Audit 302075

Federal Program Information: Higher Education Institutional Aid: Strengthening Historically Black Colleges and Universities Program (“Title III”) (ALN: 84.031B and 84.031E) and TRIO Cluster (“TRIO”) (ALN: 84.047A, 84.042A and 84.217A) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): A. Activities Allowed or Unallowed/N. Special Tests and Provisions – Per 2 Code of Federal Regulation (“CFR”) Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities as well as facilities and administration (“F&A”) cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. For after-the-fact activity records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included); (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. B. Allowable Costs and Cost Principles - In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles. G. Level of Effort - Level of effort includes requirements for (a) a specified level of service to be provided from period to period and (b) a specified level of expenditures from nonfederal or federal sources for specified activities to be maintained from period to period. Only allowable categories of expenditures or other effort indicators (e.g., hours, number of people served) should be included in the computation and expenditures categories should be consistent from year to year. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Additionally, for certain payroll and non-payroll expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. Cause: Insufficient administrative oversight and internal controls with respect to the University’s administration of federal awards in accordance with certain compliance requirements. Effect or Potential Effect: The University was unable to support certain amounts charged to federal awards and effort certifications supporting certain payroll costs charged to federal awards were not completed timely and/or appropriately monitored during the year. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions during our testing: • For 4 of 15 non-payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting that the expenditure was appropriately approved prior to the disbursement of funds. • For 1 of 15 non-payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 2 of 10 payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 5 of 8 Title III employees selected for testing, time and effort reports certified by the employee could not be provided and/or did not support the amount charged to the federal award. • For 2 of 12 months selected for testing, the University did not obtain a level of effort certification for the Title III program director. • For 1 of 10 non-payroll TRIO expenditures selected for testing, the University was unable to provide documentation supporting that the expenditure was appropriately approved prior to the disbursement of funds. • For 1 of 15 payroll TRIO expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 10 of 10 TRIO Program employees selected for testing, time and effort reports certified by the employee could not be provided and/or did not support the amount charged to the federal award. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University has appropriate and formal documentation to support federal expenditures as required, as well as appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: The University experienced turnover of key positions throughout campus, particularly in the Division of Finance, Government Sponsored Programs and various federally funds programs. The changes in staffing lead to a loss of institutional knowledge, and interrupted policy and process enforcement campus wide. The Office of Government Sponsored Programs (“GSPAR”) will enhance its internal controls, policies and procedures to ensure the appropriate documentation to support is maintained, and to ensure that level of effort is appropriately documented and reported. GSPAR will be working in conjunction with the Office of Human Resources, including Payroll, to ensure accuracy, or timely correction, of general ledger postings. In addition, the grant onboarding process will be revised to emphasize key federal regulations and emphasize the importance of compliance. Reminders will also be provided during GSPAR’s semi-annual grant compliance workshops.

Federal Program Information: Higher Education Institutional Aid: Strengthening Historically Black Colleges and Universities Program (“Title III”) (ALN: 84.031B and 84.031E) and TRIO Cluster (“TRIO”) (ALN: 84.047A, 84.042A and 84.217A) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): A. Activities Allowed or Unallowed/N. Special Tests and Provisions – Per 2 Code of Federal Regulation (“CFR”) Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities as well as facilities and administration (“F&A”) cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. For after-the-fact activity records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included); (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. B. Allowable Costs and Cost Principles - In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles. G. Level of Effort - Level of effort includes requirements for (a) a specified level of service to be provided from period to period and (b) a specified level of expenditures from nonfederal or federal sources for specified activities to be maintained from period to period. Only allowable categories of expenditures or other effort indicators (e.g., hours, number of people served) should be included in the computation and expenditures categories should be consistent from year to year. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Additionally, for certain payroll and non-payroll expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. Cause: Insufficient administrative oversight and internal controls with respect to the University’s administration of federal awards in accordance with certain compliance requirements. Effect or Potential Effect: The University was unable to support certain amounts charged to federal awards and effort certifications supporting certain payroll costs charged to federal awards were not completed timely and/or appropriately monitored during the year. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions during our testing: • For 4 of 15 non-payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting that the expenditure was appropriately approved prior to the disbursement of funds. • For 1 of 15 non-payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 2 of 10 payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 5 of 8 Title III employees selected for testing, time and effort reports certified by the employee could not be provided and/or did not support the amount charged to the federal award. • For 2 of 12 months selected for testing, the University did not obtain a level of effort certification for the Title III program director. • For 1 of 10 non-payroll TRIO expenditures selected for testing, the University was unable to provide documentation supporting that the expenditure was appropriately approved prior to the disbursement of funds. • For 1 of 15 payroll TRIO expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 10 of 10 TRIO Program employees selected for testing, time and effort reports certified by the employee could not be provided and/or did not support the amount charged to the federal award. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University has appropriate and formal documentation to support federal expenditures as required, as well as appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: The University experienced turnover of key positions throughout campus, particularly in the Division of Finance, Government Sponsored Programs and various federally funds programs. The changes in staffing lead to a loss of institutional knowledge, and interrupted policy and process enforcement campus wide. The Office of Government Sponsored Programs (“GSPAR”) will enhance its internal controls, policies and procedures to ensure the appropriate documentation to support is maintained, and to ensure that level of effort is appropriately documented and reported. GSPAR will be working in conjunction with the Office of Human Resources, including Payroll, to ensure accuracy, or timely correction, of general ledger postings. In addition, the grant onboarding process will be revised to emphasize key federal regulations and emphasize the importance of compliance. Reminders will also be provided during GSPAR’s semi-annual grant compliance workshops.

