SCHEDULE OF FINDINGS AND QUESTIONED COSTS AND CORRECTIVE ACTION PLAN
Federal Award Findings and Questioned Costs
June 30, 2023
Comment 2023-005
ENROLLMENT REPORTING PROCEDURES SHOULD BE STRENGTHENED
STUDENT FINANCIAL AID CLUSTER PROGRAM
CFDA # 84.268
(Questioned Costs - None)
Condition:
When the Registrar’s Office discovers that a student did not enroll or ceased to be enrolled on at least a half-time basis,
the National Student Loan Data System (NSLDS) should be notified of the change in the student’s enrollment status
within thirty days of the occurrence, unless the Institution expects to complete its next scheduled filing within sixty days.
During our audit, we noted three (3) instances in which student status changes were reported more than sixty (60) days
after the occurrence.
Context:
A haphazard selection of ten (10) students was made from the list of student withdrawals and graduates during the year.
Criteria:
Federal regulations require the Institution to notify the NSLDS of a change in student status (i.e., withdrawn, graduated,
enrolled less than half-time, etc.). Unless the Institution expects to complete its next filing within sixty days, the
Institution must notify the NSLDS within thirty days if it discovers a student with an outstanding federal loan balance
has ceased to be enrolled on at least a half-time basis. [34 CFR 685.309]
Effect:
The lender or guaranty agency is not receiving prompt notification of changes in borrower’s enrollment status. This
results in delayed processing of loan repayment periods and leads to poor default management. Late or incorrect updates
to the NSLDS may also cause students to receive loans for which they are not eligible, as half-time enrollment is a
requirement for Federal Direct Loan (FDL) eligibility.
Cause:
Necessary withdrawal documentation is not consistently processed and forwarded to appropriate departments in a timely
manner to ensure reports are accurately filed as scheduled. Overall, there is an inadequate process of verifying the
enrollment status of students.
Recommendation:
The Institution should implement procedures to ensure compliance with federal regulations. The Registrar’s Office
should obtain a complete understanding of the NSLDS reporting requirements. Improving the accuracy and timeliness
of student status filings will aid in the transition of students to loan repayment status.
Views of Responsible Officials and Planned Corrective Actions:
Management agrees with the auditors and has initiated the necessary corrective action plan to mitigate the deficiency
from occurring again. The plan is to implement new procedures to ensure the reporting to the NSLDS is done on a
timely basis.
Implementation date: Immediately.
Persons Responsible: Vice President of Business & Finance, the Registrars Office and the Director of Student
Financial Aid.
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
Federal Award Findings and Questioned Costs
June 30, 2023
Comment #2023-004
PROCEDURES GOVERNING THE RECONCILIATION AND MANAGEMENT
OF FEDERAL PROGRAMS SHOULD BE IMPROVED
HIGHER EDUCATION EMERGENCY RELIEF FUND
HIGHER EDUCATIONAL INSTITUTIONAL AID
STRENGTHENING MINORITY-SERVING INSTITUTIONS
U.S. DEPARTMENT OF EDUCATION
ALN# 84.031B and E, 84.382G, 84.425T
(Questioned Costs - None)
(Repeat 2022-004)
Condition:
Good internal controls over the receipt of federal funds require the reconciliation of authorized and recorded
disbursements of cash drawn from the federal cash management system. This process ensures that federal funds are
properly earned by the University and the University has not made a disbursement for which it has not been funded.
During our audit, we noted that the University made efforts to reconcile its program activity under the COVID-19 Higher
Education Emergency Relief Funds (American Rescue Plan - HEERF-III), Higher Educational Institutional Aid (Title
III), and Strengthening Minority-Serving Institutions. However, we did not see evidence that the reconciliation of
HEERF funding and Title III program activity is performed regularly as part of the University’s monthly and annual
close-out. As a result, we noted the following:
• The proper reconciliation of funds disbursed as allowed by the HEERF III program requires reconciliation of
the funds drawn and disbursed for each assistant listing portion (1) a reconciliation of funds disbursed to
students directly (student aid portion) and funds disbursed for other allowable expenditures to the general
ledger, (2) a reconciliation to the disbursement for general operating purposes and loss revenue to the approved
and documented methodology and the general ledger accounts and (3) all funds requested via the G-5 reports
should be accurately reconciled to the general ledger and to the various detail reports supporting the
disbursements. The reconciliations should be summarized and reported quarterly and annually as required by
the CARES Act (See HEERF Reporting web page).
• Financial statement adjustments were needed to properly recognize the cash balance for the Title III program,
Strengthening Minority-Serving Institutions. The reconciliation process, as outlined in the internal control
procedures is not performed in a timely manner.
Context:
Review of cash management procedures related to the HEERF and Title III-Strengthening Minority-Serving Institutions.
Criteria:
Standards for financial management systems [2 CFR §215.21] and CARES Act 18004 (ARP).
Effect:
The effect is that unresolved balances could represent excess cash due back to the U.S. Department of Education, or not
receipting funds that are due to the University for students who have obtained their education. The failure to not meeting
he three components of reporting for HEERF as required by the CARES Act and ARP.
