2023-006 – Outstanding Refund Checks
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Numbers: 84.007, 84.063, 84.268
Federal Award Identification Number and Year: P007A220811, P063P221233 and P268K231233 – all
grants were awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance
2023-006 – Outstanding Refund Checks
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Numbers: 84.007, 84.063, 84.268
Federal Award Identification Number and Year: P007A220811, P063P221233 and P268K231233 – all
grants were awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance
2023-009 – Gramm-Leach-Bliley Act (GLBA)
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Numbers: 84.007, 84.063, 84.268, 84.033
Federal Award Identification Number and Year: P007A220811, P063P221233 and P268K231233 – all
grants were awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Matters and Material Weakness in Internal Control Over Compliance
Criteria or Specific Requirement: Institutions are required to develop, implement, and maintain a
comprehensive information security program that is written in one or more readily accessible parts. The
information security program should provide for the design and implementation of safeguards to control
the risks the institution identifies through its risk assessment (16 CFR 314.4(c)). At a minimum, the
institution’s written information security program must address the implementation of the minimum
safeguards identified in 16 CFR 314.4(c)(1) through (8).
A non-federal entity must maintain effective internal control over the federal award (2 CFR 200.303).
Condition: The University’s written information security program did not contain elements required by
GLBA. In addition, the approval of the plan was not able to be cited.
Questioned Costs: N/A
Context: During the testing of the University’s written information security program, it was noted that of
the 8 minimum safeguards, the University’s document was missing 5 minimum safeguards.
Cause: University does not have the policies and procedures in place to ensure the written information
security program is in compliance with GLBA.
Effect: The University’s written information security program is out of compliance with GLBA.
Repeat Finding: No.
Recommendation: We recommend the University review is policies and procedures and update the
information security plan to be GLBA compliant.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
2023-009 – Gramm-Leach-Bliley Act (GLBA)
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Numbers: 84.007, 84.063, 84.268, 84.033
Federal Award Identification Number and Year: P007A220811, P063P221233 and P268K231233 – all
grants were awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Matters and Material Weakness in Internal Control Over Compliance
Criteria or Specific Requirement: Institutions are required to develop, implement, and maintain a
comprehensive information security program that is written in one or more readily accessible parts. The
information security program should provide for the design and implementation of safeguards to control
the risks the institution identifies through its risk assessment (16 CFR 314.4(c)). At a minimum, the
institution’s written information security program must address the implementation of the minimum
safeguards identified in 16 CFR 314.4(c)(1) through (8).
A non-federal entity must maintain effective internal control over the federal award (2 CFR 200.303).
Condition: The University’s written information security program did not contain elements required by
GLBA. In addition, the approval of the plan was not able to be cited.
Questioned Costs: N/A
Context: During the testing of the University’s written information security program, it was noted that of
the 8 minimum safeguards, the University’s document was missing 5 minimum safeguards.
Cause: University does not have the policies and procedures in place to ensure the written information
security program is in compliance with GLBA.
Effect: The University’s written information security program is out of compliance with GLBA.
Repeat Finding: No.
Recommendation: We recommend the University review is policies and procedures and update the
information security plan to be GLBA compliant.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
2023-006 – Outstanding Refund Checks
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Numbers: 84.007, 84.063, 84.268
Federal Award Identification Number and Year: P007A220811, P063P221233 and P268K231233 – all
grants were awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance
2023-006 – Outstanding Refund Checks
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Numbers: 84.007, 84.063, 84.268
Federal Award Identification Number and Year: P007A220811, P063P221233 and P268K231233 – all
grants were awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance
2023-009 – Gramm-Leach-Bliley Act (GLBA)
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Numbers: 84.007, 84.063, 84.268, 84.033
Federal Award Identification Number and Year: P007A220811, P063P221233 and P268K231233 – all
grants were awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Matters and Material Weakness in Internal Control Over Compliance
Criteria or Specific Requirement: Institutions are required to develop, implement, and maintain a
comprehensive information security program that is written in one or more readily accessible parts. The
information security program should provide for the design and implementation of safeguards to control
the risks the institution identifies through its risk assessment (16 CFR 314.4(c)). At a minimum, the
institution’s written information security program must address the implementation of the minimum
safeguards identified in 16 CFR 314.4(c)(1) through (8).
A non-federal entity must maintain effective internal control over the federal award (2 CFR 200.303).
Condition: The University’s written information security program did not contain elements required by
GLBA. In addition, the approval of the plan was not able to be cited.
Questioned Costs: N/A
Context: During the testing of the University’s written information security program, it was noted that of
the 8 minimum safeguards, the University’s document was missing 5 minimum safeguards.
Cause: University does not have the policies and procedures in place to ensure the written information
security program is in compliance with GLBA.
Effect: The University’s written information security program is out of compliance with GLBA.
Repeat Finding: No.
Recommendation: We recommend the University review is policies and procedures and update the
information security plan to be GLBA compliant.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
2023-005 – Enrollment Reporting
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Federal Assistance Listing Numbers: 84.063 and 84.268
Federal Award Identification Number and Year: P063P221233 and P268K231233 – all grants were
awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Material Noncompliance (Modified Opinion) and Material Weakness in Internal Control
Over Compliance
Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools
participating (or approved to participate) in the Federal Student Assistance programs must have an
arrangement to report student enrollment data to the National Students Loan Data System (NSLDS)
through a roster file.