Federal Program Information: Higher Education Institutional Aid: Strengthening Historically Black Colleges and Universities Program (“Title III”) (ALN: 84.031B and 84.031E) and TRIO Cluster (“TRIO”) (ALN: 84.047A, 84.042A and 84.217A) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): A. Activities Allowed or Unallowed/N. Special Tests and Provisions – Per 2 Code of Federal Regulation (“CFR”) Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities as well as facilities and administration (“F&A”) cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. For after-the-fact activity records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included); (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. B. Allowable Costs and Cost Principles - In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles. G. Level of Effort - Level of effort includes requirements for (a) a specified level of service to be provided from period to period and (b) a specified level of expenditures from nonfederal or federal sources for specified activities to be maintained from period to period. Only allowable categories of expenditures or other effort indicators (e.g., hours, number of people served) should be included in the computation and expenditures categories should be consistent from year to year. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Additionally, for certain payroll and non-payroll expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. Cause: Insufficient administrative oversight and internal controls with respect to the University’s administration of federal awards in accordance with certain compliance requirements. Effect or Potential Effect: The University was unable to support certain amounts charged to federal awards and effort certifications supporting certain payroll costs charged to federal awards were not completed timely and/or appropriately monitored during the year. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions during our testing: • For 4 of 15 non-payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting that the expenditure was appropriately approved prior to the disbursement of funds. • For 1 of 15 non-payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 2 of 10 payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 5 of 8 Title III employees selected for testing, time and effort reports certified by the employee could not be provided and/or did not support the amount charged to the federal award. • For 2 of 12 months selected for testing, the University did not obtain a level of effort certification for the Title III program director. • For 1 of 10 non-payroll TRIO expenditures selected for testing, the University was unable to provide documentation supporting that the expenditure was appropriately approved prior to the disbursement of funds. • For 1 of 15 payroll TRIO expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 10 of 10 TRIO Program employees selected for testing, time and effort reports certified by the employee could not be provided and/or did not support the amount charged to the federal award. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University has appropriate and formal documentation to support federal expenditures as required, as well as appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: The University experienced turnover of key positions throughout campus, particularly in the Division of Finance, Government Sponsored Programs and various federally funds programs. The changes in staffing lead to a loss of institutional knowledge, and interrupted policy and process enforcement campus wide. The Office of Government Sponsored Programs (“GSPAR”) will enhance its internal controls, policies and procedures to ensure the appropriate documentation to support is maintained, and to ensure that level of effort is appropriately documented and reported. GSPAR will be working in conjunction with the Office of Human Resources, including Payroll, to ensure accuracy, or timely correction, of general ledger postings. In addition, the grant onboarding process will be revised to emphasize key federal regulations and emphasize the importance of compliance. Reminders will also be provided during GSPAR’s semi-annual grant compliance workshops.

Federal Program Information: Higher Education Institutional Aid: Strengthening Historically Black Colleges and Universities Program (“Title III”) (ALN: 84.031B and 84.031E) and TRIO Cluster (“TRIO”) (ALN: 84.047A, 84.042A and 84.217A) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): A. Activities Allowed or Unallowed/N. Special Tests and Provisions – Per 2 Code of Federal Regulation (“CFR”) Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities as well as facilities and administration (“F&A”) cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. For after-the-fact activity records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included); (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. B. Allowable Costs and Cost Principles - In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles. G. Level of Effort - Level of effort includes requirements for (a) a specified level of service to be provided from period to period and (b) a specified level of expenditures from nonfederal or federal sources for specified activities to be maintained from period to period. Only allowable categories of expenditures or other effort indicators (e.g., hours, number of people served) should be included in the computation and expenditures categories should be consistent from year to year. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Additionally, for certain payroll and non-payroll expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. Cause: Insufficient administrative oversight and internal controls with respect to the University’s administration of federal awards in accordance with certain compliance requirements. Effect or Potential Effect: The University was unable to support certain amounts charged to federal awards and effort certifications supporting certain payroll costs charged to federal awards were not completed timely and/or appropriately monitored during the year. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions during our testing: • For 4 of 15 non-payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting that the expenditure was appropriately approved prior to the disbursement of funds. • For 1 of 15 non-payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 2 of 10 payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 5 of 8 Title III employees selected for testing, time and effort reports certified by the employee could not be provided and/or did not support the amount charged to the federal award. • For 2 of 12 months selected for testing, the University did not obtain a level of effort certification for the Title III program director. • For 1 of 10 non-payroll TRIO expenditures selected for testing, the University was unable to provide documentation supporting that the expenditure was appropriately approved prior to the disbursement of funds. • For 1 of 15 payroll TRIO expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 10 of 10 TRIO Program employees selected for testing, time and effort reports certified by the employee could not be provided and/or did not support the amount charged to the federal award. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University has appropriate and formal documentation to support federal expenditures as required, as well as appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: The University experienced turnover of key positions throughout campus, particularly in the Division of Finance, Government Sponsored Programs and various federally funds programs. The changes in staffing lead to a loss of institutional knowledge, and interrupted policy and process enforcement campus wide. The Office of Government Sponsored Programs (“GSPAR”) will enhance its internal controls, policies and procedures to ensure the appropriate documentation to support is maintained, and to ensure that level of effort is appropriately documented and reported. GSPAR will be working in conjunction with the Office of Human Resources, including Payroll, to ensure accuracy, or timely correction, of general ledger postings. In addition, the grant onboarding process will be revised to emphasize key federal regulations and emphasize the importance of compliance. Reminders will also be provided during GSPAR’s semi-annual grant compliance workshops.