63
WILBERFORCE UNIVERSITY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
Federal Award Findings and Questioned Costs
June 30, 2023
Comment #2023-004
PROCEDURES GOVERNING THE RECONCILIATION AND MANAGEMENT
OF FEDERAL PROGRAMS SHOULD BE IMPROVED
STUDENT FINANCIAL AID CLUSTER PROGRAM
HIGHER EDUCATIONAL INSTITUTIONAL AID
STRENGTHENING MINORITY-SERVING INSTITUTIONS
U.S. DEPARTMENT OF EDUCATION
ALN# 84.031B and E, 84.382G, 84.425T
(Questioned Costs - None)
(Repeat 2022-004)
(Continued)
Cause:
Weaknesses in procedures over reconciliation of grant activity.
Recommendation:
We recommend that management implement procedures to ensure that federal program activity is reconciled on a
monthly basis for all open award years. This process should be coordinated between all affected departments (i.e.,
Grants and Contracts, Accounting Department, Student Financial Aid, etc.). The reconciled amounts should properly
reflect amounts due to or from the U.S. Department of Education on the University’s general ledger accounting system.
The reconciliations should be reviewed by a responsible official of the University. Monitoring of such reconciliation
and the reporting requirements should be evidenced by internal control procedures and proper documentation of
authorization.
Views of Responsible Officials and Planned Corrective Actions:
We concur with the auditor’s finding. The University has engaged a third party to review the reconciliation procedures
and to make recommendations on improvements to our current policy. The recommendations will also include any
additional documentation that showing proof that the reconciliation has been completed as timely as required. The Vice
President of Business & Finance and the Director of Student Financial Aid will review the reconciliations. Monitoring
reports will be completed and shared with senior management and relevant department leaders.
Implementation date: Immediately.
Persons Responsible: Vice President of Business & Finance, Controller and Director of Student Financial Aid.
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
Federal Award Findings and Questioned Costs
June 30, 2023
Comment #2023-004
PROCEDURES GOVERNING THE RECONCILIATION AND MANAGEMENT
OF FEDERAL PROGRAMS SHOULD BE IMPROVED
HIGHER EDUCATION EMERGENCY RELIEF FUND
HIGHER EDUCATIONAL INSTITUTIONAL AID
STRENGTHENING MINORITY-SERVING INSTITUTIONS
U.S. DEPARTMENT OF EDUCATION
ALN# 84.031B and E, 84.382G, 84.425T
(Questioned Costs - None)
(Repeat 2022-004)
Condition:
Good internal controls over the receipt of federal funds require the reconciliation of authorized and recorded
disbursements of cash drawn from the federal cash management system. This process ensures that federal funds are
properly earned by the University and the University has not made a disbursement for which it has not been funded.
During our audit, we noted that the University made efforts to reconcile its program activity under the COVID-19 Higher
Education Emergency Relief Funds (American Rescue Plan - HEERF-III), Higher Educational Institutional Aid (Title
III), and Strengthening Minority-Serving Institutions. However, we did not see evidence that the reconciliation of
HEERF funding and Title III program activity is performed regularly as part of the University’s monthly and annual
close-out. As a result, we noted the following:
• The proper reconciliation of funds disbursed as allowed by the HEERF III program requires reconciliation of
the funds drawn and disbursed for each assistant listing portion (1) a reconciliation of funds disbursed to
students directly (student aid portion) and funds disbursed for other allowable expenditures to the general
ledger, (2) a reconciliation to the disbursement for general operating purposes and loss revenue to the approved
and documented methodology and the general ledger accounts and (3) all funds requested via the G-5 reports
should be accurately reconciled to the general ledger and to the various detail reports supporting the
disbursements. The reconciliations should be summarized and reported quarterly and annually as required by
the CARES Act (See HEERF Reporting web page).
• Financial statement adjustments were needed to properly recognize the cash balance for the Title III program,
Strengthening Minority-Serving Institutions. The reconciliation process, as outlined in the internal control
procedures is not performed in a timely manner.
Context:
Review of cash management procedures related to the HEERF and Title III-Strengthening Minority-Serving Institutions.
Criteria:
Standards for financial management systems [2 CFR §215.21] and CARES Act 18004 (ARP).
Effect:
The effect is that unresolved balances could represent excess cash due back to the U.S. Department of Education, or not
receipting funds that are due to the University for students who have obtained their education. The failure to not meeting
he three components of reporting for HEERF as required by the CARES Act and ARP.
63
WILBERFORCE UNIVERSITY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
Federal Award Findings and Questioned Costs
June 30, 2023
Comment #2023-004
PROCEDURES GOVERNING THE RECONCILIATION AND MANAGEMENT
OF FEDERAL PROGRAMS SHOULD BE IMPROVED
STUDENT FINANCIAL AID CLUSTER PROGRAM
HIGHER EDUCATIONAL INSTITUTIONAL AID
STRENGTHENING MINORITY-SERVING INSTITUTIONS
U.S. DEPARTMENT OF EDUCATION
ALN# 84.031B and E, 84.382G, 84.425T
(Questioned Costs - None)
(Repeat 2022-004)
(Continued)
Cause:
Weaknesses in procedures over reconciliation of grant activity.
