requirements through 200.309 Period of performance of this part.
Condition: Indirect cost expense was improperly calculated.
Questioned Costs: None
Context: This condition occurred for the one award in our population.
Cause: A transition to a new ERP system resulted in issues with calculating F&A according to our negotiated rate agreement. As a result, we recalculate F&A on each project when invoicing or reporting. This F&A entry was identified; however, it was not made timely.
Effect: Indirect costs may be incorrectly charged to the program.
Repeat Finding: No
Recommendation: We recommend the institution strengthen its internal controls to ensure that calculations are reviewed and adjusted for, if necessary, in a timely manner.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-006: Matching
Federal Agency: U.S. Department of Health and Human Services
Federal Program Title: Value-Based Medical Student Education Training Program
Assistance Listing Number: 93.680
Award Number and Year: T99HP39200 (July 1, 2020 – June 30, 2024)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Applicable Institution: University of Mississippi Medical Center (UMMC)
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: There is no review process in place to ensure matching requirements are met.
Questioned Costs: None
Context: Cost share expenditures are not being tracked separately and monitored for compliance over matching for this grant.
Cause: Required cost share was being tracked by the department in a spreadsheet rather than in Workday as required.
Effect: The match requirement may not be met.
Repeat Finding: No
Recommendation: We recommend the institution track cost share expenditures in a separate fund and perform periodic reviews to ensure the matching requirement is being met.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-007: FFATA Reporting
Federal Agency: Department of Health and Human Services
Federal Program Title: Telehealth Center of Excellence
Assistance Listing Number: 93.211
Award Number and Year: U6631459 (September 1, 2021 – September 29, 2026)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: University of Mississippi Medical Center (UMMC)
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 – Grantees must comply with the Federal Funding Accountability and Transparency Act (Act), which requires FFATA reporting to be filed annually.
Condition: FFATA reporting was not submitted timely.
Questioned Costs: None.
Context: The institution filed 2 of 2 FFATA reports selected for testing past the deadline.
Cause: The institution has experienced turnover and restructuring of the Office of Research and Sponsored Programs. As a result some routine reporting was delayed.
Effect: The institution is not able to file the reports on time which could affect future participation in the program.
Repeat Finding: No
Recommendation: We recommend the institution strengthens their understanding of the reporting requirements established by the grant and ensure reports are filed timely.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-008: Annual Performance Reporting
Federal Agency: U.S. Department of Health and Human Services
Federal Program Title: Head Start
Assistance Listing Number: 93.600
Award Number and Year: 04HE001242-01-00 (April 1, 2021 – March 31, 2023), 04CH011182-03-00 (August 1, 2019 – July 31, 2023)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: Mississippi State University (MSU)
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 – Grantees must submit an annual performance report to the U.S. Department of Health and Human Services each year of the project period using the Real Property Status Report SF-429.
Condition: The University filed the Real Property Status Report SF-429 after the deadline.
Questioned Costs: None.
Context: This condition occurred 1 of 1 reports selected for testing.
Cause: The SF 429 report was submitted late due to human error.
Effect: The institution is not able to file the reports on time which could affect future participation in the program.
Repeat Finding: No
Recommendation: We recommend the institutions review and revise its current reporting procedures and review requirements to ensure that the reports are submitted accurately and timely.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-009: Common Origination and Disbursement (COD)
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster
Assistance Listing Number: 84.268
Award Number and Year: P268K231706(March 25, 2022- August 31, 2028)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: Jackson State University (JSU)
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 – From the 2022-23 FSA Handbook: The date funds are credited to a student’s account in the institution’s general ledger or any subledger of the general ledger or paid to a student directly is the disbursement date the financial aid office reports to COD. The Common Origination and Disbursement (COD) additional requirements are:
(1) Schools must use the COD system to request and receive federal student aid funds, including Direct Loans, Pell Grants, and Campus-Based aid programs.
Schools must ensure that all disbursements of federal student aid are made through the COD system.
(2) Schools must reconcile their records with the COD system to ensure that all disbursements are accurately reported and recorded.
(3) Schools must comply with COD reporting requirements, including reporting disbursements, adjustments, and cancellations in a timely and accurate manner.
Condition: The Fall 2022 and Spring 2023 disbursement dates in COD for Parent Plus Direct Loans did not match the disbursement date on the student ledgers.
Questioned Costs: None
Context: This condition occurred for 2 out of the 8 students selected for testing.
Cause: A change in personnel during the 22-23 academic year caused this process to not be completed timely.
Effect: The COD disbursement date is reported to the Direct Loan servicers and is the time when interest begins to accrue on the loan funds. Inaccurate disbursement date reporting may lead to inaccurate student loan interest accruals.
Repeat Finding: No
Recommendation: We recommend that the entity strengthen its internal controls to ensure that all disbursement dates are reported to COD correctly.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-010: NSLDS Enrollment Reporting
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster
Assistance Listing Number: 84.063, 84.268
Award Number and Year: P063P211695 (March 25, 2022- August 31, 2028),
P268K221695 (March 25, 2022- August 31, 2028),
P063P221706 (March 25, 2022- August 31, 2028),
P268K231706 (March 25, 2022- August 31, 2028),
P063P211722 (March 25, 2022- August 31, 2028),
P063P221722 (March 25, 2022- August 31, 2028),
P268K221722 (March 25, 2022- August 31, 2028),
P268K231722 (March 25, 2022- August 31, 2028),
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution(s): Alcorn State University (ASU), Jackson State University (JSU), and University of Mississippi Medical Center (UMMC)
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 – All schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a Roster file (formerly called the Student Status Confirmation Report or SSCR). The School is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. Changes in enrollment to less than half-time, graduated, or withdrawn status must be reported within 30 days. However, if a Roster file is expected within 60 days, you may provide the data on that Roster file (34CFR section 682.610).
Condition: Enrollment dates and statuses did not agree to institution records or were not reported timely.
Questioned Costs: None
Context: Based on the audit procedures, the following discrepancies were noted:
For 1 out of 4 ASU students, the status was not certified every 60 days.
For 5 out of 8 JSU students, the effective enrollment date per institution records and NSLDS did not agree. For 1 out of 8 JSU students, the status change was not reported timely or certified within 60 days. For 1 out of 8 JSU students, NSLDS campus enrollment status has not been updated or verified.
For 2 out of 4 UMMC students, the effective enrollment date per institution records and NSLDS did not agree.
Cause:
ASU
Students were not reported in a timely manner doe to our enrollment certification officer being out of the office on extensive medical leave as well as the office being short staffed.
JSU
In some instances, the census and financial purge deadlines are extended to ensure students complete their registration requirements. When extensions are provided, the enrollment file is unable to be submitted timely and also causes delays in processing the Enrollment Error report.
UMMC
There were two students whose enrollment status changed from one term to the next but neither were captured in the enrollment file sent to the National Student Clearinghouse. Both students withdrew between enrollment submissions and early enough in the subsequent term, our clearinghouse enrollment report didn’t capture their enrollment change. Since they were not captured on our clearinghouse enrollment file, their enrollment status change (or their withdrawal from the institution) and effective date were not reported to the NSLDS.
Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period.
Repeat Finding: 2022-010
Recommendation: CLA recommends that the entity strengthen its internal controls to ensure that all enrollment records are reported correctly and timely.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-010: NSLDS Enrollment Reporting
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster
Assistance Listing Number: 84.063, 84.268
Award Number and Year: P063P211695 (March 25, 2022- August 31, 2028),
P268K221695 (March 25, 2022- August 31, 2028),
P063P221706 (March 25, 2022- August 31, 2028),
P268K231706 (March 25, 2022- August 31, 2028),
P063P211722 (March 25, 2022- August 31, 2028),
P063P221722 (March 25, 2022- August 31, 2028),
P268K221722 (March 25, 2022- August 31, 2028),
P268K231722 (March 25, 2022- August 31, 2028),
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution(s): Alcorn State University (ASU), Jackson State University (JSU), and University of Mississippi Medical Center (UMMC)
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 – All schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a Roster file (formerly called the Student Status Confirmation Report or SSCR). The School is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. Changes in enrollment to less than half-time, graduated, or withdrawn status must be reported within 30 days. However, if a Roster file is expected within 60 days, you may provide the data on that Roster file (34CFR section 682.610).
Condition: Enrollment dates and statuses did not agree to institution records or were not reported timely.
Questioned Costs: None
Context: Based on the audit procedures, the following discrepancies were noted:
For 1 out of 4 ASU students, the status was not certified every 60 days.
For 5 out of 8 JSU students, the effective enrollment date per institution records and NSLDS did not agree. For 1 out of 8 JSU students, the status change was not reported timely or certified within 60 days. For 1 out of 8 JSU students, NSLDS campus enrollment status has not been updated or verified.
For 2 out of 4 UMMC students, the effective enrollment date per institution records and NSLDS did not agree.
Cause:
ASU
Students were not reported in a timely manner doe to our enrollment certification officer being out of the office on extensive medical leave as well as the office being short staffed.
JSU
In some instances, the census and financial purge deadlines are extended to ensure students complete their registration requirements. When extensions are provided, the enrollment file is unable to be submitted timely and also causes delays in processing the Enrollment Error report.
UMMC
There were two students whose enrollment status changed from one term to the next but neither were captured in the enrollment file sent to the National Student Clearinghouse. Both students withdrew between enrollment submissions and early enough in the subsequent term, our clearinghouse enrollment report didn’t capture their enrollment change. Since they were not captured on our clearinghouse enrollment file, their enrollment status change (or their withdrawal from the institution) and effective date were not reported to the NSLDS.
Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period.
Repeat Finding: 2022-010
Recommendation: CLA recommends that the entity strengthen its internal controls to ensure that all enrollment records are reported correctly and timely.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-011: Outstanding Student Refund Checks
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Number and Year: P063P211695(March 25, 2022- August 31, 2028),
P063P221695(March 25, 2022- August 31, 2028),
P268K221695(March 25, 2022- August 31, 2028),
P268K231695(March 25, 2022- August 31, 2028),
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: Alcorn State University (ASU)
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(h)(2) 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: Student checks totaling $234 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of June 30, 2023.
Questioned Costs: None.
Context: This condition occurred for all 3 Title IV checks outstanding at year-end.
Cause: Employee turnover in the finance area caused a lapse in the development and implementation of policies and procedures following the previous finding related to outstanding checks.
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: 2022-007
Recommendation: CLA recommends the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education by no later than 240 days.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-011: Outstanding Student Refund Checks
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Number and Year: P063P211695(March 25, 2022- August 31, 2028),
P063P221695(March 25, 2022- August 31, 2028),
P268K221695(March 25, 2022- August 31, 2028),
P268K231695(March 25, 2022- August 31, 2028),
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: Alcorn State University (ASU)
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(h)(2) 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: Student checks totaling $234 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of June 30, 2023.