Federal Program Information: Higher Education Institutional Aid: Strengthening Historically Black Colleges and Universities Program (“Title III”) (ALN: 84.031B and 84.031E) and TRIO Cluster (“TRIO”) (ALN: 84.047A, 84.042A and 84.217A) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): A. Activities Allowed or Unallowed/N. Special Tests and Provisions – Per 2 Code of Federal Regulation (“CFR”) Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities as well as facilities and administration (“F&A”) cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. For after-the-fact activity records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included); (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. B. Allowable Costs and Cost Principles - In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles. G. Level of Effort - Level of effort includes requirements for (a) a specified level of service to be provided from period to period and (b) a specified level of expenditures from nonfederal or federal sources for specified activities to be maintained from period to period. Only allowable categories of expenditures or other effort indicators (e.g., hours, number of people served) should be included in the computation and expenditures categories should be consistent from year to year. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Additionally, for certain payroll and non-payroll expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. Cause: Insufficient administrative oversight and internal controls with respect to the University’s administration of federal awards in accordance with certain compliance requirements. Effect or Potential Effect: The University was unable to support certain amounts charged to federal awards and effort certifications supporting certain payroll costs charged to federal awards were not completed timely and/or appropriately monitored during the year. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions during our testing: • For 4 of 15 non-payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting that the expenditure was appropriately approved prior to the disbursement of funds. • For 1 of 15 non-payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 2 of 10 payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 5 of 8 Title III employees selected for testing, time and effort reports certified by the employee could not be provided and/or did not support the amount charged to the federal award. • For 2 of 12 months selected for testing, the University did not obtain a level of effort certification for the Title III program director. • For 1 of 10 non-payroll TRIO expenditures selected for testing, the University was unable to provide documentation supporting that the expenditure was appropriately approved prior to the disbursement of funds. • For 1 of 15 payroll TRIO expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 10 of 10 TRIO Program employees selected for testing, time and effort reports certified by the employee could not be provided and/or did not support the amount charged to the federal award. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University has appropriate and formal documentation to support federal expenditures as required, as well as appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: The University experienced turnover of key positions throughout campus, particularly in the Division of Finance, Government Sponsored Programs and various federally funds programs. The changes in staffing lead to a loss of institutional knowledge, and interrupted policy and process enforcement campus wide. The Office of Government Sponsored Programs (“GSPAR”) will enhance its internal controls, policies and procedures to ensure the appropriate documentation to support is maintained, and to ensure that level of effort is appropriately documented and reported. GSPAR will be working in conjunction with the Office of Human Resources, including Payroll, to ensure accuracy, or timely correction, of general ledger postings. In addition, the grant onboarding process will be revised to emphasize key federal regulations and emphasize the importance of compliance. Reminders will also be provided during GSPAR’s semi-annual grant compliance workshops.

Federal Program Information: Higher Education Institutional Aid: Strengthening Historically Black Colleges and Universities Program (ALN: 84.031B and 84.031E) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48). Condition: The University was unable to provide documentation supporting an appropriate competitive bidding process, sole source justification and/or appropriate review of the federal suspension and debarment database prior to the disbursement of funds. Cause: Insufficient administrative oversight and internal controls over procurement compliance requirements. Effect or Potential Effect: The University was not in compliance with procurement compliance requirements. Questioned Costs: None. Context: For 5 of 5 procurement transactions tested, the University was unable to provide documentation supporting an appropriate competitive bidding process, sole source justification and/or appropriate review of the federal suspension and debarment database prior to the disbursement of funds. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The University eliminated the position of Procurement Manager several years back, which decentralized the responsibility for procurement. The change led to a loss of institutional knowledge, and interrupted policy and process enforcement campus wide. GSPAR will enhance its internal controls and implement formal policies and procedures to ensure that those responsible for procurement activities are aware of, and comply with, all federal purchasing rules and regulations. The GSPAR will ensure the appropriate documentation related to debarment, sole source justification and bidding process are received, or attached to the purchasing requisition, prior to approving purchases. In addition, the grant onboarding process will be revised to emphasize key federal regulations and emphasize the importance of compliance. Reminders will also be provided during GSPAR’s semi-annual grant compliance workshops.

Federal Program Information: Higher Education Institutional Aid: Strengthening Historically Black Colleges and Universities Program (ALN: 84.031B and 84.031E) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48). Condition: The University was unable to provide documentation supporting an appropriate competitive bidding process, sole source justification and/or appropriate review of the federal suspension and debarment database prior to the disbursement of funds. Cause: Insufficient administrative oversight and internal controls over procurement compliance requirements. Effect or Potential Effect: The University was not in compliance with procurement compliance requirements. Questioned Costs: None. Context: For 5 of 5 procurement transactions tested, the University was unable to provide documentation supporting an appropriate competitive bidding process, sole source justification and/or appropriate review of the federal suspension and debarment database prior to the disbursement of funds. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The University eliminated the position of Procurement Manager several years back, which decentralized the responsibility for procurement. The change led to a loss of institutional knowledge, and interrupted policy and process enforcement campus wide. GSPAR will enhance its internal controls and implement formal policies and procedures to ensure that those responsible for procurement activities are aware of, and comply with, all federal purchasing rules and regulations. The GSPAR will ensure the appropriate documentation related to debarment, sole source justification and bidding process are received, or attached to the purchasing requisition, prior to approving purchases. In addition, the grant onboarding process will be revised to emphasize key federal regulations and emphasize the importance of compliance. Reminders will also be provided during GSPAR’s semi-annual grant compliance workshops.

Federal Program Information: Higher Education Institutional Aid: Strengthening Historically Black Colleges and Universities Program (ALN: 84.031B and 84.031E) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment records shall be maintained, a physical inventory of equipment shall be taken at least once every 2 years and reconciled to the equipment records, an appropriate control system shall be used to safeguard equipment, and equipment shall be adequately maintained. Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. The Uniform Guidance further requires that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: The University did not comply with the requirements of equipment and real property management. Cause: Insufficient administrative oversight and internal controls with respect to equipment and real property management. Effect or Potential Effect: The University did not comply with the requirements of equipment and real property management. Questioned Costs: None. Context: The University was unable to provide documentation supporting the completion of a physical inventory of equipment and real property purchased with federal funds during the most recent two fiscal years. Additionally, for 1 of 2 sampled items, the University was unable to provide documentation supporting the required tagging and appropriate maintenance of property records for federally funded equipment. Identification as a Repeat Finding: No similar findings noted in the prior year.   Recommendation: We recommend that the University enhance its internal controls and procedures over the equipment and real property management compliance requirements. Views of Responsible Officials: The University eliminated the position of Procurement Manager several years back, which decentralized the responsibility for procurement. The change led to a loss of institutional knowledge, and interrupted policy and process enforcement campus wide. While Government Sponsored Programs and Research (“GSPAR”) has a process for recording and inventorying federal purchases, the information was not updated timely and did not provide required information. GSPAR will enhance update its inventory tracking process to capture required information. In addition, the grant onboarding process will be revised to emphasize key federal regulations and emphasize the importance of compliance. Reminders will also be provided during GSPAR’s semi-annual grant compliance workshops.