Recommendation:
We recommend that management implement procedures to ensure that federal program activity is reconciled on a
monthly basis for all open award years. This process should be coordinated between all affected departments (i.e.,
Grants and Contracts, Accounting Department, Student Financial Aid, etc.). The reconciled amounts should properly
reflect amounts due to or from the U.S. Department of Education on the University’s general ledger accounting system.
The reconciliations should be reviewed by a responsible official of the University. Monitoring of such reconciliation
and the reporting requirements should be evidenced by internal control procedures and proper documentation of
authorization.
Views of Responsible Officials and Planned Corrective Actions:
We concur with the auditor’s finding. The University has engaged a third party to review the reconciliation procedures
and to make recommendations on improvements to our current policy. The recommendations will also include any
additional documentation that showing proof that the reconciliation has been completed as timely as required. The Vice
President of Business & Finance and the Director of Student Financial Aid will review the reconciliations. Monitoring
reports will be completed and shared with senior management and relevant department leaders.
Implementation date: Immediately.
Persons Responsible: Vice President of Business & Finance, Controller and Director of Student Financial Aid.
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
Federal Award Findings and Questioned Costs
June 30, 2023
Comment #2023-004
PROCEDURES GOVERNING THE RECONCILIATION AND MANAGEMENT
OF FEDERAL PROGRAMS SHOULD BE IMPROVED
HIGHER EDUCATION EMERGENCY RELIEF FUND
HIGHER EDUCATIONAL INSTITUTIONAL AID
STRENGTHENING MINORITY-SERVING INSTITUTIONS
U.S. DEPARTMENT OF EDUCATION
ALN# 84.031B and E, 84.382G, 84.425T
(Questioned Costs - None)
(Repeat 2022-004)
Condition:
Good internal controls over the receipt of federal funds require the reconciliation of authorized and recorded
disbursements of cash drawn from the federal cash management system. This process ensures that federal funds are
properly earned by the University and the University has not made a disbursement for which it has not been funded.
During our audit, we noted that the University made efforts to reconcile its program activity under the COVID-19 Higher
Education Emergency Relief Funds (American Rescue Plan - HEERF-III), Higher Educational Institutional Aid (Title
III), and Strengthening Minority-Serving Institutions. However, we did not see evidence that the reconciliation of
HEERF funding and Title III program activity is performed regularly as part of the University’s monthly and annual
close-out. As a result, we noted the following:
• The proper reconciliation of funds disbursed as allowed by the HEERF III program requires reconciliation of
the funds drawn and disbursed for each assistant listing portion (1) a reconciliation of funds disbursed to
students directly (student aid portion) and funds disbursed for other allowable expenditures to the general
ledger, (2) a reconciliation to the disbursement for general operating purposes and loss revenue to the approved
and documented methodology and the general ledger accounts and (3) all funds requested via the G-5 reports
should be accurately reconciled to the general ledger and to the various detail reports supporting the
disbursements. The reconciliations should be summarized and reported quarterly and annually as required by
the CARES Act (See HEERF Reporting web page).
• Financial statement adjustments were needed to properly recognize the cash balance for the Title III program,
Strengthening Minority-Serving Institutions. The reconciliation process, as outlined in the internal control
procedures is not performed in a timely manner.
Context:
Review of cash management procedures related to the HEERF and Title III-Strengthening Minority-Serving Institutions.
Criteria:
Standards for financial management systems [2 CFR §215.21] and CARES Act 18004 (ARP).
Effect:
The effect is that unresolved balances could represent excess cash due back to the U.S. Department of Education, or not
receipting funds that are due to the University for students who have obtained their education. The failure to not meeting
he three components of reporting for HEERF as required by the CARES Act and ARP.
63
WILBERFORCE UNIVERSITY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
Federal Award Findings and Questioned Costs
June 30, 2023
Comment #2023-004
PROCEDURES GOVERNING THE RECONCILIATION AND MANAGEMENT
OF FEDERAL PROGRAMS SHOULD BE IMPROVED
STUDENT FINANCIAL AID CLUSTER PROGRAM
HIGHER EDUCATIONAL INSTITUTIONAL AID
STRENGTHENING MINORITY-SERVING INSTITUTIONS
U.S. DEPARTMENT OF EDUCATION
ALN# 84.031B and E, 84.382G, 84.425T
(Questioned Costs - None)
(Repeat 2022-004)
(Continued)
Cause:
Weaknesses in procedures over reconciliation of grant activity.
Recommendation:
We recommend that management implement procedures to ensure that federal program activity is reconciled on a
monthly basis for all open award years. This process should be coordinated between all affected departments (i.e.,
Grants and Contracts, Accounting Department, Student Financial Aid, etc.). The reconciled amounts should properly
reflect amounts due to or from the U.S. Department of Education on the University’s general ledger accounting system.
The reconciliations should be reviewed by a responsible official of the University. Monitoring of such reconciliation
and the reporting requirements should be evidenced by internal control procedures and proper documentation of
authorization.