Questioned Costs: None.
Context: This condition occurred for all 3 Title IV checks outstanding at year-end.
Cause: Employee turnover in the finance area caused a lapse in the development and implementation of policies and procedures following the previous finding related to outstanding checks.
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: 2022-007
Recommendation: CLA recommends the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education by no later than 240 days.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-011: Outstanding Student Refund Checks
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Number and Year: P063P211695(March 25, 2022- August 31, 2028),
P063P221695(March 25, 2022- August 31, 2028),
P268K221695(March 25, 2022- August 31, 2028),
P268K231695(March 25, 2022- August 31, 2028),
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: Alcorn State University (ASU)
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(h)(2) 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: Student checks totaling $234 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of June 30, 2023.
Questioned Costs: None.
Context: This condition occurred for all 3 Title IV checks outstanding at year-end.
Cause: Employee turnover in the finance area caused a lapse in the development and implementation of policies and procedures following the previous finding related to outstanding checks.
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: 2022-007
Recommendation: CLA recommends the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education by no later than 240 days.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-011: Outstanding Student Refund Checks
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Number and Year: P063P211695(March 25, 2022- August 31, 2028),
P063P221695(March 25, 2022- August 31, 2028),
P268K221695(March 25, 2022- August 31, 2028),
P268K231695(March 25, 2022- August 31, 2028),
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: Alcorn State University (ASU)
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(h)(2) 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: Student checks totaling $234 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of June 30, 2023.
Questioned Costs: None.
Context: This condition occurred for all 3 Title IV checks outstanding at year-end.
Cause: Employee turnover in the finance area caused a lapse in the development and implementation of policies and procedures following the previous finding related to outstanding checks.
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: 2022-007
Recommendation: CLA recommends the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education by no later than 240 days.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-012: Direct Loan Exit Counseling
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster
Assistance Listing Number: 84.268
Award Number and Year: P268K231706(March 25, 2022- August 31, 2028)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: Jackson State University (JSU)
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 – All schools that participate in the Federal Student Aid programs are required to provide exit counseling to student borrowers who withdraw from school. This requirement is outlined in 34 CFR section 685.304. Specifically, exit counseling must be provided within 30 days after the school learns that the student borrower has withdrawn from school.
Condition: Exit counseling was not sent to borrowers who graduated or withdrew during the 22-23 school year.
Questioned Costs: None
Context: This condition occurred for 3 out of 8 JSU students selected for testing
Cause: A change in personnel during the 22-23 academic year caused this process to not be completed timely.
Effect: Students are not receiving the required loan exit counseling which may contribute to a higher default rate.
Repeat Finding: No
Recommendation: We recommend that the entity review its policies and procedures to ensure that all exit counseling notifications are sent.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-013: The Gramm-Leach-Bliley Act (GLBA) Compliance
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Number and Year: P007A222226(March 25, 2022- August 31, 2028),
P033P212226(March 25, 2022- August 31, 2028),
P063P211695(March 25, 2022- August 31, 2028),
P268K221695(March 25, 2022- August 31, 2028),
P033A212226(March 25, 2022- August 31, 2028),
P007A222257(March 25, 2022- August 31, 2028),
P033A222257(March 25, 2022- August 31, 2028),
P063P220252(March 23, 2022- August 31, 2028),
P268K230252(March 25, 2022- August 31, 2028),
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution(s): Alcorn State University (ASU) and Mississippi Valley State University (MVSU)
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 Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to perform Safeguards that address the required areas noted in GLBA 16 CFR 314.4, which are (1) the Institution designated a Qualified Individual responsible for implementing and monitoring the Institution’s information security program and (2) the Institution’s written information security program addresses the remaining six elements.
Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs.
Questioned Costs: None
Context: This condition occurred for the institutions as follows:
• For ASU, the institution’s policy did not identify a qualified individual (such as a CIO, ISO, CISO) responsible for the Information Security program. In addition, the written information security program (WISP) did not address certain required elements.
• For MVSU, the institution’s WISP has not been approved by the individual leading the information security program. In addition, the WISP did not address certain required elements.
Cause:
ASU
At the time of the audit, the University’s security program had not matured to the extent that published policies and procedures covered the items referred to in this finding.
MVSU
The University experienced turnover in the department responsible for this process.
Effect: The student personal information could be vulnerable.
Repeat Finding: 2022-008
Recommendation: CLA recommend that the University engage a third party or perform the risk assessment for the two areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks which are included in the Written Information Security Program.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-013: The Gramm-Leach-Bliley Act (GLBA) Compliance
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Number and Year: P007A222226(March 25, 2022- August 31, 2028),
P033P212226(March 25, 2022- August 31, 2028),
P063P211695(March 25, 2022- August 31, 2028),
P268K221695(March 25, 2022- August 31, 2028),
P033A212226(March 25, 2022- August 31, 2028),
P007A222257(March 25, 2022- August 31, 2028),
P033A222257(March 25, 2022- August 31, 2028),
P063P220252(March 23, 2022- August 31, 2028),
P268K230252(March 25, 2022- August 31, 2028),
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution(s): Alcorn State University (ASU) and Mississippi Valley State University (MVSU)
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 Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to perform Safeguards that address the required areas noted in GLBA 16 CFR 314.4, which are (1) the Institution designated a Qualified Individual responsible for implementing and monitoring the Institution’s information security program and (2) the Institution’s written information security program addresses the remaining six elements.
Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs.
Questioned Costs: None
Context: This condition occurred for the institutions as follows:
• For ASU, the institution’s policy did not identify a qualified individual (such as a CIO, ISO, CISO) responsible for the Information Security program. In addition, the written information security program (WISP) did not address certain required elements.
• For MVSU, the institution’s WISP has not been approved by the individual leading the information security program. In addition, the WISP did not address certain required elements.
Cause:
ASU
At the time of the audit, the University’s security program had not matured to the extent that published policies and procedures covered the items referred to in this finding.
MVSU
The University experienced turnover in the department responsible for this process.
Effect: The student personal information could be vulnerable.
Repeat Finding: 2022-008
Recommendation: CLA recommend that the University engage a third party or perform the risk assessment for the two areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks which are included in the Written Information Security Program.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-013: The Gramm-Leach-Bliley Act (GLBA) Compliance
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Number and Year: P007A222226(March 25, 2022- August 31, 2028),
P033P212226(March 25, 2022- August 31, 2028),
P063P211695(March 25, 2022- August 31, 2028),
P268K221695(March 25, 2022- August 31, 2028),
P033A212226(March 25, 2022- August 31, 2028),
P007A222257(March 25, 2022- August 31, 2028),
P033A222257(March 25, 2022- August 31, 2028),
P063P220252(March 23, 2022- August 31, 2028),
P268K230252(March 25, 2022- August 31, 2028),
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution(s): Alcorn State University (ASU) and Mississippi Valley State University (MVSU)
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 Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to perform Safeguards that address the required areas noted in GLBA 16 CFR 314.4, which are (1) the Institution designated a Qualified Individual responsible for implementing and monitoring the Institution’s information security program and (2) the Institution’s written information security program addresses the remaining six elements.
Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs.
Questioned Costs: None
Context: This condition occurred for the institutions as follows:
• For ASU, the institution’s policy did not identify a qualified individual (such as a CIO, ISO, CISO) responsible for the Information Security program. In addition, the written information security program (WISP) did not address certain required elements.
• For MVSU, the institution’s WISP has not been approved by the individual leading the information security program. In addition, the WISP did not address certain required elements.
Cause:
ASU
At the time of the audit, the University’s security program had not matured to the extent that published policies and procedures covered the items referred to in this finding.
MVSU
The University experienced turnover in the department responsible for this process.
Effect: The student personal information could be vulnerable.
Repeat Finding: 2022-008
Recommendation: CLA recommend that the University engage a third party or perform the risk assessment for the two areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks which are included in the Written Information Security Program.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-013: The Gramm-Leach-Bliley Act (GLBA) Compliance
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Number and Year: P007A222226(March 25, 2022- August 31, 2028),
P033P212226(March 25, 2022- August 31, 2028),
P063P211695(March 25, 2022- August 31, 2028),
P268K221695(March 25, 2022- August 31, 2028),
P033A212226(March 25, 2022- August 31, 2028),
P007A222257(March 25, 2022- August 31, 2028),
P033A222257(March 25, 2022- August 31, 2028),
P063P220252(March 23, 2022- August 31, 2028),
P268K230252(March 25, 2022- August 31, 2028),
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution(s): Alcorn State University (ASU) and Mississippi Valley State University (MVSU)
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 Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to perform Safeguards that address the required areas noted in GLBA 16 CFR 314.4, which are (1) the Institution designated a Qualified Individual responsible for implementing and monitoring the Institution’s information security program and (2) the Institution’s written information security program addresses the remaining six elements.
Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs.
Questioned Costs: None
Context: This condition occurred for the institutions as follows:
• For ASU, the institution’s policy did not identify a qualified individual (such as a CIO, ISO, CISO) responsible for the Information Security program. In addition, the written information security program (WISP) did not address certain required elements.
• For MVSU, the institution’s WISP has not been approved by the individual leading the information security program. In addition, the WISP did not address certain required elements.
Cause:
ASU
At the time of the audit, the University’s security program had not matured to the extent that published policies and procedures covered the items referred to in this finding.
MVSU
The University experienced turnover in the department responsible for this process.
Effect: The student personal information could be vulnerable.
Repeat Finding: 2022-008
Recommendation: CLA recommend that the University engage a third party or perform the risk assessment for the two areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks which are included in the Written Information Security Program.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-014: Return of Title IV Funds
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster
Assistance Listing Number: 84.063 and 84.268
Award Number and Year: P063P221706 (March 25, 2022- August 31, 2028),
P268K231706 (March 25, 2022- August 31, 2028)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: Jackson State University (JSU)
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 – When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date (34CFR section 668.22).
Condition: The return of funds was calculated improperly.
Questioned Costs: None
Context: For 1 out of 8 JSU students, the institution made an error in the R2T4 calculation. The school incorrectly deemed the student to have withdrawn after the 60% point of the semester, when in fact the student withdrew before the 60% point resulting in the institution needing to return Pell funds.
Cause: A change in personnel during the 22-23 academic year caused this process to not be completed timely. The counselor over this process resigned during the summer semester and the unofficial R2T4s were not completed as efficiently for that short period.
Effect: The students’ return of funds calculation was not done correctly and the return of funds back to the federal government was for the incorrect amount.
Repeat Finding: No
Recommendation: CLA recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct amount of term days and are accurately completed.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-014: Return of Title IV Funds
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster
Assistance Listing Number: 84.063 and 84.268
Award Number and Year: P063P221706 (March 25, 2022- August 31, 2028),
P268K231706 (March 25, 2022- August 31, 2028)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: Jackson State University (JSU)
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 – When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date (34CFR section 668.22).