Federal Program Information: Higher Education Institutional Aid: Strengthening Historically Black Colleges and Universities Program (ALN: 84.031B and 84.031E) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment records shall be maintained, a physical inventory of equipment shall be taken at least once every 2 years and reconciled to the equipment records, an appropriate control system shall be used to safeguard equipment, and equipment shall be adequately maintained. Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. The Uniform Guidance further requires that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: The University did not comply with the requirements of equipment and real property management. Cause: Insufficient administrative oversight and internal controls with respect to equipment and real property management. Effect or Potential Effect: The University did not comply with the requirements of equipment and real property management. Questioned Costs: None. Context: The University was unable to provide documentation supporting the completion of a physical inventory of equipment and real property purchased with federal funds during the most recent two fiscal years. Additionally, for 1 of 2 sampled items, the University was unable to provide documentation supporting the required tagging and appropriate maintenance of property records for federally funded equipment. Identification as a Repeat Finding: No similar findings noted in the prior year.   Recommendation: We recommend that the University enhance its internal controls and procedures over the equipment and real property management compliance requirements. Views of Responsible Officials: The University eliminated the position of Procurement Manager several years back, which decentralized the responsibility for procurement. The change led to a loss of institutional knowledge, and interrupted policy and process enforcement campus wide. While Government Sponsored Programs and Research (“GSPAR”) has a process for recording and inventorying federal purchases, the information was not updated timely and did not provide required information. GSPAR will enhance update its inventory tracking process to capture required information. In addition, the grant onboarding process will be revised to emphasize key federal regulations and emphasize the importance of compliance. Reminders will also be provided during GSPAR’s semi-annual grant compliance workshops.

Federal Program Information: TRIO Cluster (“TRIO”) (ALN: 84.042A and 84.217A) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility – Under the McNair Post-Baccalaureate Achievement (“McNair”) program, the University may award stipends of up to $2,800 per year for students engaged in approved research internships. Per 34 CFR 646.30(i), Student Support Services (“SSS”) grant aid may be provided to students who have completed their first two years of postsecondary education and who are receiving Federal Pell Grants under subpart 1 of part A of title IV of the Act if the institution demonstrates to the satisfaction of the Secretary that: • These students are at high risk of dropping out; and • It will first meet the needs of all its eligible first- and second-year students for services under this paragraph. Additionally, eligible participants for the SSS Program must meet the following requirements: • Is a citizen or national of the United States or meets the residency requirements for federal student financial assistance; • Is enrolled at the grantee institution or accepted for enrollment in the next academic term at that institution; • Has a need for academic support as determined by the grantee in order to pursue successfully a postsecondary educational program; and • Is a low-income individual, a first-generation college student, or an individual with disabilities (34 CFR sections 646.3 and 646.7) Condition: The University was unable to provide documentation supporting certain students’ eligibility to participate in the TRIO program or the amounts awarded for certain stipends. Cause: Insufficient administrative oversight and internal controls over TRIO program eligibility requirements. Effect or Potential Effect: The University was not in compliance with TRIO program eligibility requirements. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions during our testing: • For 3 of 16 student selected for testing, the University was unable to provide documentation supporting that approval was obtained from the U.S. Department of Education to increase the stipend amount awarded under the McNair program above the allowed annual maximum during the year before disbursements were made to the students. • For 1 of 4 students selected for testing, the University was not able to demonstrate that the criteria for awarding SSS TRIO grant aid to a student who had previously completed their first two years of postsecondary education was appropriately satisfied. • For 2 of 25 students selected for testing, the University was unable to provide documentation supporting the students’ eligibility for the TRIO program. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that documentation supporting TRIO program eligibility is appropriately retained as required. Views of Responsible Officials: The University experienced significant staffing changes in the TRIO programs. The changes in staffing lead to a loss of institutional knowledge, and interrupted policy and process enforcement. In many instance the documentation wasn’t available due to the transition of key individuals. During the period of staff transition for the McNair program, original communication showing previous approval from the Program Officer was not accessible. While the Department of Education provided correspondence granting McNair projects permission to reallocate travel funding to increase stipends for participants, given the limitations on travel capabilities due to the COVID-19 pandemic, which was subsequently confirmed by the Program Officer, we encountered difficulty locating explicit documentation approving the specific stipend increase amount. Continuous monitoring of program records will be implemented to ensure compliance with federal, Institutional and program requirements. The programs will review existing program operating procedures manuals to identify needed updates to current policies and procedures to align with federal, institutional and program requirements. The program stall will also engage in professional development opportunities to improve grant management.