Views of Responsible Officials and Planned Corrective Actions:
We concur with the auditor’s finding. The University has engaged a third party to review the reconciliation procedures
and to make recommendations on improvements to our current policy. The recommendations will also include any
additional documentation that showing proof that the reconciliation has been completed as timely as required. The Vice
President of Business & Finance and the Director of Student Financial Aid will review the reconciliations. Monitoring
reports will be completed and shared with senior management and relevant department leaders.
Implementation date: Immediately.
Persons Responsible: Vice President of Business & Finance, Controller and Director of Student Financial Aid.
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
Federal Award Findings and Questioned Costs
June 30, 2023
Comment #2023-004
PROCEDURES GOVERNING THE RECONCILIATION AND MANAGEMENT
OF FEDERAL PROGRAMS SHOULD BE IMPROVED
HIGHER EDUCATION EMERGENCY RELIEF FUND
HIGHER EDUCATIONAL INSTITUTIONAL AID
STRENGTHENING MINORITY-SERVING INSTITUTIONS
U.S. DEPARTMENT OF EDUCATION
ALN# 84.031B and E, 84.382G, 84.425T
(Questioned Costs - None)
(Repeat 2022-004)
Condition:
Good internal controls over the receipt of federal funds require the reconciliation of authorized and recorded
disbursements of cash drawn from the federal cash management system. This process ensures that federal funds are
properly earned by the University and the University has not made a disbursement for which it has not been funded.
During our audit, we noted that the University made efforts to reconcile its program activity under the COVID-19 Higher
Education Emergency Relief Funds (American Rescue Plan - HEERF-III), Higher Educational Institutional Aid (Title
III), and Strengthening Minority-Serving Institutions. However, we did not see evidence that the reconciliation of
HEERF funding and Title III program activity is performed regularly as part of the University’s monthly and annual
close-out. As a result, we noted the following:
• The proper reconciliation of funds disbursed as allowed by the HEERF III program requires reconciliation of
the funds drawn and disbursed for each assistant listing portion (1) a reconciliation of funds disbursed to
students directly (student aid portion) and funds disbursed for other allowable expenditures to the general
ledger, (2) a reconciliation to the disbursement for general operating purposes and loss revenue to the approved
and documented methodology and the general ledger accounts and (3) all funds requested via the G-5 reports
should be accurately reconciled to the general ledger and to the various detail reports supporting the
disbursements. The reconciliations should be summarized and reported quarterly and annually as required by
the CARES Act (See HEERF Reporting web page).
• Financial statement adjustments were needed to properly recognize the cash balance for the Title III program,
Strengthening Minority-Serving Institutions. The reconciliation process, as outlined in the internal control
procedures is not performed in a timely manner.
Context:
Review of cash management procedures related to the HEERF and Title III-Strengthening Minority-Serving Institutions.
Criteria:
Standards for financial management systems [2 CFR §215.21] and CARES Act 18004 (ARP).
Effect:
The effect is that unresolved balances could represent excess cash due back to the U.S. Department of Education, or not
receipting funds that are due to the University for students who have obtained their education. The failure to not meeting
he three components of reporting for HEERF as required by the CARES Act and ARP.
63
WILBERFORCE UNIVERSITY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
Federal Award Findings and Questioned Costs
June 30, 2023
Comment #2023-004
PROCEDURES GOVERNING THE RECONCILIATION AND MANAGEMENT
OF FEDERAL PROGRAMS SHOULD BE IMPROVED
STUDENT FINANCIAL AID CLUSTER PROGRAM
HIGHER EDUCATIONAL INSTITUTIONAL AID
STRENGTHENING MINORITY-SERVING INSTITUTIONS
U.S. DEPARTMENT OF EDUCATION
ALN# 84.031B and E, 84.382G, 84.425T
(Questioned Costs - None)
(Repeat 2022-004)
(Continued)
Cause:
Weaknesses in procedures over reconciliation of grant activity.
Recommendation:
We recommend that management implement procedures to ensure that federal program activity is reconciled on a
monthly basis for all open award years. This process should be coordinated between all affected departments (i.e.,
Grants and Contracts, Accounting Department, Student Financial Aid, etc.). The reconciled amounts should properly
reflect amounts due to or from the U.S. Department of Education on the University’s general ledger accounting system.
The reconciliations should be reviewed by a responsible official of the University. Monitoring of such reconciliation
and the reporting requirements should be evidenced by internal control procedures and proper documentation of
authorization.
Views of Responsible Officials and Planned Corrective Actions:
We concur with the auditor’s finding. The University has engaged a third party to review the reconciliation procedures
and to make recommendations on improvements to our current policy. The recommendations will also include any
additional documentation that showing proof that the reconciliation has been completed as timely as required. The Vice
President of Business & Finance and the Director of Student Financial Aid will review the reconciliations. Monitoring
reports will be completed and shared with senior management and relevant department leaders.
Implementation date: Immediately.
Persons Responsible: Vice President of Business & Finance, Controller and Director of Student Financial Aid.