Condition: The return of funds was calculated improperly.
Questioned Costs: None
Context: For 1 out of 8 JSU students, the institution made an error in the R2T4 calculation. The school incorrectly deemed the student to have withdrawn after the 60% point of the semester, when in fact the student withdrew before the 60% point resulting in the institution needing to return Pell funds.
Cause: A change in personnel during the 22-23 academic year caused this process to not be completed timely. The counselor over this process resigned during the summer semester and the unofficial R2T4s were not completed as efficiently for that short period.
Effect: The students’ return of funds calculation was not done correctly and the return of funds back to the federal government was for the incorrect amount.
Repeat Finding: No
Recommendation: CLA recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct amount of term days and are accurately completed.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-015: SEFA Reporting of Expenditures
Federal Agency: Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425F
Award Number and Year: P425F201683 (May 6, 2020 – June 30, 2023)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Applicable Institution: Mississippi University for Women (MUW)
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 drew funds in fiscal year 2022 for amounts earned in fiscal year 2022 but were not reported on the SEFA until fiscal year 2023.
Questioned Costs: None
Context: The University’s calculation of lost revenue was performed in fiscal year 2022 and funds were drawn at that time the charge to the grant in the general ledger did not occur until fiscal year 2023 resulting in an error to the SEFA.
Cause: A journal entry for the lost revenue calculation was not entered in FY22 when the money was drawn down.
Effect: The SEFA does not reflect the accurate amount of federal expenditures for the year.
Repeat Finding: No
Recommendation: We recommend the institution review and revise its current reporting procedures and review requirements to ensure that federal expenditures are properly identified and classified.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-016: Suspension and Debarment
Federal Agency: Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425F
Award Number and Year: P425F201683 (May 6, 2020 – June 30, 2023)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Applicable Institution: Mississippi University for Women (MUW)
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: We noted that the University does not have policies or procedures in place for compliance with suspension and debarment requirements.
Questioned Costs: None
Context: The University does not have a policy or procedure to verify a vendor’s suspension and debarment status.
Cause: Due to personnel changes and undocumented policies and procedures, the individuals making purchases were not aware of the requirement.
Effect: The University is not in compliance with suspension and debarment requirements for its federal programs.
Repeat Finding: No
Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in contract with vendors that they are not suspended or debarred.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-017: Quarterly and Annual HEERF Reporting
Federal Agency: U.S. Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F, 84.425J
Award Number and Year: P425F201683 (May 6, 2020 – June 30, 2023)
P425E200639 (April 21, 2020 – June 30, 2023)
P425F202078 (May 7, 2020 – June 30, 2023)
P425J200085 (May 1, 2020 – June 30, 2023)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution(s): Mississippi Valley State University (MVSU), Mississippi University for Women (MUW)
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 Federal Register Notice of Public Posting Requirement of Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees dated 5/13/21, institutions are required to submit (in a time and manner required by the Secretary) a report to the Secretary describing the use of funds distributed from the HEERF. The Department further requires institutions to post all quarterly reports to their website in a publicly accessible location. According to the OPE Reporting and Data Collection website, quarterly reports should appear on separate documents by quarter and should not be cumulative.
All institutions of higher education that received HEERF grant awards are required to submit a HEERF Annual Report. The HEERF Annual Report by the March 24, 2023 deadline.
Condition:
Mississippi Valley State University (MVSU)
Quarterly Reporting: MVSU could not provide evidence of review over the quarterly report submitted for the quarter ended June 30, 2022.
Annual Reporting: MVSU could not provide evidence of review over the annual report submitted March 25, 2023.
Mississippi University for Women (MUW)
Annual Reporting: MUW could not provide evidence of review over the annual report submitted March 24, 2023.
Quarterly Reporting: MUW submitted an out-of-date quarterly form for the quarter ending September 30, 2022. In addition, MUW could not provide evidence of review over the quarterly report submitted for the quarter ended September 30, 2022.
Questioned Costs: None.
Context:
Mississippi Valley State University (MVSU)
Quarterly Reporting: MVSU could not provide evidence of review over the quarterly report submitted for the quarter ended June 30, 2022.
Annual Reporting: MVSU could not provide evidence of review over the annual report submitted March 25, 2023. In addition, the report was submitted after the deadline.
Mississippi University for Women (MUW)
Annual Reporting: MUW could not provide evidence of review over the annual report submitted March 24, 2023.
Quarterly Reporting: MUW submitted an out of date quarterly form for the quarter ending September 30, 2022. In addition, MUW could not provide evidence of review over the quarterly report submitted for the quarter ended September 30, 2022.
Cause:
MVSU
Lack of proper internal controls to ensure that all reports are reviewed prior to posting quarterly reports to the University’s website and submitting annual performance reports. Previously, the State Director was not fully aware that reports must be reviewed prior to posting/submission. Effective July 10, 2023, quarterly reports are reviewed by the Director of Accounting and Vice President for Business and Finance prior to posting. The same procedure will apply to the annual performance report. The annual performance report provided for review was submitted after the deadline with no evidence that the report was submitted by the deadline.
MUW
Annual Reporting: All reports were reviewed prior to submission; however, there was no documented evidence that the review occurred.
Quarterly reporting: The grant PI failed to communicate to the Grant Accountant that one of the reporting forms had been revised.
Effect: Reports submitted are not in compliance with the reporting and information-sharing requirements established by the Department of Education.
Repeat Finding: 2022-005
Recommendation: We recommend the institutions strengthen their understanding of the reporting requirements established by the grant and ensure supporting documentation is maintained to substantiate amounts reported.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-017: Quarterly and Annual HEERF Reporting
Federal Agency: U.S. Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F, 84.425J
Award Number and Year: P425F201683 (May 6, 2020 – June 30, 2023)
P425E200639 (April 21, 2020 – June 30, 2023)
P425F202078 (May 7, 2020 – June 30, 2023)
P425J200085 (May 1, 2020 – June 30, 2023)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution(s): Mississippi Valley State University (MVSU), Mississippi University for Women (MUW)
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 Federal Register Notice of Public Posting Requirement of Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees dated 5/13/21, institutions are required to submit (in a time and manner required by the Secretary) a report to the Secretary describing the use of funds distributed from the HEERF. The Department further requires institutions to post all quarterly reports to their website in a publicly accessible location. According to the OPE Reporting and Data Collection website, quarterly reports should appear on separate documents by quarter and should not be cumulative.
All institutions of higher education that received HEERF grant awards are required to submit a HEERF Annual Report. The HEERF Annual Report by the March 24, 2023 deadline.
Condition:
Mississippi Valley State University (MVSU)
Quarterly Reporting: MVSU could not provide evidence of review over the quarterly report submitted for the quarter ended June 30, 2022.
Annual Reporting: MVSU could not provide evidence of review over the annual report submitted March 25, 2023.
Mississippi University for Women (MUW)
Annual Reporting: MUW could not provide evidence of review over the annual report submitted March 24, 2023.
Quarterly Reporting: MUW submitted an out-of-date quarterly form for the quarter ending September 30, 2022. In addition, MUW could not provide evidence of review over the quarterly report submitted for the quarter ended September 30, 2022.
Questioned Costs: None.
Context:
Mississippi Valley State University (MVSU)
Quarterly Reporting: MVSU could not provide evidence of review over the quarterly report submitted for the quarter ended June 30, 2022.
Annual Reporting: MVSU could not provide evidence of review over the annual report submitted March 25, 2023. In addition, the report was submitted after the deadline.
Mississippi University for Women (MUW)
Annual Reporting: MUW could not provide evidence of review over the annual report submitted March 24, 2023.
Quarterly Reporting: MUW submitted an out of date quarterly form for the quarter ending September 30, 2022. In addition, MUW could not provide evidence of review over the quarterly report submitted for the quarter ended September 30, 2022.
Cause:
MVSU
Lack of proper internal controls to ensure that all reports are reviewed prior to posting quarterly reports to the University’s website and submitting annual performance reports. Previously, the State Director was not fully aware that reports must be reviewed prior to posting/submission. Effective July 10, 2023, quarterly reports are reviewed by the Director of Accounting and Vice President for Business and Finance prior to posting. The same procedure will apply to the annual performance report. The annual performance report provided for review was submitted after the deadline with no evidence that the report was submitted by the deadline.
MUW
Annual Reporting: All reports were reviewed prior to submission; however, there was no documented evidence that the review occurred.
Quarterly reporting: The grant PI failed to communicate to the Grant Accountant that one of the reporting forms had been revised.
Effect: Reports submitted are not in compliance with the reporting and information-sharing requirements established by the Department of Education.
Repeat Finding: 2022-005
Recommendation: We recommend the institutions strengthen their understanding of the reporting requirements established by the grant and ensure supporting documentation is maintained to substantiate amounts reported.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-017: Quarterly and Annual HEERF Reporting
Federal Agency: U.S. Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F, 84.425J
Award Number and Year: P425F201683 (May 6, 2020 – June 30, 2023)
P425E200639 (April 21, 2020 – June 30, 2023)
P425F202078 (May 7, 2020 – June 30, 2023)
P425J200085 (May 1, 2020 – June 30, 2023)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution(s): Mississippi Valley State University (MVSU), Mississippi University for Women (MUW)
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 Federal Register Notice of Public Posting Requirement of Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees dated 5/13/21, institutions are required to submit (in a time and manner required by the Secretary) a report to the Secretary describing the use of funds distributed from the HEERF. The Department further requires institutions to post all quarterly reports to their website in a publicly accessible location. According to the OPE Reporting and Data Collection website, quarterly reports should appear on separate documents by quarter and should not be cumulative.
All institutions of higher education that received HEERF grant awards are required to submit a HEERF Annual Report. The HEERF Annual Report by the March 24, 2023 deadline.
Condition:
Mississippi Valley State University (MVSU)
Quarterly Reporting: MVSU could not provide evidence of review over the quarterly report submitted for the quarter ended June 30, 2022.
Annual Reporting: MVSU could not provide evidence of review over the annual report submitted March 25, 2023.
Mississippi University for Women (MUW)
Annual Reporting: MUW could not provide evidence of review over the annual report submitted March 24, 2023.
Quarterly Reporting: MUW submitted an out-of-date quarterly form for the quarter ending September 30, 2022. In addition, MUW could not provide evidence of review over the quarterly report submitted for the quarter ended September 30, 2022.
Questioned Costs: None.
Context:
Mississippi Valley State University (MVSU)
Quarterly Reporting: MVSU could not provide evidence of review over the quarterly report submitted for the quarter ended June 30, 2022.
Annual Reporting: MVSU could not provide evidence of review over the annual report submitted March 25, 2023. In addition, the report was submitted after the deadline.
Mississippi University for Women (MUW)
Annual Reporting: MUW could not provide evidence of review over the annual report submitted March 24, 2023.