Federal Program Information: TRIO Cluster (“TRIO”) (ALN: 84.042A and 84.217A) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility – Under the McNair Post-Baccalaureate Achievement (“McNair”) program, the University may award stipends of up to $2,800 per year for students engaged in approved research internships. Per 34 CFR 646.30(i), Student Support Services (“SSS”) grant aid may be provided to students who have completed their first two years of postsecondary education and who are receiving Federal Pell Grants under subpart 1 of part A of title IV of the Act if the institution demonstrates to the satisfaction of the Secretary that: • These students are at high risk of dropping out; and • It will first meet the needs of all its eligible first- and second-year students for services under this paragraph. Additionally, eligible participants for the SSS Program must meet the following requirements: • Is a citizen or national of the United States or meets the residency requirements for federal student financial assistance; • Is enrolled at the grantee institution or accepted for enrollment in the next academic term at that institution; • Has a need for academic support as determined by the grantee in order to pursue successfully a postsecondary educational program; and • Is a low-income individual, a first-generation college student, or an individual with disabilities (34 CFR sections 646.3 and 646.7) Condition: The University was unable to provide documentation supporting certain students’ eligibility to participate in the TRIO program or the amounts awarded for certain stipends. Cause: Insufficient administrative oversight and internal controls over TRIO program eligibility requirements. Effect or Potential Effect: The University was not in compliance with TRIO program eligibility requirements. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions during our testing: • For 3 of 16 student selected for testing, the University was unable to provide documentation supporting that approval was obtained from the U.S. Department of Education to increase the stipend amount awarded under the McNair program above the allowed annual maximum during the year before disbursements were made to the students. • For 1 of 4 students selected for testing, the University was not able to demonstrate that the criteria for awarding SSS TRIO grant aid to a student who had previously completed their first two years of postsecondary education was appropriately satisfied. • For 2 of 25 students selected for testing, the University was unable to provide documentation supporting the students’ eligibility for the TRIO program. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that documentation supporting TRIO program eligibility is appropriately retained as required. Views of Responsible Officials: The University experienced significant staffing changes in the TRIO programs. The changes in staffing lead to a loss of institutional knowledge, and interrupted policy and process enforcement. In many instance the documentation wasn’t available due to the transition of key individuals. During the period of staff transition for the McNair program, original communication showing previous approval from the Program Officer was not accessible. While the Department of Education provided correspondence granting McNair projects permission to reallocate travel funding to increase stipends for participants, given the limitations on travel capabilities due to the COVID-19 pandemic, which was subsequently confirmed by the Program Officer, we encountered difficulty locating explicit documentation approving the specific stipend increase amount. Continuous monitoring of program records will be implemented to ensure compliance with federal, Institutional and program requirements. The programs will review existing program operating procedures manuals to identify needed updates to current policies and procedures to align with federal, institutional and program requirements. The program stall will also engage in professional development opportunities to improve grant management.

Federal Program Information: TRIO Cluster (“TRIO”) (84.047A, 84.042A and 84.217A) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - Grantees must submit an annual performance report to Department of Education each year of the project period. Certain key items contain critical information that should be included within the report and such information should be reconciled to the institution’s underlying records. Condition: The University did not include certain key line items in its annual TRIO reports and was unable to provide documentation supporting certain other information included within the reports. Cause: Insufficient administrative oversight and internal controls over TRIO program reporting requirements. Effect or Potential Effect: The University was not in compliance with TRIO program reporting requirements. Questioned Costs: None. Context: During our audit procedures, we noted that the University did not include certain key line items within their annual TRIO reports and was unable to provide documentation supporting certain other information included within the reports. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that TRIO reports are prepared in accordance with federal regulations and that supporting documentation is appropriately retained as required.   Views of Responsible Officials: The University experienced significant staffing changes in the TRIO programs. The changes in staffing lead to a loss of institutional knowledge, and interrupted policy and process enforcement. In many instance the documentation wasn’t available due to the transition of key individuals. Continuous monitoring of program records will be implemented to ensure compliance with federal, Institutional and program requirements. The programs will review existing program operating procedures manuals to identify needed updates to current policies and procedures to align with federal, institutional and program requirements. The program stall will also engage in professional development opportunities to improve grant management.

Federal Program Information: TRIO Cluster (“TRIO”) (84.047A, 84.042A and 84.217A) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - Grantees must submit an annual performance report to Department of Education each year of the project period. Certain key items contain critical information that should be included within the report and such information should be reconciled to the institution’s underlying records. Condition: The University did not include certain key line items in its annual TRIO reports and was unable to provide documentation supporting certain other information included within the reports. Cause: Insufficient administrative oversight and internal controls over TRIO program reporting requirements. Effect or Potential Effect: The University was not in compliance with TRIO program reporting requirements. Questioned Costs: None. Context: During our audit procedures, we noted that the University did not include certain key line items within their annual TRIO reports and was unable to provide documentation supporting certain other information included within the reports. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that TRIO reports are prepared in accordance with federal regulations and that supporting documentation is appropriately retained as required.   Views of Responsible Officials: The University experienced significant staffing changes in the TRIO programs. The changes in staffing lead to a loss of institutional knowledge, and interrupted policy and process enforcement. In many instance the documentation wasn’t available due to the transition of key individuals. Continuous monitoring of program records will be implemented to ensure compliance with federal, Institutional and program requirements. The programs will review existing program operating procedures manuals to identify needed updates to current policies and procedures to align with federal, institutional and program requirements. The program stall will also engage in professional development opportunities to improve grant management.

Federal Program Information: TRIO Cluster (“TRIO”) (84.047A, 84.042A and 84.217A) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - Grantees must submit an annual performance report to Department of Education each year of the project period. Certain key items contain critical information that should be included within the report and such information should be reconciled to the institution’s underlying records. Condition: The University did not include certain key line items in its annual TRIO reports and was unable to provide documentation supporting certain other information included within the reports. Cause: Insufficient administrative oversight and internal controls over TRIO program reporting requirements. Effect or Potential Effect: The University was not in compliance with TRIO program reporting requirements. Questioned Costs: None. Context: During our audit procedures, we noted that the University did not include certain key line items within their annual TRIO reports and was unable to provide documentation supporting certain other information included within the reports. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that TRIO reports are prepared in accordance with federal regulations and that supporting documentation is appropriately retained as required.   Views of Responsible Officials: The University experienced significant staffing changes in the TRIO programs. The changes in staffing lead to a loss of institutional knowledge, and interrupted policy and process enforcement. In many instance the documentation wasn’t available due to the transition of key individuals. Continuous monitoring of program records will be implemented to ensure compliance with federal, Institutional and program requirements. The programs will review existing program operating procedures manuals to identify needed updates to current policies and procedures to align with federal, institutional and program requirements. The program stall will also engage in professional development opportunities to improve grant management.