The school is required to report enrollment status at both the school and program level. The school is
required to report changes in the student’s enrollment status, the effective date of the status and an
anticipated completion date. An academic program is defined as the combination of the school’s Office
of Postsecondary Education Identification (OPEID) number and the program’s Classification of
Instructional Program (CIP) code, credential level, and published program length. ED requires the
University to report changes in enrollment status and indicate the date that the changes occurred (34
CFR 685.309).
Changes in enrollment status must be reported within 30 days. However, if a roster file is expected
within 60 days, you may provide the date on that roster file. In addition, regulations require that an
institution make necessary corrections and return the records within 10 days for any roster files that do
not pass the NSLDS enrollment reporting edits. ED requires the University to report changes in
enrollment status within 30 or 60 days that the University determined the changes occurred
(34 CFR 682.610).
A non-federal entity must maintain effective internal control over the federal award (2 CFR 200.303).
Condition: Certain students’ enrollment information was not reported accurately and timely to the
NSLDS.
Questioned Costs: N/A
Context: During the testing of enrollment status submissions, the following was noted:
1 student out of a sample of 40 was reported with the incorrect enrollment status at both the
campus and program levels.
2 students out of a sample of 40 students tested, had effective dates reported at the campus
level and program level that did not match.
3 students out of a sample of 40 students tested were reported to the NSLDS as a withdrawal
status at both the campus and program level but graduated per the University’s records. Their
status was not subsequently updated to reflect that they graduated.
19 students out of a sample of 40 students tested, were reported to the NSLDS with an incorrect
effective date at both the campus and program level.
31 students out of a sample of 40 students tested were not reported to the NSLDS at least
every 60 days.
Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS.
Occasionally, the third-party servicer incorrectly communicates information to the NSLDS which results
in discrepancies between the University's system and the NSLDS. The University has the ultimate
responsibility to ensure that reporting is correct.
Effect: Incorrect reporting to the NSLDS can result in incorrect determination of when the students’
grace period should begin.
Repeat Finding: Yes, 2022-006
Recommendation: We recommend the University evaluate its procedures and review policies in
overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we
recommend the University review its policies and procedures on reporting enrollment information to the
NSLDS to ensure that all relevant information is being captured and reported timely in accordance with
applicable regulations.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
2023-006 – Outstanding Refund Checks
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Numbers: 84.007, 84.063, 84.268
Federal Award Identification Number and Year: P007A220811, P063P221233 and P268K231233 – all
grants were awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance
2023-006 – Outstanding Refund Checks
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Numbers: 84.007, 84.063, 84.268
Federal Award Identification Number and Year: P007A220811, P063P221233 and P268K231233 – all
grants were awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance
2023-009 – Gramm-Leach-Bliley Act (GLBA)
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Numbers: 84.007, 84.063, 84.268, 84.033
Federal Award Identification Number and Year: P007A220811, P063P221233 and P268K231233 – all
grants were awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Matters and Material Weakness in Internal Control Over Compliance
Criteria or Specific Requirement: Institutions are required to develop, implement, and maintain a
comprehensive information security program that is written in one or more readily accessible parts. The
information security program should provide for the design and implementation of safeguards to control
the risks the institution identifies through its risk assessment (16 CFR 314.4(c)). At a minimum, the
institution’s written information security program must address the implementation of the minimum
safeguards identified in 16 CFR 314.4(c)(1) through (8).
A non-federal entity must maintain effective internal control over the federal award (2 CFR 200.303).
Condition: The University’s written information security program did not contain elements required by
GLBA. In addition, the approval of the plan was not able to be cited.
Questioned Costs: N/A
Context: During the testing of the University’s written information security program, it was noted that of
the 8 minimum safeguards, the University’s document was missing 5 minimum safeguards.
Cause: University does not have the policies and procedures in place to ensure the written information
security program is in compliance with GLBA.
Effect: The University’s written information security program is out of compliance with GLBA.
Repeat Finding: No.
Recommendation: We recommend the University review is policies and procedures and update the
information security plan to be GLBA compliant.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
2023-005 – Enrollment Reporting
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Federal Assistance Listing Numbers: 84.063 and 84.268
Federal Award Identification Number and Year: P063P221233 and P268K231233 – all grants were
awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Material Noncompliance (Modified Opinion) and Material Weakness in Internal Control
Over Compliance
Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools
participating (or approved to participate) in the Federal Student Assistance programs must have an
arrangement to report student enrollment data to the National Students Loan Data System (NSLDS)
through a roster file.
The school is required to report enrollment status at both the school and program level. The school is
required to report changes in the student’s enrollment status, the effective date of the status and an
anticipated completion date. An academic program is defined as the combination of the school’s Office
of Postsecondary Education Identification (OPEID) number and the program’s Classification of
Instructional Program (CIP) code, credential level, and published program length. ED requires the
University to report changes in enrollment status and indicate the date that the changes occurred (34
CFR 685.309).