Quarterly Reporting: MUW submitted an out of date quarterly form for the quarter ending September 30, 2022. In addition, MUW could not provide evidence of review over the quarterly report submitted for the quarter ended September 30, 2022.
Cause:
MVSU
Lack of proper internal controls to ensure that all reports are reviewed prior to posting quarterly reports to the University’s website and submitting annual performance reports. Previously, the State Director was not fully aware that reports must be reviewed prior to posting/submission. Effective July 10, 2023, quarterly reports are reviewed by the Director of Accounting and Vice President for Business and Finance prior to posting. The same procedure will apply to the annual performance report. The annual performance report provided for review was submitted after the deadline with no evidence that the report was submitted by the deadline.
MUW
Annual Reporting: All reports were reviewed prior to submission; however, there was no documented evidence that the review occurred.
Quarterly reporting: The grant PI failed to communicate to the Grant Accountant that one of the reporting forms had been revised.
Effect: Reports submitted are not in compliance with the reporting and information-sharing requirements established by the Department of Education.
Repeat Finding: 2022-005
Recommendation: We recommend the institutions strengthen their understanding of the reporting requirements established by the grant and ensure supporting documentation is maintained to substantiate amounts reported.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-018: Equipment Records
Federal Agency: Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425C
Award Number and Year: GEER (November 8, 2021 – September 30, 2023)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: Jackson State University (JSU)
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 – Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property (2 CFR section 200.313(d)(1)).
Condition: Property records did not contain accurate information related to certain equipment purchases.
Questioned Costs: None
Context: We noted the following discrepancies with the property records of the University:
• For 2 out of 8 equipment assets selected for testing, the cost of the property per the invoice did not agree to the cost included on the property record.
• For 1 out of 8 equipment assets selected for testing, the description of the property on the property record was inaccurate.
• For 1 out of 8 equipment assets selected for testing, the serial number included on the property record did not match the serial number on the equipment.
Cause: Personnel made inaccurate entries on the front end of receiving and tagging the equipment.
Effect: The University is not in compliance with equipment requirements for its federal programs. As a result, equipment may not be properly accounted for and inventoried.
Repeat Finding: No
Recommendation: We recommend the institution strengthen its controls and processes related to capturing information relating to equipment purchases and ensure that property records properly reflect the required information.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-001: SEFA Reporting – R&D Classification
Federal Agency: Department of Health and Human Services
Federal Program Title: Medical Student Education Program, Prevention of Disease, Disability, and Death by Infection Diseases, and Postdoctoral Training in General Dentistry
Assistance Listing Number: 93.680, 93.084, 93.059
Award Number and Year: T99HP39200 (July 1, 2020 – June 30, 2024), NU2GGH002319 (September 30, 2020 – September 29, 2024), D88HP375559200 (July 1, 2020 – June 30, 2024)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters
Applicable Institution: University of Mississippi Medical Center (UMMC)
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 – 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with §200.502.
Condition: The Schedule of Expenditures of Federal Awards (SEFA) contained errors and incorrect information which affected the major program determination.
Questioned Costs: None noted as the reporting requirement does not affect the allowability of costs and/or activities.
Context: The following SEFA errors were noted:
• Amounts provided by UMMC incorrectly reported $4,558,549 in the Research & Development Cluster that should have been classified as expenditures for the Medical Student Education program (Assistance Listing 93.680).
• Amounts provided by UMMC incorrectly reported $622,758 in the Research & Development Cluster that should have been classified as expenditures for the Prevention of Disease, Disability, and Death by Infection Diseases Program (Assistance Listing 93.084).
• Amounts provided by UMMC incorrectly reported $383,695 in the Research & Development Cluster that should have been classified as expenditures for the Postdoctoral Training in General Dentistry Program (Assistance Listing 93.059).
Cause: Awards were incorrectly coded as Research & Development during the award set-up process.
Effect: The SEFA was not prepared in accordance with OMB requirements which affects the major program risk assessment.
Repeat Finding: 2022-002
Recommendation: We recommend the institution review and revise its current reporting procedures and review requirements to ensure that federal expenditures are properly identified and classified.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-001: SEFA Reporting – R&D Classification
Federal Agency: Department of Health and Human Services
Federal Program Title: Medical Student Education Program, Prevention of Disease, Disability, and Death by Infection Diseases, and Postdoctoral Training in General Dentistry
Assistance Listing Number: 93.680, 93.084, 93.059
Award Number and Year: T99HP39200 (July 1, 2020 – June 30, 2024), NU2GGH002319 (September 30, 2020 – September 29, 2024), D88HP375559200 (July 1, 2020 – June 30, 2024)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters
Applicable Institution: University of Mississippi Medical Center (UMMC)
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 – 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with §200.502.
Condition: The Schedule of Expenditures of Federal Awards (SEFA) contained errors and incorrect information which affected the major program determination.
Questioned Costs: None noted as the reporting requirement does not affect the allowability of costs and/or activities.
Context: The following SEFA errors were noted:
• Amounts provided by UMMC incorrectly reported $4,558,549 in the Research & Development Cluster that should have been classified as expenditures for the Medical Student Education program (Assistance Listing 93.680).
• Amounts provided by UMMC incorrectly reported $622,758 in the Research & Development Cluster that should have been classified as expenditures for the Prevention of Disease, Disability, and Death by Infection Diseases Program (Assistance Listing 93.084).
• Amounts provided by UMMC incorrectly reported $383,695 in the Research & Development Cluster that should have been classified as expenditures for the Postdoctoral Training in General Dentistry Program (Assistance Listing 93.059).
Cause: Awards were incorrectly coded as Research & Development during the award set-up process.
Effect: The SEFA was not prepared in accordance with OMB requirements which affects the major program risk assessment.
Repeat Finding: 2022-002
Recommendation: We recommend the institution review and revise its current reporting procedures and review requirements to ensure that federal expenditures are properly identified and classified.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-001: SEFA Reporting – R&D Classification
Federal Agency: Department of Health and Human Services
Federal Program Title: Medical Student Education Program, Prevention of Disease, Disability, and Death by Infection Diseases, and Postdoctoral Training in General Dentistry
Assistance Listing Number: 93.680, 93.084, 93.059
Award Number and Year: T99HP39200 (July 1, 2020 – June 30, 2024), NU2GGH002319 (September 30, 2020 – September 29, 2024), D88HP375559200 (July 1, 2020 – June 30, 2024)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters
Applicable Institution: University of Mississippi Medical Center (UMMC)
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 – 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with §200.502.
Condition: The Schedule of Expenditures of Federal Awards (SEFA) contained errors and incorrect information which affected the major program determination.
Questioned Costs: None noted as the reporting requirement does not affect the allowability of costs and/or activities.
Context: The following SEFA errors were noted:
• Amounts provided by UMMC incorrectly reported $4,558,549 in the Research & Development Cluster that should have been classified as expenditures for the Medical Student Education program (Assistance Listing 93.680).
• Amounts provided by UMMC incorrectly reported $622,758 in the Research & Development Cluster that should have been classified as expenditures for the Prevention of Disease, Disability, and Death by Infection Diseases Program (Assistance Listing 93.084).
• Amounts provided by UMMC incorrectly reported $383,695 in the Research & Development Cluster that should have been classified as expenditures for the Postdoctoral Training in General Dentistry Program (Assistance Listing 93.059).
Cause: Awards were incorrectly coded as Research & Development during the award set-up process.
Effect: The SEFA was not prepared in accordance with OMB requirements which affects the major program risk assessment.
Repeat Finding: 2022-002
Recommendation: We recommend the institution review and revise its current reporting procedures and review requirements to ensure that federal expenditures are properly identified and classified.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-002: SEFA Reporting- Incorrect Assistance Listing Numbers, Non-Federal Amounts on SEFA
Federal Agency: Department of Education
Federal Program Title: Title I, Special Education Grants to States, Career and Technical Education
Assistance Listing Number: 84.010, 84.027, 84.048
Award Number and Year: VS010A0180024 (July 1, 2020 – June 30, 2023), H027A190108 (July 1, 2020 – June 30, 2023), V048A190024 (July 1, 2020 – June 30, 2023)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters
Applicable Institution: Mississippi State University (MSU)
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 – 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with §200.502.
Condition:
The Schedule of Expenditures of Federal Awards (SEFA) contained errors and incorrect information which affected the major program determination.
Questioned Costs: None noted as the reporting requirement does not affect the allowability of costs and/or activities.
Context:
The following SEFA errors were noted:
• Amounts provided by MSU incorrectly reported $371,067 in the Title I Program (Assistance Listing 84.010) that should have been reported in Special Education Grants to States (Assistance Listing Number 84.027).
• Amounts provided by MSU incorrectly reported $902,101 in the Title I Program (Assistance Listing 84.010) that should have been reported in Career and Technical Education (Assistance Listing Number 84.048).
• Amounts provided by MSU incorrectly reported $2,011,409 in the Title I Program (Assistance Listing 84.010) that were State Grants and not reportable on the SEFA.
Cause: Mississippi State University did not have a process in place for awards that includes multiple ALNs and sources of funding.
Effect: The SEFA was not prepared in accordance with OMB requirements which affects the major program risk assessment.
Repeat Finding: 2022-002
Recommendation: We recommend the institution review and revise its current reporting procedures and review requirements to ensure that federal expenditures are properly identified and classified.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-002: SEFA Reporting- Incorrect Assistance Listing Numbers, Non-Federal Amounts on SEFA
Federal Agency: Department of Education
Federal Program Title: Title I, Special Education Grants to States, Career and Technical Education
Assistance Listing Number: 84.010, 84.027, 84.048
Award Number and Year: VS010A0180024 (July 1, 2020 – June 30, 2023), H027A190108 (July 1, 2020 – June 30, 2023), V048A190024 (July 1, 2020 – June 30, 2023)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters
Applicable Institution: Mississippi State University (MSU)
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 – 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with §200.502.
Condition:
The Schedule of Expenditures of Federal Awards (SEFA) contained errors and incorrect information which affected the major program determination.
Questioned Costs: None noted as the reporting requirement does not affect the allowability of costs and/or activities.
Context:
The following SEFA errors were noted:
• Amounts provided by MSU incorrectly reported $371,067 in the Title I Program (Assistance Listing 84.010) that should have been reported in Special Education Grants to States (Assistance Listing Number 84.027).
• Amounts provided by MSU incorrectly reported $902,101 in the Title I Program (Assistance Listing 84.010) that should have been reported in Career and Technical Education (Assistance Listing Number 84.048).
• Amounts provided by MSU incorrectly reported $2,011,409 in the Title I Program (Assistance Listing 84.010) that were State Grants and not reportable on the SEFA.
Cause: Mississippi State University did not have a process in place for awards that includes multiple ALNs and sources of funding.
Effect: The SEFA was not prepared in accordance with OMB requirements which affects the major program risk assessment.