Federal Program Information: Federal Perkins Loan program (“Perkins”) (84.038) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - A school must ensure that all of its loans are properly accounted for and updated on the National Student Loan Data System (“NSLDS”). It is the school's responsibility to ensure that the required reporting to NSLDS, including Perkins Loan account detail, is completed timely and accurately. The school should request a Perkins Loan Reconciliation Report (REC005) from the NSLDS Professional Access website and reconcile its records against the report to ensure its outstanding portfolio has been accurately reported to NSLDS. The total amount of loans and number of borrowers on NSLDS should reconcile with the school’s records, its third-party servicer records, and what is reported on its Fiscal Operations Report and Application to Participate (“FISAP”). Condition: The University was unable to provide a record of the total amount of loans and number of borrowers that reconciled with the amounts reported per the most recent FISAP and the Perkins Intent and Closeout form. Cause: Insufficient administrative oversight over the Perkins program liquidation requirements. Effect or Potential Effect: The total amount of loans and number of borrowers reported per the most recent FISAP and the Perkins Intent and Closeout form did not reconcile as required. Questioned Costs: Below reporting threshold. Context: The University was unable to provide records supporting the total amount of loans and number of borrowers that were reported during the closeout process for its Perkins loan program and in the latest reported FISAP. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its policies and procedures to ensure that the amount of loans and number of borrowers in the Perkins program are properly reconciled and accurately reported, in accordance with federal regulations. Views of Responsible Officials: Due to limitation on the FISAP, once the number of borrowers and loan balances are entered they cannot be changes, as a result there were minor differences, approximately 5 students and less than $10,000, that had been carried forward for several years. The Department of Education program officer, as well as the University’s loan servicer ECSI, have communicated that some of the numbers may differ due to payments or cancellations made after the loans were recorded. The Department of Education has accepted the information as final. The University has completed the Perkins Loan program liquidation process. The re-assignment of eligible loans to the Department of Education has been completed. Those not eligible for re-assignment have been deemed uncollectible and written-off. Once the University’s audit has been submitted we anticipated receiving the final close out letter from the Department of Education, which will officially close the Perkins Loan program at the University.

Federal Program Information: Higher Education Institutional Aid: Strengthening Historically Black Colleges and Universities Program (“Title III”) (ALN: 84.031B and 84.031E) and TRIO Cluster (“TRIO”) (ALN: 84.047A, 84.042A and 84.217A) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): A. Activities Allowed or Unallowed/N. Special Tests and Provisions – Per 2 Code of Federal Regulation (“CFR”) Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities as well as facilities and administration (“F&A”) cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. For after-the-fact activity records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included); (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. B. Allowable Costs and Cost Principles - In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles. G. Level of Effort - Level of effort includes requirements for (a) a specified level of service to be provided from period to period and (b) a specified level of expenditures from nonfederal or federal sources for specified activities to be maintained from period to period. Only allowable categories of expenditures or other effort indicators (e.g., hours, number of people served) should be included in the computation and expenditures categories should be consistent from year to year. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Additionally, for certain payroll and non-payroll expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. Cause: Insufficient administrative oversight and internal controls with respect to the University’s administration of federal awards in accordance with certain compliance requirements. Effect or Potential Effect: The University was unable to support certain amounts charged to federal awards and effort certifications supporting certain payroll costs charged to federal awards were not completed timely and/or appropriately monitored during the year. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions during our testing: • For 4 of 15 non-payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting that the expenditure was appropriately approved prior to the disbursement of funds. • For 1 of 15 non-payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 2 of 10 payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 5 of 8 Title III employees selected for testing, time and effort reports certified by the employee could not be provided and/or did not support the amount charged to the federal award. • For 2 of 12 months selected for testing, the University did not obtain a level of effort certification for the Title III program director. • For 1 of 10 non-payroll TRIO expenditures selected for testing, the University was unable to provide documentation supporting that the expenditure was appropriately approved prior to the disbursement of funds. • For 1 of 15 payroll TRIO expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 10 of 10 TRIO Program employees selected for testing, time and effort reports certified by the employee could not be provided and/or did not support the amount charged to the federal award. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University has appropriate and formal documentation to support federal expenditures as required, as well as appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: The University experienced turnover of key positions throughout campus, particularly in the Division of Finance, Government Sponsored Programs and various federally funds programs. The changes in staffing lead to a loss of institutional knowledge, and interrupted policy and process enforcement campus wide. The Office of Government Sponsored Programs (“GSPAR”) will enhance its internal controls, policies and procedures to ensure the appropriate documentation to support is maintained, and to ensure that level of effort is appropriately documented and reported. GSPAR will be working in conjunction with the Office of Human Resources, including Payroll, to ensure accuracy, or timely correction, of general ledger postings. In addition, the grant onboarding process will be revised to emphasize key federal regulations and emphasize the importance of compliance. Reminders will also be provided during GSPAR’s semi-annual grant compliance workshops.