Changes in enrollment status must be reported within 30 days. However, if a roster file is expected
within 60 days, you may provide the date on that roster file. In addition, regulations require that an
institution make necessary corrections and return the records within 10 days for any roster files that do
not pass the NSLDS enrollment reporting edits. ED requires the University to report changes in
enrollment status within 30 or 60 days that the University determined the changes occurred
(34 CFR 682.610).
A non-federal entity must maintain effective internal control over the federal award (2 CFR 200.303).
Condition: Certain students’ enrollment information was not reported accurately and timely to the
NSLDS.
Questioned Costs: N/A
Context: During the testing of enrollment status submissions, the following was noted:
1 student out of a sample of 40 was reported with the incorrect enrollment status at both the
campus and program levels.
2 students out of a sample of 40 students tested, had effective dates reported at the campus
level and program level that did not match.
3 students out of a sample of 40 students tested were reported to the NSLDS as a withdrawal
status at both the campus and program level but graduated per the University’s records. Their
status was not subsequently updated to reflect that they graduated.
19 students out of a sample of 40 students tested, were reported to the NSLDS with an incorrect
effective date at both the campus and program level.
31 students out of a sample of 40 students tested were not reported to the NSLDS at least
every 60 days.
Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS.
Occasionally, the third-party servicer incorrectly communicates information to the NSLDS which results
in discrepancies between the University's system and the NSLDS. The University has the ultimate
responsibility to ensure that reporting is correct.
Effect: Incorrect reporting to the NSLDS can result in incorrect determination of when the students’
grace period should begin.
Repeat Finding: Yes, 2022-006
Recommendation: We recommend the University evaluate its procedures and review policies in
overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we
recommend the University review its policies and procedures on reporting enrollment information to the
NSLDS to ensure that all relevant information is being captured and reported timely in accordance with
applicable regulations.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
2023-007 – Reporting
Federal Agency: U.S. Department of Education
Federal Program Title: Education Stabilization Fund – Higher Education Emergency Relief Fund –
Student Aid Portion and Institutional Portion
Federal Assistance Listing Numbers: 84.425E and 84.425F
Federal Award Identification Number and Year: P425F203028 and P425E201388 – all grants were
awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance
Criteria or Specific Requirement: There are three components to reporting for Higher Education
Emergency Relief Fund (HEERF): 1) public reporting on the (a)(1) Student Aid Portion; 2) public
reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form),
as applicable; and 3) the annual report. A non-federal entity must maintain effective internal control
over the federal award (2 CFR 200.303).
Condition: The University did not comply with the requirements for timely reporting under HEERF.
Questioned Costs: N/A
Context: During testing of the reporting requirements for HEERF, the quarter three report was posted
to the University website more than 10 days after the end of the quarter.
Cause: This report was overlooked.
Effect: Failure to support or file the required reports timely may result in the loss of funding.
Repeat Finding: Yes, 2022-010
Recommendation: We recommend the University enhances its procedures, controls, and review
policies around HEERF reporting requirements.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
2023-008 – Cash Management
Federal Agency: U.S. Department of Education
Federal Program Title: Education Stabilization Fund – Higher Education Emergency Relief Fund –
Student Aid Portion and Institutional Portion
Federal Assistance Listing Numbers: 84.425E and 84.425F
Federal Award Identification Number and Year: P425F203028 and P425E201388 – all grants were
awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance
Criteria or Specific Requirement: The Code of Federal Regulations, 2 CFR 200.305(b)(1), the non-
Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to
maintain both written procedures that minimize the time elapsing between the transfer of funds and
disbursement by the non-Federal entity, and financial management systems that meet the standards for
fund control and accountability as established in this part. Advance payments to a non-Federal entity
must be limited to the minimum amounts needed and be timed to be in accordance with the actual,
immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved
program or project. The timing and amount of advance payments must be as close as is
administratively feasible to the actual disbursements by the non-Federal entity for direct program or
project costs and the proportionate share of any allowable indirect costs. The non-Federal entity must
make timely payment to contractors in accordance with the contract provisions.
200.305(b)(9) Interest earned amounts up to $500 per year may be retained by the non-Federal entity
for administrative expense. Any additional interest earned on Federal advance payments deposited in
interest-bearing accounts must be remitted annually to the government.
A non-federal entity must maintain effective internal control over the federal award (2 CFR 200.303).
Condition: The University did not expend all funds drawn down in advance by June 30, 2023, and
therefore, they did not minimize the amount of time between the transfer of funds and disbursement.
Additionally, more than $500 of interest was earned on the unspent funds and it was not remitted to the
federal government as of year-end.
Questioned Costs: $75,070 of interest earned as of June 30, 2023
Context: Federal funds were drawn down in advance of expenditure and there were no policies to
minimize the time elapsing between the transfer of funds and disbursement by the University.
Additionally, the University earned interest greater than $500 which was not remitted as of report date.
Cause: University does not have a documented procedure or control that minimizes the time elapsing
between the transfer of funds and disbursement or returning earned interest.
Effect: Failure to document and adhere to procedures to minimize the time elapsing between transfer
and disbursement of funds and the University incurred interest that has not been remitted back to the
treasury.