Repeat Finding: 2022-002
Recommendation: We recommend the institution review and revise its current reporting procedures and review requirements to ensure that federal expenditures are properly identified and classified.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-002: SEFA Reporting- Incorrect Assistance Listing Numbers, Non-Federal Amounts on SEFA
Federal Agency: Department of Education
Federal Program Title: Title I, Special Education Grants to States, Career and Technical Education
Assistance Listing Number: 84.010, 84.027, 84.048
Award Number and Year: VS010A0180024 (July 1, 2020 – June 30, 2023), H027A190108 (July 1, 2020 – June 30, 2023), V048A190024 (July 1, 2020 – June 30, 2023)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters
Applicable Institution: Mississippi State University (MSU)
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 – 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with §200.502.
Condition:
The Schedule of Expenditures of Federal Awards (SEFA) contained errors and incorrect information which affected the major program determination.
Questioned Costs: None noted as the reporting requirement does not affect the allowability of costs and/or activities.
Context:
The following SEFA errors were noted:
• Amounts provided by MSU incorrectly reported $371,067 in the Title I Program (Assistance Listing 84.010) that should have been reported in Special Education Grants to States (Assistance Listing Number 84.027).
• Amounts provided by MSU incorrectly reported $902,101 in the Title I Program (Assistance Listing 84.010) that should have been reported in Career and Technical Education (Assistance Listing Number 84.048).
• Amounts provided by MSU incorrectly reported $2,011,409 in the Title I Program (Assistance Listing 84.010) that were State Grants and not reportable on the SEFA.
Cause: Mississippi State University did not have a process in place for awards that includes multiple ALNs and sources of funding.
Effect: The SEFA was not prepared in accordance with OMB requirements which affects the major program risk assessment.
Repeat Finding: 2022-002
Recommendation: We recommend the institution review and revise its current reporting procedures and review requirements to ensure that federal expenditures are properly identified and classified.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-003: SEFA Reporting –Expenditures Recorded in the Incorrect Period
Federal Agency: Department of Health and Human Services
Federal Program Title: Telehealth Center of Excellence
Assistance Listing Number: 93.211
Award Number and Year: U6631459 (September 1, 2021 – September 29, 2026)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: University of Mississippi Medical Center (UMMC)
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 – 2 CFR, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, §200.510(b) requires that auditees prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with §200.502.
Condition: Schedule of Expenditures of Federal Awards (SEFA) contained salary expenses of $1,175 that were not allowable and should have been removed from the SEFA.
Questioned Costs: None.
Context: For 1 out of 60 payroll expenditures selected for testing, the amount was not allowable and should not have been charged to the grant.
Cause: Transfer of project expenditures occurred late and resulted in effort not being certified for salary amount in question. As a result, the salary was not reported to the sponsor via an invoice or financial report. However, the department did not remove the salary expenditure from the project in a timely manner.
Effect: The SEFA does not reflect the accurate amount of federal expenditures for the year.
Repeat Finding: 2022-002
Recommendation: We recommend the institutions review and revise its current reporting procedures and review requirements to ensure that federal expenditures are properly identified, recorded, and classified in the accurate year.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004: Procurement
Federal Agency: Department of Education, United States Department of Agriculture, Federal Aviation Administration
Federal Program Title: GEAR UP Mississippi, Improving Efficiency in Catfish Aquaculture, ASSURE
Assistance Listing Number: 84.334, 10.001, 20.109
Award Number and Year: P334S190003 (August 23, 2019 – August 22, 2026), 58-6066-0-031 (April 1, 2020 – March 31, 2025), 15-C-UAS-MSU-A (May 8, 2015 – May 7, 2025)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: Mississippi State University (MSU)
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 200.320: Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following:
(A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit;
(B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or,
(C) For public institutions, a higher threshold consistent with State law.
Micro-purchase thresholds higher than $50,000 must be approved by the cognizant agency for indirect costs. The non-federal entity must submit a request with the requirements included in paragraph (a)(1)(iv) of this section. The increased threshold is valid until there is a change in status in which the justification was approved.
Condition: MSU established a micro-purchase threshold of $75,000 for contracted services and was not able to provide documentation to support this threshold.
Questioned Costs: None.
Context: For 3 out of the 7 contracts tested, the dollar amount of the contract was above the Federally established Micro-Threshold of $10,000, and price or rate quotations were not obtained providing for full and open competition.
Cause: Mississippi State University’s Procurement and Contracts Manual was updated in August 2022; however, the section addressing federal requirements was not properly addressed.
Effect: The institution procured services with a policy not meeting Federal requirements.
Repeat Finding: No
Recommendation: We recommend the institution review and revise their current procurement policy and review requirements to ensure that their policy is meeting Federal requirements.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004: Procurement
Federal Agency: Department of Education, United States Department of Agriculture, Federal Aviation Administration
Federal Program Title: GEAR UP Mississippi, Improving Efficiency in Catfish Aquaculture, ASSURE
Assistance Listing Number: 84.334, 10.001, 20.109
Award Number and Year: P334S190003 (August 23, 2019 – August 22, 2026), 58-6066-0-031 (April 1, 2020 – March 31, 2025), 15-C-UAS-MSU-A (May 8, 2015 – May 7, 2025)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: Mississippi State University (MSU)
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 200.320: Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following:
(A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit;
(B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or,
(C) For public institutions, a higher threshold consistent with State law.
Micro-purchase thresholds higher than $50,000 must be approved by the cognizant agency for indirect costs. The non-federal entity must submit a request with the requirements included in paragraph (a)(1)(iv) of this section. The increased threshold is valid until there is a change in status in which the justification was approved.
Condition: MSU established a micro-purchase threshold of $75,000 for contracted services and was not able to provide documentation to support this threshold.
Questioned Costs: None.
Context: For 3 out of the 7 contracts tested, the dollar amount of the contract was above the Federally established Micro-Threshold of $10,000, and price or rate quotations were not obtained providing for full and open competition.
Cause: Mississippi State University’s Procurement and Contracts Manual was updated in August 2022; however, the section addressing federal requirements was not properly addressed.
Effect: The institution procured services with a policy not meeting Federal requirements.
Repeat Finding: No
Recommendation: We recommend the institution review and revise their current procurement policy and review requirements to ensure that their policy is meeting Federal requirements.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004: Procurement
Federal Agency: Department of Education, United States Department of Agriculture, Federal Aviation Administration
Federal Program Title: GEAR UP Mississippi, Improving Efficiency in Catfish Aquaculture, ASSURE
Assistance Listing Number: 84.334, 10.001, 20.109
Award Number and Year: P334S190003 (August 23, 2019 – August 22, 2026), 58-6066-0-031 (April 1, 2020 – March 31, 2025), 15-C-UAS-MSU-A (May 8, 2015 – May 7, 2025)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: Mississippi State University (MSU)
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 200.320: Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following:
(A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit;
(B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or,
(C) For public institutions, a higher threshold consistent with State law.
Micro-purchase thresholds higher than $50,000 must be approved by the cognizant agency for indirect costs. The non-federal entity must submit a request with the requirements included in paragraph (a)(1)(iv) of this section. The increased threshold is valid until there is a change in status in which the justification was approved.
Condition: MSU established a micro-purchase threshold of $75,000 for contracted services and was not able to provide documentation to support this threshold.
Questioned Costs: None.
Context: For 3 out of the 7 contracts tested, the dollar amount of the contract was above the Federally established Micro-Threshold of $10,000, and price or rate quotations were not obtained providing for full and open competition.
Cause: Mississippi State University’s Procurement and Contracts Manual was updated in August 2022; however, the section addressing federal requirements was not properly addressed.
Effect: The institution procured services with a policy not meeting Federal requirements.
Repeat Finding: No
Recommendation: We recommend the institution review and revise their current procurement policy and review requirements to ensure that their policy is meeting Federal requirements.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-005: Indirect Costs
Federal Agency: U.S. Department of Health and Human Services
Federal Program Title: Value-Based Medical Student Education Training Program
Assistance Listing Number: 93.680
Award Number and Year: T99HP39200 (July 1, 2020 – June 30, 2024)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: University of Mississippi Medical Center (UMMC)
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. See also §200.306 Cost sharing or matching paragraph (b). (g) Be adequately documented. See also §§200.300 Statutory and national policy requirements through 200.309 Period of performance of this part.
Condition: Indirect cost expense was improperly calculated.
Questioned Costs: None
Context: This condition occurred for the one award in our population.
Cause: A transition to a new ERP system resulted in issues with calculating F&A according to our negotiated rate agreement. As a result, we recalculate F&A on each project when invoicing or reporting. This F&A entry was identified; however, it was not made timely.
Effect: Indirect costs may be incorrectly charged to the program.
Repeat Finding: No
Recommendation: We recommend the institution strengthen its internal controls to ensure that calculations are reviewed and adjusted for, if necessary, in a timely manner.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-006: Matching
Federal Agency: U.S. Department of Health and Human Services
Federal Program Title: Value-Based Medical Student Education Training Program
Assistance Listing Number: 93.680
Award Number and Year: T99HP39200 (July 1, 2020 – June 30, 2024)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Applicable Institution: University of Mississippi Medical Center (UMMC)
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: There is no review process in place to ensure matching requirements are met.
Questioned Costs: None
Context: Cost share expenditures are not being tracked separately and monitored for compliance over matching for this grant.
Cause: Required cost share was being tracked by the department in a spreadsheet rather than in Workday as required.
Effect: The match requirement may not be met.
Repeat Finding: No
Recommendation: We recommend the institution track cost share expenditures in a separate fund and perform periodic reviews to ensure the matching requirement is being met.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-007: FFATA Reporting
Federal Agency: Department of Health and Human Services
Federal Program Title: Telehealth Center of Excellence
Assistance Listing Number: 93.211
Award Number and Year: U6631459 (September 1, 2021 – September 29, 2026)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: University of Mississippi Medical Center (UMMC)
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 – Grantees must comply with the Federal Funding Accountability and Transparency Act (Act), which requires FFATA reporting to be filed annually.
Condition: FFATA reporting was not submitted timely.
Questioned Costs: None.
Context: The institution filed 2 of 2 FFATA reports selected for testing past the deadline.
Cause: The institution has experienced turnover and restructuring of the Office of Research and Sponsored Programs. As a result some routine reporting was delayed.
Effect: The institution is not able to file the reports on time which could affect future participation in the program.
Repeat Finding: No
Recommendation: We recommend the institution strengthens their understanding of the reporting requirements established by the grant and ensure reports are filed timely.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-008: Annual Performance Reporting
Federal Agency: U.S. Department of Health and Human Services
Federal Program Title: Head Start
Assistance Listing Number: 93.600
Award Number and Year: 04HE001242-01-00 (April 1, 2021 – March 31, 2023), 04CH011182-03-00 (August 1, 2019 – July 31, 2023)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: Mississippi State University (MSU)
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 – Grantees must submit an annual performance report to the U.S. Department of Health and Human Services each year of the project period using the Real Property Status Report SF-429.