SCHEDULE OF FINDINGS AND QUESTIONED COSTS AND CORRECTIVE ACTION PLAN
Federal Award Findings and Questioned Costs
June 30, 2023
Comment 2023-005
ENROLLMENT REPORTING PROCEDURES SHOULD BE STRENGTHENED
STUDENT FINANCIAL AID CLUSTER PROGRAM
CFDA # 84.268
(Questioned Costs - None)
Condition:
When the Registrar’s Office discovers that a student did not enroll or ceased to be enrolled on at least a half-time basis,
the National Student Loan Data System (NSLDS) should be notified of the change in the student’s enrollment status
within thirty days of the occurrence, unless the Institution expects to complete its next scheduled filing within sixty days.
During our audit, we noted three (3) instances in which student status changes were reported more than sixty (60) days
after the occurrence.
Context:
A haphazard selection of ten (10) students was made from the list of student withdrawals and graduates during the year.
Criteria:
Federal regulations require the Institution to notify the NSLDS of a change in student status (i.e., withdrawn, graduated,
enrolled less than half-time, etc.). Unless the Institution expects to complete its next filing within sixty days, the
Institution must notify the NSLDS within thirty days if it discovers a student with an outstanding federal loan balance
has ceased to be enrolled on at least a half-time basis. [34 CFR 685.309]
Effect:
The lender or guaranty agency is not receiving prompt notification of changes in borrower’s enrollment status. This
results in delayed processing of loan repayment periods and leads to poor default management. Late or incorrect updates
to the NSLDS may also cause students to receive loans for which they are not eligible, as half-time enrollment is a
requirement for Federal Direct Loan (FDL) eligibility.
Cause:
Necessary withdrawal documentation is not consistently processed and forwarded to appropriate departments in a timely
manner to ensure reports are accurately filed as scheduled. Overall, there is an inadequate process of verifying the
enrollment status of students.
Recommendation:
The Institution should implement procedures to ensure compliance with federal regulations. The Registrar’s Office
should obtain a complete understanding of the NSLDS reporting requirements. Improving the accuracy and timeliness
of student status filings will aid in the transition of students to loan repayment status.
Views of Responsible Officials and Planned Corrective Actions:
Management agrees with the auditors and has initiated the necessary corrective action plan to mitigate the deficiency
from occurring again. The plan is to implement new procedures to ensure the reporting to the NSLDS is done on a
timely basis.
Implementation date: Immediately.
Persons Responsible: Vice President of Business & Finance, the Registrars Office and the Director of Student
Financial Aid.
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
Federal Award Findings and Questioned Costs
June 30, 2023
Comment #2023-004
PROCEDURES GOVERNING THE RECONCILIATION AND MANAGEMENT
OF FEDERAL PROGRAMS SHOULD BE IMPROVED
HIGHER EDUCATION EMERGENCY RELIEF FUND
HIGHER EDUCATIONAL INSTITUTIONAL AID
STRENGTHENING MINORITY-SERVING INSTITUTIONS
U.S. DEPARTMENT OF EDUCATION
ALN# 84.031B and E, 84.382G, 84.425T
(Questioned Costs - None)
(Repeat 2022-004)
Condition:
Good internal controls over the receipt of federal funds require the reconciliation of authorized and recorded
disbursements of cash drawn from the federal cash management system. This process ensures that federal funds are
properly earned by the University and the University has not made a disbursement for which it has not been funded.
During our audit, we noted that the University made efforts to reconcile its program activity under the COVID-19 Higher
Education Emergency Relief Funds (American Rescue Plan - HEERF-III), Higher Educational Institutional Aid (Title
III), and Strengthening Minority-Serving Institutions. However, we did not see evidence that the reconciliation of
HEERF funding and Title III program activity is performed regularly as part of the University’s monthly and annual
close-out. As a result, we noted the following:
• The proper reconciliation of funds disbursed as allowed by the HEERF III program requires reconciliation of
the funds drawn and disbursed for each assistant listing portion (1) a reconciliation of funds disbursed to
students directly (student aid portion) and funds disbursed for other allowable expenditures to the general
ledger, (2) a reconciliation to the disbursement for general operating purposes and loss revenue to the approved
and documented methodology and the general ledger accounts and (3) all funds requested via the G-5 reports
should be accurately reconciled to the general ledger and to the various detail reports supporting the
disbursements. The reconciliations should be summarized and reported quarterly and annually as required by
the CARES Act (See HEERF Reporting web page).
• Financial statement adjustments were needed to properly recognize the cash balance for the Title III program,
Strengthening Minority-Serving Institutions. The reconciliation process, as outlined in the internal control
procedures is not performed in a timely manner.
Context:
Review of cash management procedures related to the HEERF and Title III-Strengthening Minority-Serving Institutions.
Criteria:
Standards for financial management systems [2 CFR §215.21] and CARES Act 18004 (ARP).
Effect:
The effect is that unresolved balances could represent excess cash due back to the U.S. Department of Education, or not
receipting funds that are due to the University for students who have obtained their education. The failure to not meeting
he three components of reporting for HEERF as required by the CARES Act and ARP.