Repeat Finding: Yes, 2022-011
Recommendation: We recommend the University formally design and implement controls and monitor
advances in federal funds to ensure time elapsing between the transfer of funds and disbursement is
minimized and any interest required to be remitted is calculated and returned on a timely basis.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
2023-007 – Reporting
Federal Agency: U.S. Department of Education
Federal Program Title: Education Stabilization Fund – Higher Education Emergency Relief Fund –
Student Aid Portion and Institutional Portion
Federal Assistance Listing Numbers: 84.425E and 84.425F
Federal Award Identification Number and Year: P425F203028 and P425E201388 – all grants were
awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance
Criteria or Specific Requirement: There are three components to reporting for Higher Education
Emergency Relief Fund (HEERF): 1) public reporting on the (a)(1) Student Aid Portion; 2) public
reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form),
as applicable; and 3) the annual report. A non-federal entity must maintain effective internal control
over the federal award (2 CFR 200.303).
Condition: The University did not comply with the requirements for timely reporting under HEERF.
Questioned Costs: N/A
Context: During testing of the reporting requirements for HEERF, the quarter three report was posted
to the University website more than 10 days after the end of the quarter.
Cause: This report was overlooked.
Effect: Failure to support or file the required reports timely may result in the loss of funding.
Repeat Finding: Yes, 2022-010
Recommendation: We recommend the University enhances its procedures, controls, and review
policies around HEERF reporting requirements.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
2023-008 – Cash Management
Federal Agency: U.S. Department of Education
Federal Program Title: Education Stabilization Fund – Higher Education Emergency Relief Fund –
Student Aid Portion and Institutional Portion
Federal Assistance Listing Numbers: 84.425E and 84.425F
Federal Award Identification Number and Year: P425F203028 and P425E201388 – all grants were
awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance
Criteria or Specific Requirement: The Code of Federal Regulations, 2 CFR 200.305(b)(1), the non-
Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to
maintain both written procedures that minimize the time elapsing between the transfer of funds and
disbursement by the non-Federal entity, and financial management systems that meet the standards for
fund control and accountability as established in this part. Advance payments to a non-Federal entity
must be limited to the minimum amounts needed and be timed to be in accordance with the actual,
immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved
program or project. The timing and amount of advance payments must be as close as is
administratively feasible to the actual disbursements by the non-Federal entity for direct program or
project costs and the proportionate share of any allowable indirect costs. The non-Federal entity must
make timely payment to contractors in accordance with the contract provisions.
200.305(b)(9) Interest earned amounts up to $500 per year may be retained by the non-Federal entity
for administrative expense. Any additional interest earned on Federal advance payments deposited in
interest-bearing accounts must be remitted annually to the government.
A non-federal entity must maintain effective internal control over the federal award (2 CFR 200.303).
Condition: The University did not expend all funds drawn down in advance by June 30, 2023, and
therefore, they did not minimize the amount of time between the transfer of funds and disbursement.
Additionally, more than $500 of interest was earned on the unspent funds and it was not remitted to the
federal government as of year-end.
Questioned Costs: $75,070 of interest earned as of June 30, 2023
Context: Federal funds were drawn down in advance of expenditure and there were no policies to
minimize the time elapsing between the transfer of funds and disbursement by the University.
Additionally, the University earned interest greater than $500 which was not remitted as of report date.
Cause: University does not have a documented procedure or control that minimizes the time elapsing
between the transfer of funds and disbursement or returning earned interest.
Effect: Failure to document and adhere to procedures to minimize the time elapsing between transfer
and disbursement of funds and the University incurred interest that has not been remitted back to the
treasury.
Repeat Finding: Yes, 2022-011
Recommendation: We recommend the University formally design and implement controls and monitor
advances in federal funds to ensure time elapsing between the transfer of funds and disbursement is
minimized and any interest required to be remitted is calculated and returned on a timely basis.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
2023-004 – Schedule of Expenditures of Federal Awards
Federal Agency: U.S. Department of Treasury
Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds
Federal Assistance Listing Number: 21.027
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Noncompliance and Material Weakness in Internal Control Over Compliance
Criteria or Specific Requirement: Uniform guidance requires the auditee to prepare a schedule of
expenditures of federal awards (SEFA) which must include the total federal awards expended as
determined in accordance with sub-section 200.502. 2 CFR 200.510. A non-federal entity must
maintain effective internal control over the federal award (2 CFR 200.303).
Condition: During our testing of the SEFA it was identified that there were missing federal
expenditures, expenditures included in error that were not related to a federal grant, and amounts
reported as subrecipient pass through expenses in error.
Questioned Costs: N/A.
Context: Federal expenses were omitted from the schedule totaling $5,648,252 of federal passthrough
funds. In addition, $3,848,887 were erroneously included in the SEFA that did not meet the
definition of federal funds and management included approximately $2,487,864 in pass-through funds
to subrecipients in error. The SEFA was revised to correct these errors.
Cause: The University’s policies and procedures were not followed or not adequate to ensure a
complete and accurate SEFA.
Effect: The SEFA did not include correct amounts for the fiscal year ended June 30, 2023.
Repeat Finding: No.