Condition: The University filed the Real Property Status Report SF-429 after the deadline.
Questioned Costs: None.
Context: This condition occurred 1 of 1 reports selected for testing.
Cause: The SF 429 report was submitted late due to human error.
Effect: The institution is not able to file the reports on time which could affect future participation in the program.
Repeat Finding: No
Recommendation: We recommend the institutions review and revise its current reporting procedures and review requirements to ensure that the reports are submitted accurately and timely.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-009: Common Origination and Disbursement (COD)
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster
Assistance Listing Number: 84.268
Award Number and Year: P268K231706(March 25, 2022- August 31, 2028)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: Jackson State University (JSU)
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 – From the 2022-23 FSA Handbook: The date funds are credited to a student’s account in the institution’s general ledger or any subledger of the general ledger or paid to a student directly is the disbursement date the financial aid office reports to COD. The Common Origination and Disbursement (COD) additional requirements are:
(1) Schools must use the COD system to request and receive federal student aid funds, including Direct Loans, Pell Grants, and Campus-Based aid programs.
Schools must ensure that all disbursements of federal student aid are made through the COD system.
(2) Schools must reconcile their records with the COD system to ensure that all disbursements are accurately reported and recorded.
(3) Schools must comply with COD reporting requirements, including reporting disbursements, adjustments, and cancellations in a timely and accurate manner.
Condition: The Fall 2022 and Spring 2023 disbursement dates in COD for Parent Plus Direct Loans did not match the disbursement date on the student ledgers.
Questioned Costs: None
Context: This condition occurred for 2 out of the 8 students selected for testing.
Cause: A change in personnel during the 22-23 academic year caused this process to not be completed timely.
Effect: The COD disbursement date is reported to the Direct Loan servicers and is the time when interest begins to accrue on the loan funds. Inaccurate disbursement date reporting may lead to inaccurate student loan interest accruals.
Repeat Finding: No
Recommendation: We recommend that the entity strengthen its internal controls to ensure that all disbursement dates are reported to COD correctly.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-010: NSLDS Enrollment Reporting
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster
Assistance Listing Number: 84.063, 84.268
Award Number and Year: P063P211695 (March 25, 2022- August 31, 2028),
P268K221695 (March 25, 2022- August 31, 2028),
P063P221706 (March 25, 2022- August 31, 2028),
P268K231706 (March 25, 2022- August 31, 2028),
P063P211722 (March 25, 2022- August 31, 2028),
P063P221722 (March 25, 2022- August 31, 2028),
P268K221722 (March 25, 2022- August 31, 2028),
P268K231722 (March 25, 2022- August 31, 2028),
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution(s): Alcorn State University (ASU), Jackson State University (JSU), and University of Mississippi Medical Center (UMMC)
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 – All schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a Roster file (formerly called the Student Status Confirmation Report or SSCR). The School is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. Changes in enrollment to less than half-time, graduated, or withdrawn status must be reported within 30 days. However, if a Roster file is expected within 60 days, you may provide the data on that Roster file (34CFR section 682.610).
Condition: Enrollment dates and statuses did not agree to institution records or were not reported timely.
Questioned Costs: None
Context: Based on the audit procedures, the following discrepancies were noted:
For 1 out of 4 ASU students, the status was not certified every 60 days.
For 5 out of 8 JSU students, the effective enrollment date per institution records and NSLDS did not agree. For 1 out of 8 JSU students, the status change was not reported timely or certified within 60 days. For 1 out of 8 JSU students, NSLDS campus enrollment status has not been updated or verified.
For 2 out of 4 UMMC students, the effective enrollment date per institution records and NSLDS did not agree.
Cause:
ASU
Students were not reported in a timely manner doe to our enrollment certification officer being out of the office on extensive medical leave as well as the office being short staffed.
JSU
In some instances, the census and financial purge deadlines are extended to ensure students complete their registration requirements. When extensions are provided, the enrollment file is unable to be submitted timely and also causes delays in processing the Enrollment Error report.
UMMC
There were two students whose enrollment status changed from one term to the next but neither were captured in the enrollment file sent to the National Student Clearinghouse. Both students withdrew between enrollment submissions and early enough in the subsequent term, our clearinghouse enrollment report didn’t capture their enrollment change. Since they were not captured on our clearinghouse enrollment file, their enrollment status change (or their withdrawal from the institution) and effective date were not reported to the NSLDS.
Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period.
Repeat Finding: 2022-010
Recommendation: CLA recommends that the entity strengthen its internal controls to ensure that all enrollment records are reported correctly and timely.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-010: NSLDS Enrollment Reporting
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster
Assistance Listing Number: 84.063, 84.268
Award Number and Year: P063P211695 (March 25, 2022- August 31, 2028),
P268K221695 (March 25, 2022- August 31, 2028),
P063P221706 (March 25, 2022- August 31, 2028),
P268K231706 (March 25, 2022- August 31, 2028),
P063P211722 (March 25, 2022- August 31, 2028),
P063P221722 (March 25, 2022- August 31, 2028),
P268K221722 (March 25, 2022- August 31, 2028),
P268K231722 (March 25, 2022- August 31, 2028),
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution(s): Alcorn State University (ASU), Jackson State University (JSU), and University of Mississippi Medical Center (UMMC)
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 – All schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a Roster file (formerly called the Student Status Confirmation Report or SSCR). The School is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. Changes in enrollment to less than half-time, graduated, or withdrawn status must be reported within 30 days. However, if a Roster file is expected within 60 days, you may provide the data on that Roster file (34CFR section 682.610).
Condition: Enrollment dates and statuses did not agree to institution records or were not reported timely.
Questioned Costs: None
Context: Based on the audit procedures, the following discrepancies were noted:
For 1 out of 4 ASU students, the status was not certified every 60 days.
For 5 out of 8 JSU students, the effective enrollment date per institution records and NSLDS did not agree. For 1 out of 8 JSU students, the status change was not reported timely or certified within 60 days. For 1 out of 8 JSU students, NSLDS campus enrollment status has not been updated or verified.
For 2 out of 4 UMMC students, the effective enrollment date per institution records and NSLDS did not agree.
Cause:
ASU
Students were not reported in a timely manner doe to our enrollment certification officer being out of the office on extensive medical leave as well as the office being short staffed.
JSU
In some instances, the census and financial purge deadlines are extended to ensure students complete their registration requirements. When extensions are provided, the enrollment file is unable to be submitted timely and also causes delays in processing the Enrollment Error report.
UMMC
There were two students whose enrollment status changed from one term to the next but neither were captured in the enrollment file sent to the National Student Clearinghouse. Both students withdrew between enrollment submissions and early enough in the subsequent term, our clearinghouse enrollment report didn’t capture their enrollment change. Since they were not captured on our clearinghouse enrollment file, their enrollment status change (or their withdrawal from the institution) and effective date were not reported to the NSLDS.
Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period.
Repeat Finding: 2022-010
Recommendation: CLA recommends that the entity strengthen its internal controls to ensure that all enrollment records are reported correctly and timely.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-011: Outstanding Student Refund Checks
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Number and Year: P063P211695(March 25, 2022- August 31, 2028),
P063P221695(March 25, 2022- August 31, 2028),
P268K221695(March 25, 2022- August 31, 2028),
P268K231695(March 25, 2022- August 31, 2028),
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: Alcorn State University (ASU)
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(h)(2) 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: Student checks totaling $234 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of June 30, 2023.
Questioned Costs: None.
Context: This condition occurred for all 3 Title IV checks outstanding at year-end.
Cause: Employee turnover in the finance area caused a lapse in the development and implementation of policies and procedures following the previous finding related to outstanding checks.
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: 2022-007
Recommendation: CLA recommends the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education by no later than 240 days.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-011: Outstanding Student Refund Checks
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Number and Year: P063P211695(March 25, 2022- August 31, 2028),
P063P221695(March 25, 2022- August 31, 2028),
P268K221695(March 25, 2022- August 31, 2028),
P268K231695(March 25, 2022- August 31, 2028),
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: Alcorn State University (ASU)
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(h)(2) 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: Student checks totaling $234 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of June 30, 2023.
Questioned Costs: None.
Context: This condition occurred for all 3 Title IV checks outstanding at year-end.
Cause: Employee turnover in the finance area caused a lapse in the development and implementation of policies and procedures following the previous finding related to outstanding checks.
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: 2022-007
Recommendation: CLA recommends the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education by no later than 240 days.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-011: Outstanding Student Refund Checks
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Number and Year: P063P211695(March 25, 2022- August 31, 2028),
P063P221695(March 25, 2022- August 31, 2028),
P268K221695(March 25, 2022- August 31, 2028),
P268K231695(March 25, 2022- August 31, 2028),
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: Alcorn State University (ASU)
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(h)(2) 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: Student checks totaling $234 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of June 30, 2023.
Questioned Costs: None.
Context: This condition occurred for all 3 Title IV checks outstanding at year-end.
Cause: Employee turnover in the finance area caused a lapse in the development and implementation of policies and procedures following the previous finding related to outstanding checks.
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: 2022-007
Recommendation: CLA recommends the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education by no later than 240 days.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-011: Outstanding Student Refund Checks
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Number and Year: P063P211695(March 25, 2022- August 31, 2028),
P063P221695(March 25, 2022- August 31, 2028),
P268K221695(March 25, 2022- August 31, 2028),
P268K231695(March 25, 2022- August 31, 2028),
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: Alcorn State University (ASU)
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(h)(2) 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: Student checks totaling $234 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of June 30, 2023.
Questioned Costs: None.
Context: This condition occurred for all 3 Title IV checks outstanding at year-end.
Cause: Employee turnover in the finance area caused a lapse in the development and implementation of policies and procedures following the previous finding related to outstanding checks.
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: 2022-007
Recommendation: CLA recommends the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education by no later than 240 days.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-012: Direct Loan Exit Counseling
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster
Assistance Listing Number: 84.268
Award Number and Year: P268K231706(March 25, 2022- August 31, 2028)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: Jackson State University (JSU)
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 – All schools that participate in the Federal Student Aid programs are required to provide exit counseling to student borrowers who withdraw from school. This requirement is outlined in 34 CFR section 685.304. Specifically, exit counseling must be provided within 30 days after the school learns that the student borrower has withdrawn from school.
Condition: Exit counseling was not sent to borrowers who graduated or withdrew during the 22-23 school year.
Questioned Costs: None
Context: This condition occurred for 3 out of 8 JSU students selected for testing
Cause: A change in personnel during the 22-23 academic year caused this process to not be completed timely.
Effect: Students are not receiving the required loan exit counseling which may contribute to a higher default rate.