Federal Program Information: Higher Education Institutional Aid: Strengthening Historically Black Colleges and Universities Program (“Title III”) (ALN: 84.031B and 84.031E) and TRIO Cluster (“TRIO”) (ALN: 84.047A, 84.042A and 84.217A) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): A. Activities Allowed or Unallowed/N. Special Tests and Provisions – Per 2 Code of Federal Regulation (“CFR”) Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities as well as facilities and administration (“F&A”) cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. For after-the-fact activity records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included); (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. B. Allowable Costs and Cost Principles - In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles. G. Level of Effort - Level of effort includes requirements for (a) a specified level of service to be provided from period to period and (b) a specified level of expenditures from nonfederal or federal sources for specified activities to be maintained from period to period. Only allowable categories of expenditures or other effort indicators (e.g., hours, number of people served) should be included in the computation and expenditures categories should be consistent from year to year. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Additionally, for certain payroll and non-payroll expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. Cause: Insufficient administrative oversight and internal controls with respect to the University’s administration of federal awards in accordance with certain compliance requirements. Effect or Potential Effect: The University was unable to support certain amounts charged to federal awards and effort certifications supporting certain payroll costs charged to federal awards were not completed timely and/or appropriately monitored during the year. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions during our testing: • For 4 of 15 non-payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting that the expenditure was appropriately approved prior to the disbursement of funds. • For 1 of 15 non-payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 2 of 10 payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 5 of 8 Title III employees selected for testing, time and effort reports certified by the employee could not be provided and/or did not support the amount charged to the federal award. • For 2 of 12 months selected for testing, the University did not obtain a level of effort certification for the Title III program director. • For 1 of 10 non-payroll TRIO expenditures selected for testing, the University was unable to provide documentation supporting that the expenditure was appropriately approved prior to the disbursement of funds. • For 1 of 15 payroll TRIO expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 10 of 10 TRIO Program employees selected for testing, time and effort reports certified by the employee could not be provided and/or did not support the amount charged to the federal award. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University has appropriate and formal documentation to support federal expenditures as required, as well as appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: The University experienced turnover of key positions throughout campus, particularly in the Division of Finance, Government Sponsored Programs and various federally funds programs. The changes in staffing lead to a loss of institutional knowledge, and interrupted policy and process enforcement campus wide. The Office of Government Sponsored Programs (“GSPAR”) will enhance its internal controls, policies and procedures to ensure the appropriate documentation to support is maintained, and to ensure that level of effort is appropriately documented and reported. GSPAR will be working in conjunction with the Office of Human Resources, including Payroll, to ensure accuracy, or timely correction, of general ledger postings. In addition, the grant onboarding process will be revised to emphasize key federal regulations and emphasize the importance of compliance. Reminders will also be provided during GSPAR’s semi-annual grant compliance workshops.

Federal Program Information: Higher Education Institutional Aid: Strengthening Historically Black Colleges and Universities Program (“Title III”) (ALN: 84.031B and 84.031E) and TRIO Cluster (“TRIO”) (ALN: 84.047A, 84.042A and 84.217A) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): A. Activities Allowed or Unallowed/N. Special Tests and Provisions – Per 2 Code of Federal Regulation (“CFR”) Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities as well as facilities and administration (“F&A”) cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. For after-the-fact activity records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included); (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. B. Allowable Costs and Cost Principles - In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles. G. Level of Effort - Level of effort includes requirements for (a) a specified level of service to be provided from period to period and (b) a specified level of expenditures from nonfederal or federal sources for specified activities to be maintained from period to period. Only allowable categories of expenditures or other effort indicators (e.g., hours, number of people served) should be included in the computation and expenditures categories should be consistent from year to year. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Additionally, for certain payroll and non-payroll expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. Cause: Insufficient administrative oversight and internal controls with respect to the University’s administration of federal awards in accordance with certain compliance requirements. Effect or Potential Effect: The University was unable to support certain amounts charged to federal awards and effort certifications supporting certain payroll costs charged to federal awards were not completed timely and/or appropriately monitored during the year. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions during our testing: • For 4 of 15 non-payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting that the expenditure was appropriately approved prior to the disbursement of funds. • For 1 of 15 non-payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 2 of 10 payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 5 of 8 Title III employees selected for testing, time and effort reports certified by the employee could not be provided and/or did not support the amount charged to the federal award. • For 2 of 12 months selected for testing, the University did not obtain a level of effort certification for the Title III program director. • For 1 of 10 non-payroll TRIO expenditures selected for testing, the University was unable to provide documentation supporting that the expenditure was appropriately approved prior to the disbursement of funds. • For 1 of 15 payroll TRIO expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 10 of 10 TRIO Program employees selected for testing, time and effort reports certified by the employee could not be provided and/or did not support the amount charged to the federal award. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University has appropriate and formal documentation to support federal expenditures as required, as well as appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: The University experienced turnover of key positions throughout campus, particularly in the Division of Finance, Government Sponsored Programs and various federally funds programs. The changes in staffing lead to a loss of institutional knowledge, and interrupted policy and process enforcement campus wide. The Office of Government Sponsored Programs (“GSPAR”) will enhance its internal controls, policies and procedures to ensure the appropriate documentation to support is maintained, and to ensure that level of effort is appropriately documented and reported. GSPAR will be working in conjunction with the Office of Human Resources, including Payroll, to ensure accuracy, or timely correction, of general ledger postings. In addition, the grant onboarding process will be revised to emphasize key federal regulations and emphasize the importance of compliance. Reminders will also be provided during GSPAR’s semi-annual grant compliance workshops.

Federal Program Information: Higher Education Institutional Aid: Strengthening Historically Black Colleges and Universities Program (“Title III”) (ALN: 84.031B and 84.031E) and TRIO Cluster (“TRIO”) (ALN: 84.047A, 84.042A and 84.217A) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): A. Activities Allowed or Unallowed/N. Special Tests and Provisions – Per 2 Code of Federal Regulation (“CFR”) Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities as well as facilities and administration (“F&A”) cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. For after-the-fact activity records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included); (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. B. Allowable Costs and Cost Principles - In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles. G. Level of Effort - Level of effort includes requirements for (a) a specified level of service to be provided from period to period and (b) a specified level of expenditures from nonfederal or federal sources for specified activities to be maintained from period to period. Only allowable categories of expenditures or other effort indicators (e.g., hours, number of people served) should be included in the computation and expenditures categories should be consistent from year to year. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Additionally, for certain payroll and non-payroll expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. Cause: Insufficient administrative oversight and internal controls with respect to the University’s administration of federal awards in accordance with certain compliance requirements. Effect or Potential Effect: The University was unable to support certain amounts charged to federal awards and effort certifications supporting certain payroll costs charged to federal awards were not completed timely and/or appropriately monitored during the year. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions during our testing: • For 4 of 15 non-payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting that the expenditure was appropriately approved prior to the disbursement of funds. • For 1 of 15 non-payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 2 of 10 payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 5 of 8 Title III employees selected for testing, time and effort reports certified by the employee could not be provided and/or did not support the amount charged to the federal award. • For 2 of 12 months selected for testing, the University did not obtain a level of effort certification for the Title III program director. • For 1 of 10 non-payroll TRIO expenditures selected for testing, the University was unable to provide documentation supporting that the expenditure was appropriately approved prior to the disbursement of funds. • For 1 of 15 payroll TRIO expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 10 of 10 TRIO Program employees selected for testing, time and effort reports certified by the employee could not be provided and/or did not support the amount charged to the federal award. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University has appropriate and formal documentation to support federal expenditures as required, as well as appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: The University experienced turnover of key positions throughout campus, particularly in the Division of Finance, Government Sponsored Programs and various federally funds programs. The changes in staffing lead to a loss of institutional knowledge, and interrupted policy and process enforcement campus wide. The Office of Government Sponsored Programs (“GSPAR”) will enhance its internal controls, policies and procedures to ensure the appropriate documentation to support is maintained, and to ensure that level of effort is appropriately documented and reported. GSPAR will be working in conjunction with the Office of Human Resources, including Payroll, to ensure accuracy, or timely correction, of general ledger postings. In addition, the grant onboarding process will be revised to emphasize key federal regulations and emphasize the importance of compliance. Reminders will also be provided during GSPAR’s semi-annual grant compliance workshops.