Recommendation: We recommend that the University reevaluate its policies and controls related to
the preparation of the SEFA to ensure its complete and accurate.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
2023-006 – Outstanding Refund Checks
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Numbers: 84.007, 84.063, 84.268
Federal Award Identification Number and Year: P007A220811, P063P221233 and P268K231233 – all
grants were awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance
2023-006 – Outstanding Refund Checks
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Numbers: 84.007, 84.063, 84.268
Federal Award Identification Number and Year: P007A220811, P063P221233 and P268K231233 – all
grants were awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance
2023-009 – Gramm-Leach-Bliley Act (GLBA)
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Numbers: 84.007, 84.063, 84.268, 84.033
Federal Award Identification Number and Year: P007A220811, P063P221233 and P268K231233 – all
grants were awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Matters and Material Weakness in Internal Control Over Compliance
Criteria or Specific Requirement: Institutions are required to develop, implement, and maintain a
comprehensive information security program that is written in one or more readily accessible parts. The
information security program should provide for the design and implementation of safeguards to control
the risks the institution identifies through its risk assessment (16 CFR 314.4(c)). At a minimum, the
institution’s written information security program must address the implementation of the minimum
safeguards identified in 16 CFR 314.4(c)(1) through (8).
A non-federal entity must maintain effective internal control over the federal award (2 CFR 200.303).
Condition: The University’s written information security program did not contain elements required by
GLBA. In addition, the approval of the plan was not able to be cited.
Questioned Costs: N/A
Context: During the testing of the University’s written information security program, it was noted that of
the 8 minimum safeguards, the University’s document was missing 5 minimum safeguards.
Cause: University does not have the policies and procedures in place to ensure the written information
security program is in compliance with GLBA.
Effect: The University’s written information security program is out of compliance with GLBA.
Repeat Finding: No.
Recommendation: We recommend the University review is policies and procedures and update the
information security plan to be GLBA compliant.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
2023-009 – Gramm-Leach-Bliley Act (GLBA)
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Numbers: 84.007, 84.063, 84.268, 84.033
Federal Award Identification Number and Year: P007A220811, P063P221233 and P268K231233 – all
grants were awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Matters and Material Weakness in Internal Control Over Compliance
Criteria or Specific Requirement: Institutions are required to develop, implement, and maintain a
comprehensive information security program that is written in one or more readily accessible parts. The
information security program should provide for the design and implementation of safeguards to control
the risks the institution identifies through its risk assessment (16 CFR 314.4(c)). At a minimum, the
institution’s written information security program must address the implementation of the minimum
safeguards identified in 16 CFR 314.4(c)(1) through (8).
A non-federal entity must maintain effective internal control over the federal award (2 CFR 200.303).
Condition: The University’s written information security program did not contain elements required by
GLBA. In addition, the approval of the plan was not able to be cited.
Questioned Costs: N/A
Context: During the testing of the University’s written information security program, it was noted that of
the 8 minimum safeguards, the University’s document was missing 5 minimum safeguards.
Cause: University does not have the policies and procedures in place to ensure the written information
security program is in compliance with GLBA.
Effect: The University’s written information security program is out of compliance with GLBA.
Repeat Finding: No.
Recommendation: We recommend the University review is policies and procedures and update the
information security plan to be GLBA compliant.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
2023-006 – Outstanding Refund Checks
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Numbers: 84.007, 84.063, 84.268
Federal Award Identification Number and Year: P007A220811, P063P221233 and P268K231233 – all
grants were awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance
2023-006 – Outstanding Refund Checks
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Numbers: 84.007, 84.063, 84.268
Federal Award Identification Number and Year: P007A220811, P063P221233 and P268K231233 – all
grants were awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance
2023-009 – Gramm-Leach-Bliley Act (GLBA)
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Numbers: 84.007, 84.063, 84.268, 84.033
Federal Award Identification Number and Year: P007A220811, P063P221233 and P268K231233 – all
grants were awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Matters and Material Weakness in Internal Control Over Compliance
Criteria or Specific Requirement: Institutions are required to develop, implement, and maintain a
comprehensive information security program that is written in one or more readily accessible parts. The
information security program should provide for the design and implementation of safeguards to control
the risks the institution identifies through its risk assessment (16 CFR 314.4(c)). At a minimum, the
institution’s written information security program must address the implementation of the minimum
safeguards identified in 16 CFR 314.4(c)(1) through (8).
A non-federal entity must maintain effective internal control over the federal award (2 CFR 200.303).
Condition: The University’s written information security program did not contain elements required by
GLBA. In addition, the approval of the plan was not able to be cited.
Questioned Costs: N/A
Context: During the testing of the University’s written information security program, it was noted that of
the 8 minimum safeguards, the University’s document was missing 5 minimum safeguards.
Cause: University does not have the policies and procedures in place to ensure the written information
security program is in compliance with GLBA.
Effect: The University’s written information security program is out of compliance with GLBA.
Repeat Finding: No.
Recommendation: We recommend the University review is policies and procedures and update the
information security plan to be GLBA compliant.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
2023-005 – Enrollment Reporting
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Federal Assistance Listing Numbers: 84.063 and 84.268
Federal Award Identification Number and Year: P063P221233 and P268K231233 – all grants were
awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Material Noncompliance (Modified Opinion) and Material Weakness in Internal Control
Over Compliance
Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools
participating (or approved to participate) in the Federal Student Assistance programs must have an
arrangement to report student enrollment data to the National Students Loan Data System (NSLDS)
through a roster file.