63
WILBERFORCE UNIVERSITY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
Federal Award Findings and Questioned Costs
June 30, 2023
Comment #2023-004
PROCEDURES GOVERNING THE RECONCILIATION AND MANAGEMENT
OF FEDERAL PROGRAMS SHOULD BE IMPROVED
STUDENT FINANCIAL AID CLUSTER PROGRAM
HIGHER EDUCATIONAL INSTITUTIONAL AID
STRENGTHENING MINORITY-SERVING INSTITUTIONS
U.S. DEPARTMENT OF EDUCATION
ALN# 84.031B and E, 84.382G, 84.425T
(Questioned Costs - None)
(Repeat 2022-004)
(Continued)
Cause:
Weaknesses in procedures over reconciliation of grant activity.
Recommendation:
We recommend that management implement procedures to ensure that federal program activity is reconciled on a
monthly basis for all open award years. This process should be coordinated between all affected departments (i.e.,
Grants and Contracts, Accounting Department, Student Financial Aid, etc.). The reconciled amounts should properly
reflect amounts due to or from the U.S. Department of Education on the University’s general ledger accounting system.
The reconciliations should be reviewed by a responsible official of the University. Monitoring of such reconciliation
and the reporting requirements should be evidenced by internal control procedures and proper documentation of
authorization.
Views of Responsible Officials and Planned Corrective Actions:
We concur with the auditor’s finding. The University has engaged a third party to review the reconciliation procedures
and to make recommendations on improvements to our current policy. The recommendations will also include any
additional documentation that showing proof that the reconciliation has been completed as timely as required. The Vice
President of Business & Finance and the Director of Student Financial Aid will review the reconciliations. Monitoring
reports will be completed and shared with senior management and relevant department leaders.
Implementation date: Immediately.
Persons Responsible: Vice President of Business & Finance, Controller and Director of Student Financial Aid.
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
Federal Award Findings and Questioned Costs
June 30, 2023
Comment #2023-004
PROCEDURES GOVERNING THE RECONCILIATION AND MANAGEMENT
OF FEDERAL PROGRAMS SHOULD BE IMPROVED
HIGHER EDUCATION EMERGENCY RELIEF FUND
HIGHER EDUCATIONAL INSTITUTIONAL AID
STRENGTHENING MINORITY-SERVING INSTITUTIONS
U.S. DEPARTMENT OF EDUCATION
ALN# 84.031B and E, 84.382G, 84.425T
(Questioned Costs - None)
(Repeat 2022-004)
Condition:
Good internal controls over the receipt of federal funds require the reconciliation of authorized and recorded
disbursements of cash drawn from the federal cash management system. This process ensures that federal funds are
properly earned by the University and the University has not made a disbursement for which it has not been funded.
During our audit, we noted that the University made efforts to reconcile its program activity under the COVID-19 Higher
Education Emergency Relief Funds (American Rescue Plan - HEERF-III), Higher Educational Institutional Aid (Title
III), and Strengthening Minority-Serving Institutions. However, we did not see evidence that the reconciliation of
HEERF funding and Title III program activity is performed regularly as part of the University’s monthly and annual
close-out. As a result, we noted the following:
• The proper reconciliation of funds disbursed as allowed by the HEERF III program requires reconciliation of
the funds drawn and disbursed for each assistant listing portion (1) a reconciliation of funds disbursed to
students directly (student aid portion) and funds disbursed for other allowable expenditures to the general
ledger, (2) a reconciliation to the disbursement for general operating purposes and loss revenue to the approved
and documented methodology and the general ledger accounts and (3) all funds requested via the G-5 reports
should be accurately reconciled to the general ledger and to the various detail reports supporting the
disbursements. The reconciliations should be summarized and reported quarterly and annually as required by
the CARES Act (See HEERF Reporting web page).
• Financial statement adjustments were needed to properly recognize the cash balance for the Title III program,
Strengthening Minority-Serving Institutions. The reconciliation process, as outlined in the internal control
procedures is not performed in a timely manner.
Context:
Review of cash management procedures related to the HEERF and Title III-Strengthening Minority-Serving Institutions.
Criteria:
Standards for financial management systems [2 CFR §215.21] and CARES Act 18004 (ARP).
Effect:
The effect is that unresolved balances could represent excess cash due back to the U.S. Department of Education, or not
receipting funds that are due to the University for students who have obtained their education. The failure to not meeting
he three components of reporting for HEERF as required by the CARES Act and ARP.
63
WILBERFORCE UNIVERSITY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
Federal Award Findings and Questioned Costs
June 30, 2023
Comment #2023-004
PROCEDURES GOVERNING THE RECONCILIATION AND MANAGEMENT
OF FEDERAL PROGRAMS SHOULD BE IMPROVED
STUDENT FINANCIAL AID CLUSTER PROGRAM
HIGHER EDUCATIONAL INSTITUTIONAL AID
STRENGTHENING MINORITY-SERVING INSTITUTIONS
U.S. DEPARTMENT OF EDUCATION
ALN# 84.031B and E, 84.382G, 84.425T
(Questioned Costs - None)
(Repeat 2022-004)
(Continued)
Cause:
Weaknesses in procedures over reconciliation of grant activity.