Repeat Finding: No
Recommendation: We recommend that the entity review its policies and procedures to ensure that all exit counseling notifications are sent.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-013: The Gramm-Leach-Bliley Act (GLBA) Compliance
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Number and Year: P007A222226(March 25, 2022- August 31, 2028),
P033P212226(March 25, 2022- August 31, 2028),
P063P211695(March 25, 2022- August 31, 2028),
P268K221695(March 25, 2022- August 31, 2028),
P033A212226(March 25, 2022- August 31, 2028),
P007A222257(March 25, 2022- August 31, 2028),
P033A222257(March 25, 2022- August 31, 2028),
P063P220252(March 23, 2022- August 31, 2028),
P268K230252(March 25, 2022- August 31, 2028),
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution(s): Alcorn State University (ASU) and Mississippi Valley State University (MVSU)
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 Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to perform Safeguards that address the required areas noted in GLBA 16 CFR 314.4, which are (1) the Institution designated a Qualified Individual responsible for implementing and monitoring the Institution’s information security program and (2) the Institution’s written information security program addresses the remaining six elements.
Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs.
Questioned Costs: None
Context: This condition occurred for the institutions as follows:
• For ASU, the institution’s policy did not identify a qualified individual (such as a CIO, ISO, CISO) responsible for the Information Security program. In addition, the written information security program (WISP) did not address certain required elements.
• For MVSU, the institution’s WISP has not been approved by the individual leading the information security program. In addition, the WISP did not address certain required elements.
Cause:
ASU
At the time of the audit, the University’s security program had not matured to the extent that published policies and procedures covered the items referred to in this finding.
MVSU
The University experienced turnover in the department responsible for this process.
Effect: The student personal information could be vulnerable.
Repeat Finding: 2022-008
Recommendation: CLA recommend that the University engage a third party or perform the risk assessment for the two areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks which are included in the Written Information Security Program.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-013: The Gramm-Leach-Bliley Act (GLBA) Compliance
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Number and Year: P007A222226(March 25, 2022- August 31, 2028),
P033P212226(March 25, 2022- August 31, 2028),
P063P211695(March 25, 2022- August 31, 2028),
P268K221695(March 25, 2022- August 31, 2028),
P033A212226(March 25, 2022- August 31, 2028),
P007A222257(March 25, 2022- August 31, 2028),
P033A222257(March 25, 2022- August 31, 2028),
P063P220252(March 23, 2022- August 31, 2028),
P268K230252(March 25, 2022- August 31, 2028),
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution(s): Alcorn State University (ASU) and Mississippi Valley State University (MVSU)
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 Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to perform Safeguards that address the required areas noted in GLBA 16 CFR 314.4, which are (1) the Institution designated a Qualified Individual responsible for implementing and monitoring the Institution’s information security program and (2) the Institution’s written information security program addresses the remaining six elements.
Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs.
Questioned Costs: None
Context: This condition occurred for the institutions as follows:
• For ASU, the institution’s policy did not identify a qualified individual (such as a CIO, ISO, CISO) responsible for the Information Security program. In addition, the written information security program (WISP) did not address certain required elements.
• For MVSU, the institution’s WISP has not been approved by the individual leading the information security program. In addition, the WISP did not address certain required elements.
Cause:
ASU
At the time of the audit, the University’s security program had not matured to the extent that published policies and procedures covered the items referred to in this finding.
MVSU
The University experienced turnover in the department responsible for this process.
Effect: The student personal information could be vulnerable.
Repeat Finding: 2022-008
Recommendation: CLA recommend that the University engage a third party or perform the risk assessment for the two areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks which are included in the Written Information Security Program.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-013: The Gramm-Leach-Bliley Act (GLBA) Compliance
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Number and Year: P007A222226(March 25, 2022- August 31, 2028),
P033P212226(March 25, 2022- August 31, 2028),
P063P211695(March 25, 2022- August 31, 2028),
P268K221695(March 25, 2022- August 31, 2028),
P033A212226(March 25, 2022- August 31, 2028),
P007A222257(March 25, 2022- August 31, 2028),
P033A222257(March 25, 2022- August 31, 2028),
P063P220252(March 23, 2022- August 31, 2028),
P268K230252(March 25, 2022- August 31, 2028),
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution(s): Alcorn State University (ASU) and Mississippi Valley State University (MVSU)
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 Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to perform Safeguards that address the required areas noted in GLBA 16 CFR 314.4, which are (1) the Institution designated a Qualified Individual responsible for implementing and monitoring the Institution’s information security program and (2) the Institution’s written information security program addresses the remaining six elements.
Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs.
Questioned Costs: None
Context: This condition occurred for the institutions as follows:
• For ASU, the institution’s policy did not identify a qualified individual (such as a CIO, ISO, CISO) responsible for the Information Security program. In addition, the written information security program (WISP) did not address certain required elements.
• For MVSU, the institution’s WISP has not been approved by the individual leading the information security program. In addition, the WISP did not address certain required elements.
Cause:
ASU
At the time of the audit, the University’s security program had not matured to the extent that published policies and procedures covered the items referred to in this finding.
MVSU
The University experienced turnover in the department responsible for this process.
Effect: The student personal information could be vulnerable.
Repeat Finding: 2022-008
Recommendation: CLA recommend that the University engage a third party or perform the risk assessment for the two areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks which are included in the Written Information Security Program.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-013: The Gramm-Leach-Bliley Act (GLBA) Compliance
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Award Number and Year: P007A222226(March 25, 2022- August 31, 2028),
P033P212226(March 25, 2022- August 31, 2028),
P063P211695(March 25, 2022- August 31, 2028),
P268K221695(March 25, 2022- August 31, 2028),
P033A212226(March 25, 2022- August 31, 2028),
P007A222257(March 25, 2022- August 31, 2028),
P033A222257(March 25, 2022- August 31, 2028),
P063P220252(March 23, 2022- August 31, 2028),
P268K230252(March 25, 2022- August 31, 2028),
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution(s): Alcorn State University (ASU) and Mississippi Valley State University (MVSU)
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 Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to perform Safeguards that address the required areas noted in GLBA 16 CFR 314.4, which are (1) the Institution designated a Qualified Individual responsible for implementing and monitoring the Institution’s information security program and (2) the Institution’s written information security program addresses the remaining six elements.
Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs.
Questioned Costs: None
Context: This condition occurred for the institutions as follows:
• For ASU, the institution’s policy did not identify a qualified individual (such as a CIO, ISO, CISO) responsible for the Information Security program. In addition, the written information security program (WISP) did not address certain required elements.
• For MVSU, the institution’s WISP has not been approved by the individual leading the information security program. In addition, the WISP did not address certain required elements.
Cause:
ASU
At the time of the audit, the University’s security program had not matured to the extent that published policies and procedures covered the items referred to in this finding.
MVSU
The University experienced turnover in the department responsible for this process.
Effect: The student personal information could be vulnerable.
Repeat Finding: 2022-008
Recommendation: CLA recommend that the University engage a third party or perform the risk assessment for the two areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks which are included in the Written Information Security Program.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-014: Return of Title IV Funds
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster
Assistance Listing Number: 84.063 and 84.268
Award Number and Year: P063P221706 (March 25, 2022- August 31, 2028),
P268K231706 (March 25, 2022- August 31, 2028)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: Jackson State University (JSU)
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 – When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date (34CFR section 668.22).
Condition: The return of funds was calculated improperly.
Questioned Costs: None
Context: For 1 out of 8 JSU students, the institution made an error in the R2T4 calculation. The school incorrectly deemed the student to have withdrawn after the 60% point of the semester, when in fact the student withdrew before the 60% point resulting in the institution needing to return Pell funds.
Cause: A change in personnel during the 22-23 academic year caused this process to not be completed timely. The counselor over this process resigned during the summer semester and the unofficial R2T4s were not completed as efficiently for that short period.
Effect: The students’ return of funds calculation was not done correctly and the return of funds back to the federal government was for the incorrect amount.
Repeat Finding: No
Recommendation: CLA recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct amount of term days and are accurately completed.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-014: Return of Title IV Funds
Federal Agency: Department of Education
Federal Program Title: Student Financial Aid Cluster
Assistance Listing Number: 84.063 and 84.268
Award Number and Year: P063P221706 (March 25, 2022- August 31, 2028),
P268K231706 (March 25, 2022- August 31, 2028)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: Jackson State University (JSU)
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 – When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date (34CFR section 668.22).
Condition: The return of funds was calculated improperly.
Questioned Costs: None
Context: For 1 out of 8 JSU students, the institution made an error in the R2T4 calculation. The school incorrectly deemed the student to have withdrawn after the 60% point of the semester, when in fact the student withdrew before the 60% point resulting in the institution needing to return Pell funds.
Cause: A change in personnel during the 22-23 academic year caused this process to not be completed timely. The counselor over this process resigned during the summer semester and the unofficial R2T4s were not completed as efficiently for that short period.
Effect: The students’ return of funds calculation was not done correctly and the return of funds back to the federal government was for the incorrect amount.
Repeat Finding: No
Recommendation: CLA recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct amount of term days and are accurately completed.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-015: SEFA Reporting of Expenditures
Federal Agency: Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425F
Award Number and Year: P425F201683 (May 6, 2020 – June 30, 2023)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Applicable Institution: Mississippi University for Women (MUW)
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 drew funds in fiscal year 2022 for amounts earned in fiscal year 2022 but were not reported on the SEFA until fiscal year 2023.
Questioned Costs: None
Context: The University’s calculation of lost revenue was performed in fiscal year 2022 and funds were drawn at that time the charge to the grant in the general ledger did not occur until fiscal year 2023 resulting in an error to the SEFA.
Cause: A journal entry for the lost revenue calculation was not entered in FY22 when the money was drawn down.
Effect: The SEFA does not reflect the accurate amount of federal expenditures for the year.
Repeat Finding: No
Recommendation: We recommend the institution review and revise its current reporting procedures and review requirements to ensure that federal expenditures are properly identified and classified.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-016: Suspension and Debarment
Federal Agency: Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425F
Award Number and Year: P425F201683 (May 6, 2020 – June 30, 2023)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Applicable Institution: Mississippi University for Women (MUW)
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: We noted that the University does not have policies or procedures in place for compliance with suspension and debarment requirements.
Questioned Costs: None
Context: The University does not have a policy or procedure to verify a vendor’s suspension and debarment status.
Cause: Due to personnel changes and undocumented policies and procedures, the individuals making purchases were not aware of the requirement.
Effect: The University is not in compliance with suspension and debarment requirements for its federal programs.