The school is required to report enrollment status at both the school and program level. The school is
required to report changes in the student’s enrollment status, the effective date of the status and an
anticipated completion date. An academic program is defined as the combination of the school’s Office
of Postsecondary Education Identification (OPEID) number and the program’s Classification of
Instructional Program (CIP) code, credential level, and published program length. ED requires the
University to report changes in enrollment status and indicate the date that the changes occurred (34
CFR 685.309).
Changes in enrollment status must be reported within 30 days. However, if a roster file is expected
within 60 days, you may provide the date on that roster file. In addition, regulations require that an
institution make necessary corrections and return the records within 10 days for any roster files that do
not pass the NSLDS enrollment reporting edits. ED requires the University to report changes in
enrollment status within 30 or 60 days that the University determined the changes occurred
(34 CFR 682.610).
A non-federal entity must maintain effective internal control over the federal award (2 CFR 200.303).
Condition: Certain students’ enrollment information was not reported accurately and timely to the
NSLDS.
Questioned Costs: N/A
Context: During the testing of enrollment status submissions, the following was noted:
1 student out of a sample of 40 was reported with the incorrect enrollment status at both the
campus and program levels.
2 students out of a sample of 40 students tested, had effective dates reported at the campus
level and program level that did not match.
3 students out of a sample of 40 students tested were reported to the NSLDS as a withdrawal
status at both the campus and program level but graduated per the University’s records. Their
status was not subsequently updated to reflect that they graduated.
19 students out of a sample of 40 students tested, were reported to the NSLDS with an incorrect
effective date at both the campus and program level.
31 students out of a sample of 40 students tested were not reported to the NSLDS at least
every 60 days.
Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS.
Occasionally, the third-party servicer incorrectly communicates information to the NSLDS which results
in discrepancies between the University's system and the NSLDS. The University has the ultimate
responsibility to ensure that reporting is correct.
Effect: Incorrect reporting to the NSLDS can result in incorrect determination of when the students’
grace period should begin.
Repeat Finding: Yes, 2022-006
Recommendation: We recommend the University evaluate its procedures and review policies in
overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we
recommend the University review its policies and procedures on reporting enrollment information to the
NSLDS to ensure that all relevant information is being captured and reported timely in accordance with
applicable regulations.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
2023-006 – Outstanding Refund Checks
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Numbers: 84.007, 84.063, 84.268
Federal Award Identification Number and Year: P007A220811, P063P221233 and P268K231233 – all
grants were awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance
2023-006 – Outstanding Refund Checks
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Numbers: 84.007, 84.063, 84.268
Federal Award Identification Number and Year: P007A220811, P063P221233 and P268K231233 – all
grants were awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance
2023-009 – Gramm-Leach-Bliley Act (GLBA)
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Numbers: 84.007, 84.063, 84.268, 84.033
Federal Award Identification Number and Year: P007A220811, P063P221233 and P268K231233 – all
grants were awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Matters and Material Weakness in Internal Control Over Compliance
Criteria or Specific Requirement: Institutions are required to develop, implement, and maintain a
comprehensive information security program that is written in one or more readily accessible parts. The
information security program should provide for the design and implementation of safeguards to control
the risks the institution identifies through its risk assessment (16 CFR 314.4(c)). At a minimum, the
institution’s written information security program must address the implementation of the minimum
safeguards identified in 16 CFR 314.4(c)(1) through (8).
A non-federal entity must maintain effective internal control over the federal award (2 CFR 200.303).
Condition: The University’s written information security program did not contain elements required by
GLBA. In addition, the approval of the plan was not able to be cited.
Questioned Costs: N/A
Context: During the testing of the University’s written information security program, it was noted that of
the 8 minimum safeguards, the University’s document was missing 5 minimum safeguards.
Cause: University does not have the policies and procedures in place to ensure the written information
security program is in compliance with GLBA.
Effect: The University’s written information security program is out of compliance with GLBA.
Repeat Finding: No.
Recommendation: We recommend the University review is policies and procedures and update the
information security plan to be GLBA compliant.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
2023-005 – Enrollment Reporting
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Federal Assistance Listing Numbers: 84.063 and 84.268
Federal Award Identification Number and Year: P063P221233 and P268K231233 – all grants were
awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Material Noncompliance (Modified Opinion) and Material Weakness in Internal Control
Over Compliance
Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools
participating (or approved to participate) in the Federal Student Assistance programs must have an
arrangement to report student enrollment data to the National Students Loan Data System (NSLDS)
through a roster file.
The school is required to report enrollment status at both the school and program level. The school is
required to report changes in the student’s enrollment status, the effective date of the status and an
anticipated completion date. An academic program is defined as the combination of the school’s Office
of Postsecondary Education Identification (OPEID) number and the program’s Classification of
Instructional Program (CIP) code, credential level, and published program length. ED requires the
University to report changes in enrollment status and indicate the date that the changes occurred (34
CFR 685.309).
Changes in enrollment status must be reported within 30 days. However, if a roster file is expected
within 60 days, you may provide the date on that roster file. In addition, regulations require that an
institution make necessary corrections and return the records within 10 days for any roster files that do
not pass the NSLDS enrollment reporting edits. ED requires the University to report changes in
enrollment status within 30 or 60 days that the University determined the changes occurred
(34 CFR 682.610).