Recommendation:
We recommend that management implement procedures to ensure that federal program activity is reconciled on a
monthly basis for all open award years. This process should be coordinated between all affected departments (i.e.,
Grants and Contracts, Accounting Department, Student Financial Aid, etc.). The reconciled amounts should properly
reflect amounts due to or from the U.S. Department of Education on the University’s general ledger accounting system.
The reconciliations should be reviewed by a responsible official of the University. Monitoring of such reconciliation
and the reporting requirements should be evidenced by internal control procedures and proper documentation of
authorization.
Views of Responsible Officials and Planned Corrective Actions:
We concur with the auditor’s finding. The University has engaged a third party to review the reconciliation procedures
and to make recommendations on improvements to our current policy. The recommendations will also include any
additional documentation that showing proof that the reconciliation has been completed as timely as required. The Vice
President of Business & Finance and the Director of Student Financial Aid will review the reconciliations. Monitoring
reports will be completed and shared with senior management and relevant department leaders.
Implementation date: Immediately.
Persons Responsible: Vice President of Business & Finance, Controller and Director of Student Financial Aid.
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
Federal Award Findings and Questioned Costs
June 30, 2023
Comment #2023-004
PROCEDURES GOVERNING THE RECONCILIATION AND MANAGEMENT
OF FEDERAL PROGRAMS SHOULD BE IMPROVED
HIGHER EDUCATION EMERGENCY RELIEF FUND
HIGHER EDUCATIONAL INSTITUTIONAL AID
STRENGTHENING MINORITY-SERVING INSTITUTIONS
U.S. DEPARTMENT OF EDUCATION
ALN# 84.031B and E, 84.382G, 84.425T
(Questioned Costs - None)
(Repeat 2022-004)
Condition:
Good internal controls over the receipt of federal funds require the reconciliation of authorized and recorded
disbursements of cash drawn from the federal cash management system. This process ensures that federal funds are
properly earned by the University and the University has not made a disbursement for which it has not been funded.
During our audit, we noted that the University made efforts to reconcile its program activity under the COVID-19 Higher
Education Emergency Relief Funds (American Rescue Plan - HEERF-III), Higher Educational Institutional Aid (Title
III), and Strengthening Minority-Serving Institutions. However, we did not see evidence that the reconciliation of
HEERF funding and Title III program activity is performed regularly as part of the University’s monthly and annual
close-out. As a result, we noted the following:
• The proper reconciliation of funds disbursed as allowed by the HEERF III program requires reconciliation of
the funds drawn and disbursed for each assistant listing portion (1) a reconciliation of funds disbursed to
students directly (student aid portion) and funds disbursed for other allowable expenditures to the general
ledger, (2) a reconciliation to the disbursement for general operating purposes and loss revenue to the approved
and documented methodology and the general ledger accounts and (3) all funds requested via the G-5 reports
should be accurately reconciled to the general ledger and to the various detail reports supporting the
disbursements. The reconciliations should be summarized and reported quarterly and annually as required by
the CARES Act (See HEERF Reporting web page).
• Financial statement adjustments were needed to properly recognize the cash balance for the Title III program,
Strengthening Minority-Serving Institutions. The reconciliation process, as outlined in the internal control
procedures is not performed in a timely manner.
Context:
Review of cash management procedures related to the HEERF and Title III-Strengthening Minority-Serving Institutions.
Criteria:
Standards for financial management systems [2 CFR §215.21] and CARES Act 18004 (ARP).
Effect:
The effect is that unresolved balances could represent excess cash due back to the U.S. Department of Education, or not
receipting funds that are due to the University for students who have obtained their education. The failure to not meeting
he three components of reporting for HEERF as required by the CARES Act and ARP.
63
WILBERFORCE UNIVERSITY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
Federal Award Findings and Questioned Costs
June 30, 2023
Comment #2023-004
PROCEDURES GOVERNING THE RECONCILIATION AND MANAGEMENT
OF FEDERAL PROGRAMS SHOULD BE IMPROVED
STUDENT FINANCIAL AID CLUSTER PROGRAM
HIGHER EDUCATIONAL INSTITUTIONAL AID
STRENGTHENING MINORITY-SERVING INSTITUTIONS
U.S. DEPARTMENT OF EDUCATION
ALN# 84.031B and E, 84.382G, 84.425T
(Questioned Costs - None)
(Repeat 2022-004)
(Continued)
Cause:
Weaknesses in procedures over reconciliation of grant activity.
Recommendation:
We recommend that management implement procedures to ensure that federal program activity is reconciled on a
monthly basis for all open award years. This process should be coordinated between all affected departments (i.e.,
Grants and Contracts, Accounting Department, Student Financial Aid, etc.). The reconciled amounts should properly
reflect amounts due to or from the U.S. Department of Education on the University’s general ledger accounting system.
The reconciliations should be reviewed by a responsible official of the University. Monitoring of such reconciliation
and the reporting requirements should be evidenced by internal control procedures and proper documentation of
authorization.