Repeat Finding: No
Recommendation: We recommend that the University ensure its policies and procedures over suspension and debarment are being enforced to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the SAM.gov website, maintaining a certification from the vendor, or including a clause in contract with vendors that they are not suspended or debarred.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-017: Quarterly and Annual HEERF Reporting
Federal Agency: U.S. Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F, 84.425J
Award Number and Year: P425F201683 (May 6, 2020 – June 30, 2023)
P425E200639 (April 21, 2020 – June 30, 2023)
P425F202078 (May 7, 2020 – June 30, 2023)
P425J200085 (May 1, 2020 – June 30, 2023)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution(s): Mississippi Valley State University (MVSU), Mississippi University for Women (MUW)
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 Federal Register Notice of Public Posting Requirement of Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees dated 5/13/21, institutions are required to submit (in a time and manner required by the Secretary) a report to the Secretary describing the use of funds distributed from the HEERF. The Department further requires institutions to post all quarterly reports to their website in a publicly accessible location. According to the OPE Reporting and Data Collection website, quarterly reports should appear on separate documents by quarter and should not be cumulative.
All institutions of higher education that received HEERF grant awards are required to submit a HEERF Annual Report. The HEERF Annual Report by the March 24, 2023 deadline.
Condition:
Mississippi Valley State University (MVSU)
Quarterly Reporting: MVSU could not provide evidence of review over the quarterly report submitted for the quarter ended June 30, 2022.
Annual Reporting: MVSU could not provide evidence of review over the annual report submitted March 25, 2023.
Mississippi University for Women (MUW)
Annual Reporting: MUW could not provide evidence of review over the annual report submitted March 24, 2023.
Quarterly Reporting: MUW submitted an out-of-date quarterly form for the quarter ending September 30, 2022. In addition, MUW could not provide evidence of review over the quarterly report submitted for the quarter ended September 30, 2022.
Questioned Costs: None.
Context:
Mississippi Valley State University (MVSU)
Quarterly Reporting: MVSU could not provide evidence of review over the quarterly report submitted for the quarter ended June 30, 2022.
Annual Reporting: MVSU could not provide evidence of review over the annual report submitted March 25, 2023. In addition, the report was submitted after the deadline.
Mississippi University for Women (MUW)
Annual Reporting: MUW could not provide evidence of review over the annual report submitted March 24, 2023.
Quarterly Reporting: MUW submitted an out of date quarterly form for the quarter ending September 30, 2022. In addition, MUW could not provide evidence of review over the quarterly report submitted for the quarter ended September 30, 2022.
Cause:
MVSU
Lack of proper internal controls to ensure that all reports are reviewed prior to posting quarterly reports to the University’s website and submitting annual performance reports. Previously, the State Director was not fully aware that reports must be reviewed prior to posting/submission. Effective July 10, 2023, quarterly reports are reviewed by the Director of Accounting and Vice President for Business and Finance prior to posting. The same procedure will apply to the annual performance report. The annual performance report provided for review was submitted after the deadline with no evidence that the report was submitted by the deadline.
MUW
Annual Reporting: All reports were reviewed prior to submission; however, there was no documented evidence that the review occurred.
Quarterly reporting: The grant PI failed to communicate to the Grant Accountant that one of the reporting forms had been revised.
Effect: Reports submitted are not in compliance with the reporting and information-sharing requirements established by the Department of Education.
Repeat Finding: 2022-005
Recommendation: We recommend the institutions strengthen their understanding of the reporting requirements established by the grant and ensure supporting documentation is maintained to substantiate amounts reported.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-017: Quarterly and Annual HEERF Reporting
Federal Agency: U.S. Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F, 84.425J
Award Number and Year: P425F201683 (May 6, 2020 – June 30, 2023)
P425E200639 (April 21, 2020 – June 30, 2023)
P425F202078 (May 7, 2020 – June 30, 2023)
P425J200085 (May 1, 2020 – June 30, 2023)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution(s): Mississippi Valley State University (MVSU), Mississippi University for Women (MUW)
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 Federal Register Notice of Public Posting Requirement of Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees dated 5/13/21, institutions are required to submit (in a time and manner required by the Secretary) a report to the Secretary describing the use of funds distributed from the HEERF. The Department further requires institutions to post all quarterly reports to their website in a publicly accessible location. According to the OPE Reporting and Data Collection website, quarterly reports should appear on separate documents by quarter and should not be cumulative.
All institutions of higher education that received HEERF grant awards are required to submit a HEERF Annual Report. The HEERF Annual Report by the March 24, 2023 deadline.
Condition:
Mississippi Valley State University (MVSU)
Quarterly Reporting: MVSU could not provide evidence of review over the quarterly report submitted for the quarter ended June 30, 2022.
Annual Reporting: MVSU could not provide evidence of review over the annual report submitted March 25, 2023.
Mississippi University for Women (MUW)
Annual Reporting: MUW could not provide evidence of review over the annual report submitted March 24, 2023.
Quarterly Reporting: MUW submitted an out-of-date quarterly form for the quarter ending September 30, 2022. In addition, MUW could not provide evidence of review over the quarterly report submitted for the quarter ended September 30, 2022.
Questioned Costs: None.
Context:
Mississippi Valley State University (MVSU)
Quarterly Reporting: MVSU could not provide evidence of review over the quarterly report submitted for the quarter ended June 30, 2022.
Annual Reporting: MVSU could not provide evidence of review over the annual report submitted March 25, 2023. In addition, the report was submitted after the deadline.
Mississippi University for Women (MUW)
Annual Reporting: MUW could not provide evidence of review over the annual report submitted March 24, 2023.
Quarterly Reporting: MUW submitted an out of date quarterly form for the quarter ending September 30, 2022. In addition, MUW could not provide evidence of review over the quarterly report submitted for the quarter ended September 30, 2022.
Cause:
MVSU
Lack of proper internal controls to ensure that all reports are reviewed prior to posting quarterly reports to the University’s website and submitting annual performance reports. Previously, the State Director was not fully aware that reports must be reviewed prior to posting/submission. Effective July 10, 2023, quarterly reports are reviewed by the Director of Accounting and Vice President for Business and Finance prior to posting. The same procedure will apply to the annual performance report. The annual performance report provided for review was submitted after the deadline with no evidence that the report was submitted by the deadline.
MUW
Annual Reporting: All reports were reviewed prior to submission; however, there was no documented evidence that the review occurred.
Quarterly reporting: The grant PI failed to communicate to the Grant Accountant that one of the reporting forms had been revised.
Effect: Reports submitted are not in compliance with the reporting and information-sharing requirements established by the Department of Education.
Repeat Finding: 2022-005
Recommendation: We recommend the institutions strengthen their understanding of the reporting requirements established by the grant and ensure supporting documentation is maintained to substantiate amounts reported.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-017: Quarterly and Annual HEERF Reporting
Federal Agency: U.S. Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425E, 84.425F, 84.425J
Award Number and Year: P425F201683 (May 6, 2020 – June 30, 2023)
P425E200639 (April 21, 2020 – June 30, 2023)
P425F202078 (May 7, 2020 – June 30, 2023)
P425J200085 (May 1, 2020 – June 30, 2023)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution(s): Mississippi Valley State University (MVSU), Mississippi University for Women (MUW)
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 Federal Register Notice of Public Posting Requirement of Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees dated 5/13/21, institutions are required to submit (in a time and manner required by the Secretary) a report to the Secretary describing the use of funds distributed from the HEERF. The Department further requires institutions to post all quarterly reports to their website in a publicly accessible location. According to the OPE Reporting and Data Collection website, quarterly reports should appear on separate documents by quarter and should not be cumulative.
All institutions of higher education that received HEERF grant awards are required to submit a HEERF Annual Report. The HEERF Annual Report by the March 24, 2023 deadline.
Condition:
Mississippi Valley State University (MVSU)
Quarterly Reporting: MVSU could not provide evidence of review over the quarterly report submitted for the quarter ended June 30, 2022.
Annual Reporting: MVSU could not provide evidence of review over the annual report submitted March 25, 2023.
Mississippi University for Women (MUW)
Annual Reporting: MUW could not provide evidence of review over the annual report submitted March 24, 2023.
Quarterly Reporting: MUW submitted an out-of-date quarterly form for the quarter ending September 30, 2022. In addition, MUW could not provide evidence of review over the quarterly report submitted for the quarter ended September 30, 2022.
Questioned Costs: None.
Context:
Mississippi Valley State University (MVSU)
Quarterly Reporting: MVSU could not provide evidence of review over the quarterly report submitted for the quarter ended June 30, 2022.
Annual Reporting: MVSU could not provide evidence of review over the annual report submitted March 25, 2023. In addition, the report was submitted after the deadline.
Mississippi University for Women (MUW)
Annual Reporting: MUW could not provide evidence of review over the annual report submitted March 24, 2023.
Quarterly Reporting: MUW submitted an out of date quarterly form for the quarter ending September 30, 2022. In addition, MUW could not provide evidence of review over the quarterly report submitted for the quarter ended September 30, 2022.
Cause:
MVSU
Lack of proper internal controls to ensure that all reports are reviewed prior to posting quarterly reports to the University’s website and submitting annual performance reports. Previously, the State Director was not fully aware that reports must be reviewed prior to posting/submission. Effective July 10, 2023, quarterly reports are reviewed by the Director of Accounting and Vice President for Business and Finance prior to posting. The same procedure will apply to the annual performance report. The annual performance report provided for review was submitted after the deadline with no evidence that the report was submitted by the deadline.
MUW
Annual Reporting: All reports were reviewed prior to submission; however, there was no documented evidence that the review occurred.
Quarterly reporting: The grant PI failed to communicate to the Grant Accountant that one of the reporting forms had been revised.
Effect: Reports submitted are not in compliance with the reporting and information-sharing requirements established by the Department of Education.
Repeat Finding: 2022-005
Recommendation: We recommend the institutions strengthen their understanding of the reporting requirements established by the grant and ensure supporting documentation is maintained to substantiate amounts reported.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-018: Equipment Records
Federal Agency: Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Number: 84.425C
Award Number and Year: GEER (November 8, 2021 – September 30, 2023)
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Applicable Institution: Jackson State University (JSU)
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 – Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property (2 CFR section 200.313(d)(1)).
Condition: Property records did not contain accurate information related to certain equipment purchases.
Questioned Costs: None
Context: We noted the following discrepancies with the property records of the University:
• For 2 out of 8 equipment assets selected for testing, the cost of the property per the invoice did not agree to the cost included on the property record.
• For 1 out of 8 equipment assets selected for testing, the description of the property on the property record was inaccurate.
• For 1 out of 8 equipment assets selected for testing, the serial number included on the property record did not match the serial number on the equipment.
Cause: Personnel made inaccurate entries on the front end of receiving and tagging the equipment.
Effect: The University is not in compliance with equipment requirements for its federal programs. As a result, equipment may not be properly accounted for and inventoried.
Repeat Finding: No
Recommendation: We recommend the institution strengthen its controls and processes related to capturing information relating to equipment purchases and ensure that property records properly reflect the required information.
Views of Responsible Officials: There is no disagreement with the audit finding.