A non-federal entity must maintain effective internal control over the federal award (2 CFR 200.303).
Condition: Certain students’ enrollment information was not reported accurately and timely to the
NSLDS.
Questioned Costs: N/A
Context: During the testing of enrollment status submissions, the following was noted:
1 student out of a sample of 40 was reported with the incorrect enrollment status at both the
campus and program levels.
2 students out of a sample of 40 students tested, had effective dates reported at the campus
level and program level that did not match.
3 students out of a sample of 40 students tested were reported to the NSLDS as a withdrawal
status at both the campus and program level but graduated per the University’s records. Their
status was not subsequently updated to reflect that they graduated.
19 students out of a sample of 40 students tested, were reported to the NSLDS with an incorrect
effective date at both the campus and program level.
31 students out of a sample of 40 students tested were not reported to the NSLDS at least
every 60 days.
Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS.
Occasionally, the third-party servicer incorrectly communicates information to the NSLDS which results
in discrepancies between the University's system and the NSLDS. The University has the ultimate
responsibility to ensure that reporting is correct.
Effect: Incorrect reporting to the NSLDS can result in incorrect determination of when the students’
grace period should begin.
Repeat Finding: Yes, 2022-006
Recommendation: We recommend the University evaluate its procedures and review policies in
overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we
recommend the University review its policies and procedures on reporting enrollment information to the
NSLDS to ensure that all relevant information is being captured and reported timely in accordance with
applicable regulations.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
2023-007 – Reporting
Federal Agency: U.S. Department of Education
Federal Program Title: Education Stabilization Fund – Higher Education Emergency Relief Fund –
Student Aid Portion and Institutional Portion
Federal Assistance Listing Numbers: 84.425E and 84.425F
Federal Award Identification Number and Year: P425F203028 and P425E201388 – all grants were
awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance
Criteria or Specific Requirement: There are three components to reporting for Higher Education
Emergency Relief Fund (HEERF): 1) public reporting on the (a)(1) Student Aid Portion; 2) public
reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form),
as applicable; and 3) the annual report. A non-federal entity must maintain effective internal control
over the federal award (2 CFR 200.303).
Condition: The University did not comply with the requirements for timely reporting under HEERF.
Questioned Costs: N/A
Context: During testing of the reporting requirements for HEERF, the quarter three report was posted
to the University website more than 10 days after the end of the quarter.
Cause: This report was overlooked.
Effect: Failure to support or file the required reports timely may result in the loss of funding.
Repeat Finding: Yes, 2022-010
Recommendation: We recommend the University enhances its procedures, controls, and review
policies around HEERF reporting requirements.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
2023-008 – Cash Management
Federal Agency: U.S. Department of Education
Federal Program Title: Education Stabilization Fund – Higher Education Emergency Relief Fund –
Student Aid Portion and Institutional Portion
Federal Assistance Listing Numbers: 84.425E and 84.425F
Federal Award Identification Number and Year: P425F203028 and P425E201388 – all grants were
awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance
Criteria or Specific Requirement: The Code of Federal Regulations, 2 CFR 200.305(b)(1), the non-
Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to
maintain both written procedures that minimize the time elapsing between the transfer of funds and
disbursement by the non-Federal entity, and financial management systems that meet the standards for
fund control and accountability as established in this part. Advance payments to a non-Federal entity
must be limited to the minimum amounts needed and be timed to be in accordance with the actual,
immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved
program or project. The timing and amount of advance payments must be as close as is
administratively feasible to the actual disbursements by the non-Federal entity for direct program or
project costs and the proportionate share of any allowable indirect costs. The non-Federal entity must
make timely payment to contractors in accordance with the contract provisions.
200.305(b)(9) Interest earned amounts up to $500 per year may be retained by the non-Federal entity
for administrative expense. Any additional interest earned on Federal advance payments deposited in
interest-bearing accounts must be remitted annually to the government.
A non-federal entity must maintain effective internal control over the federal award (2 CFR 200.303).
Condition: The University did not expend all funds drawn down in advance by June 30, 2023, and
therefore, they did not minimize the amount of time between the transfer of funds and disbursement.
Additionally, more than $500 of interest was earned on the unspent funds and it was not remitted to the
federal government as of year-end.
Questioned Costs: $75,070 of interest earned as of June 30, 2023
Context: Federal funds were drawn down in advance of expenditure and there were no policies to
minimize the time elapsing between the transfer of funds and disbursement by the University.
Additionally, the University earned interest greater than $500 which was not remitted as of report date.
Cause: University does not have a documented procedure or control that minimizes the time elapsing
between the transfer of funds and disbursement or returning earned interest.
Effect: Failure to document and adhere to procedures to minimize the time elapsing between transfer
and disbursement of funds and the University incurred interest that has not been remitted back to the
treasury.