Views of Responsible Officials and Planned Corrective Actions:
We concur with the auditor’s finding. The University has engaged a third party to review the reconciliation procedures
and to make recommendations on improvements to our current policy. The recommendations will also include any
additional documentation that showing proof that the reconciliation has been completed as timely as required. The Vice
President of Business & Finance and the Director of Student Financial Aid will review the reconciliations. Monitoring
reports will be completed and shared with senior management and relevant department leaders.
Implementation date: Immediately.
Persons Responsible: Vice President of Business & Finance, Controller and Director of Student Financial Aid.
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
Federal Award Findings and Questioned Costs
June 30, 2023
Comment #2023-004
PROCEDURES GOVERNING THE RECONCILIATION AND MANAGEMENT
OF FEDERAL PROGRAMS SHOULD BE IMPROVED
HIGHER EDUCATION EMERGENCY RELIEF FUND
HIGHER EDUCATIONAL INSTITUTIONAL AID
STRENGTHENING MINORITY-SERVING INSTITUTIONS
U.S. DEPARTMENT OF EDUCATION
ALN# 84.031B and E, 84.382G, 84.425T
(Questioned Costs - None)
(Repeat 2022-004)
Condition:
Good internal controls over the receipt of federal funds require the reconciliation of authorized and recorded
disbursements of cash drawn from the federal cash management system. This process ensures that federal funds are
properly earned by the University and the University has not made a disbursement for which it has not been funded.
During our audit, we noted that the University made efforts to reconcile its program activity under the COVID-19 Higher
Education Emergency Relief Funds (American Rescue Plan - HEERF-III), Higher Educational Institutional Aid (Title
III), and Strengthening Minority-Serving Institutions. However, we did not see evidence that the reconciliation of
HEERF funding and Title III program activity is performed regularly as part of the University’s monthly and annual
close-out. As a result, we noted the following:
• The proper reconciliation of funds disbursed as allowed by the HEERF III program requires reconciliation of
the funds drawn and disbursed for each assistant listing portion (1) a reconciliation of funds disbursed to
students directly (student aid portion) and funds disbursed for other allowable expenditures to the general
ledger, (2) a reconciliation to the disbursement for general operating purposes and loss revenue to the approved
and documented methodology and the general ledger accounts and (3) all funds requested via the G-5 reports
should be accurately reconciled to the general ledger and to the various detail reports supporting the
disbursements. The reconciliations should be summarized and reported quarterly and annually as required by
the CARES Act (See HEERF Reporting web page).
• Financial statement adjustments were needed to properly recognize the cash balance for the Title III program,
Strengthening Minority-Serving Institutions. The reconciliation process, as outlined in the internal control
procedures is not performed in a timely manner.
Context:
Review of cash management procedures related to the HEERF and Title III-Strengthening Minority-Serving Institutions.
Criteria:
Standards for financial management systems [2 CFR §215.21] and CARES Act 18004 (ARP).
Effect:
The effect is that unresolved balances could represent excess cash due back to the U.S. Department of Education, or not
receipting funds that are due to the University for students who have obtained their education. The failure to not meeting
he three components of reporting for HEERF as required by the CARES Act and ARP.
63
WILBERFORCE UNIVERSITY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
Federal Award Findings and Questioned Costs
June 30, 2023
Comment #2023-004
PROCEDURES GOVERNING THE RECONCILIATION AND MANAGEMENT
OF FEDERAL PROGRAMS SHOULD BE IMPROVED
STUDENT FINANCIAL AID CLUSTER PROGRAM
HIGHER EDUCATIONAL INSTITUTIONAL AID
STRENGTHENING MINORITY-SERVING INSTITUTIONS
U.S. DEPARTMENT OF EDUCATION
ALN# 84.031B and E, 84.382G, 84.425T
(Questioned Costs - None)
(Repeat 2022-004)
(Continued)
Cause:
Weaknesses in procedures over reconciliation of grant activity.
Recommendation:
We recommend that management implement procedures to ensure that federal program activity is reconciled on a
monthly basis for all open award years. This process should be coordinated between all affected departments (i.e.,
Grants and Contracts, Accounting Department, Student Financial Aid, etc.). The reconciled amounts should properly
reflect amounts due to or from the U.S. Department of Education on the University’s general ledger accounting system.
The reconciliations should be reviewed by a responsible official of the University. Monitoring of such reconciliation
and the reporting requirements should be evidenced by internal control procedures and proper documentation of
authorization.
Views of Responsible Officials and Planned Corrective Actions:
We concur with the auditor’s finding. The University has engaged a third party to review the reconciliation procedures
and to make recommendations on improvements to our current policy. The recommendations will also include any
additional documentation that showing proof that the reconciliation has been completed as timely as required. The Vice
President of Business & Finance and the Director of Student Financial Aid will review the reconciliations. Monitoring
reports will be completed and shared with senior management and relevant department leaders.
Implementation date: Immediately.
Persons Responsible: Vice President of Business & Finance, Controller and Director of Student Financial Aid.