Repeat Finding: Yes, 2022-011
Recommendation: We recommend the University formally design and implement controls and monitor
advances in federal funds to ensure time elapsing between the transfer of funds and disbursement is
minimized and any interest required to be remitted is calculated and returned on a timely basis.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
2023-007 – Reporting
Federal Agency: U.S. Department of Education
Federal Program Title: Education Stabilization Fund – Higher Education Emergency Relief Fund –
Student Aid Portion and Institutional Portion
Federal Assistance Listing Numbers: 84.425E and 84.425F
Federal Award Identification Number and Year: P425F203028 and P425E201388 – all grants were
awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance
Criteria or Specific Requirement: There are three components to reporting for Higher Education
Emergency Relief Fund (HEERF): 1) public reporting on the (a)(1) Student Aid Portion; 2) public
reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form),
as applicable; and 3) the annual report. A non-federal entity must maintain effective internal control
over the federal award (2 CFR 200.303).
Condition: The University did not comply with the requirements for timely reporting under HEERF.
Questioned Costs: N/A
Context: During testing of the reporting requirements for HEERF, the quarter three report was posted
to the University website more than 10 days after the end of the quarter.
Cause: This report was overlooked.
Effect: Failure to support or file the required reports timely may result in the loss of funding.
Repeat Finding: Yes, 2022-010
Recommendation: We recommend the University enhances its procedures, controls, and review
policies around HEERF reporting requirements.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
2023-008 – Cash Management
Federal Agency: U.S. Department of Education
Federal Program Title: Education Stabilization Fund – Higher Education Emergency Relief Fund –
Student Aid Portion and Institutional Portion
Federal Assistance Listing Numbers: 84.425E and 84.425F
Federal Award Identification Number and Year: P425F203028 and P425E201388 – all grants were
awarded within 2021-2022 and 2022-2023
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance
Criteria or Specific Requirement: The Code of Federal Regulations, 2 CFR 200.305(b)(1), the non-
Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to
maintain both written procedures that minimize the time elapsing between the transfer of funds and
disbursement by the non-Federal entity, and financial management systems that meet the standards for
fund control and accountability as established in this part. Advance payments to a non-Federal entity
must be limited to the minimum amounts needed and be timed to be in accordance with the actual,
immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved
program or project. The timing and amount of advance payments must be as close as is
administratively feasible to the actual disbursements by the non-Federal entity for direct program or
project costs and the proportionate share of any allowable indirect costs. The non-Federal entity must
make timely payment to contractors in accordance with the contract provisions.
200.305(b)(9) Interest earned amounts up to $500 per year may be retained by the non-Federal entity
for administrative expense. Any additional interest earned on Federal advance payments deposited in
interest-bearing accounts must be remitted annually to the government.
A non-federal entity must maintain effective internal control over the federal award (2 CFR 200.303).
Condition: The University did not expend all funds drawn down in advance by June 30, 2023, and
therefore, they did not minimize the amount of time between the transfer of funds and disbursement.
Additionally, more than $500 of interest was earned on the unspent funds and it was not remitted to the
federal government as of year-end.
Questioned Costs: $75,070 of interest earned as of June 30, 2023
Context: Federal funds were drawn down in advance of expenditure and there were no policies to
minimize the time elapsing between the transfer of funds and disbursement by the University.
Additionally, the University earned interest greater than $500 which was not remitted as of report date.
Cause: University does not have a documented procedure or control that minimizes the time elapsing
between the transfer of funds and disbursement or returning earned interest.
Effect: Failure to document and adhere to procedures to minimize the time elapsing between transfer
and disbursement of funds and the University incurred interest that has not been remitted back to the
treasury.
Repeat Finding: Yes, 2022-011
Recommendation: We recommend the University formally design and implement controls and monitor
advances in federal funds to ensure time elapsing between the transfer of funds and disbursement is
minimized and any interest required to be remitted is calculated and returned on a timely basis.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.
2023-004 – Schedule of Expenditures of Federal Awards
Federal Agency: U.S. Department of Treasury
Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds
Federal Assistance Listing Number: 21.027
Award Period: 7/1/2022 – 6/30/2023
Type of Finding: Other Noncompliance and Material Weakness in Internal Control Over Compliance
Criteria or Specific Requirement: Uniform guidance requires the auditee to prepare a schedule of
expenditures of federal awards (SEFA) which must include the total federal awards expended as
determined in accordance with sub-section 200.502. 2 CFR 200.510. A non-federal entity must
maintain effective internal control over the federal award (2 CFR 200.303).
Condition: During our testing of the SEFA it was identified that there were missing federal
expenditures, expenditures included in error that were not related to a federal grant, and amounts
reported as subrecipient pass through expenses in error.
Questioned Costs: N/A.
Context: Federal expenses were omitted from the schedule totaling $5,648,252 of federal passthrough
funds. In addition, $3,848,887 were erroneously included in the SEFA that did not meet the
definition of federal funds and management included approximately $2,487,864 in pass-through funds
to subrecipients in error. The SEFA was revised to correct these errors.
Cause: The University’s policies and procedures were not followed or not adequate to ensure a
complete and accurate SEFA.
Effect: The SEFA did not include correct amounts for the fiscal year ended June 30, 2023.
Repeat Finding: No.
Recommendation: We recommend that the University reevaluate its policies and controls related to
the preparation of the SEFA to ensure its complete and accurate.
Views of Responsible Officials: There is no disagreement with the audit finding and the University is
in the process of implementing corrective procedures.