Federal Program Information: Higher Education Institutional Aid: Strengthening Historically Black Colleges and Universities Program (“Title III”) (ALN: 84.031B and 84.031E) and TRIO Cluster (“TRIO”) (ALN: 84.047A, 84.042A and 84.217A) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): A. Activities Allowed or Unallowed/N. Special Tests and Provisions – Per 2 Code of Federal Regulation (“CFR”) Part 220, the method used for apportioning salaries must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs, unless a mutually satisfactory alternative agreement is reached. Direct cost activities as well as facilities and administration (“F&A”) cost activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Confirmation by the employee is not a requirement for either direct or F&A cost activities if other responsible persons make appropriate confirmations. For after-the-fact activity records: a) Activity reports will reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in subsection a need not be included); (b) These reports will reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records. Labor costs charged to federal awards must reasonably reflect the actual labor effort contributed by the employee to meet the objectives of the award and that adequate documentation must be maintained to support labor costs charged to sponsored agreements. For professorial and professional staff, effort certifications will be prepared each academic term, but no less frequently than every six months. For other employees, unless alternate arrangements are agreed to, the reports will be prepared no less frequently than monthly and will coincide with one or more pay periods. B. Allowable Costs and Cost Principles - In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles. G. Level of Effort - Level of effort includes requirements for (a) a specified level of service to be provided from period to period and (b) a specified level of expenditures from nonfederal or federal sources for specified activities to be maintained from period to period. Only allowable categories of expenditures or other effort indicators (e.g., hours, number of people served) should be included in the computation and expenditures categories should be consistent from year to year. Condition: For certain payroll costs charged to federal awards, effort certifications were not prepared and/or reviewed timely during the fiscal year. Additionally, for certain payroll and non-payroll expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. Cause: Insufficient administrative oversight and internal controls with respect to the University’s administration of federal awards in accordance with certain compliance requirements. Effect or Potential Effect: The University was unable to support certain amounts charged to federal awards and effort certifications supporting certain payroll costs charged to federal awards were not completed timely and/or appropriately monitored during the year. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions during our testing: • For 4 of 15 non-payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting that the expenditure was appropriately approved prior to the disbursement of funds. • For 1 of 15 non-payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 2 of 10 payroll Title III expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 5 of 8 Title III employees selected for testing, time and effort reports certified by the employee could not be provided and/or did not support the amount charged to the federal award. • For 2 of 12 months selected for testing, the University did not obtain a level of effort certification for the Title III program director. • For 1 of 10 non-payroll TRIO expenditures selected for testing, the University was unable to provide documentation supporting that the expenditure was appropriately approved prior to the disbursement of funds. • For 1 of 15 payroll TRIO expenditures selected for testing, the University was unable to provide documentation supporting the amount charged to the federal award. • For 10 of 10 TRIO Program employees selected for testing, time and effort reports certified by the employee could not be provided and/or did not support the amount charged to the federal award. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and policies and procedures over the applicable compliance requirements to ensure that the University has appropriate and formal documentation to support federal expenditures as required, as well as appropriately monitoring time of effort reporting in a timely manner. Views of Responsible Officials: The University experienced turnover of key positions throughout campus, particularly in the Division of Finance, Government Sponsored Programs and various federally funds programs. The changes in staffing lead to a loss of institutional knowledge, and interrupted policy and process enforcement campus wide. The Office of Government Sponsored Programs (“GSPAR”) will enhance its internal controls, policies and procedures to ensure the appropriate documentation to support is maintained, and to ensure that level of effort is appropriately documented and reported. GSPAR will be working in conjunction with the Office of Human Resources, including Payroll, to ensure accuracy, or timely correction, of general ledger postings. In addition, the grant onboarding process will be revised to emphasize key federal regulations and emphasize the importance of compliance. Reminders will also be provided during GSPAR’s semi-annual grant compliance workshops.

Federal Program Information: Higher Education Institutional Aid: Strengthening Historically Black Colleges and Universities Program (ALN: 84.031B and 84.031E) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48). Condition: The University was unable to provide documentation supporting an appropriate competitive bidding process, sole source justification and/or appropriate review of the federal suspension and debarment database prior to the disbursement of funds. Cause: Insufficient administrative oversight and internal controls over procurement compliance requirements. Effect or Potential Effect: The University was not in compliance with procurement compliance requirements. Questioned Costs: None. Context: For 5 of 5 procurement transactions tested, the University was unable to provide documentation supporting an appropriate competitive bidding process, sole source justification and/or appropriate review of the federal suspension and debarment database prior to the disbursement of funds. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The University eliminated the position of Procurement Manager several years back, which decentralized the responsibility for procurement. The change led to a loss of institutional knowledge, and interrupted policy and process enforcement campus wide. GSPAR will enhance its internal controls and implement formal policies and procedures to ensure that those responsible for procurement activities are aware of, and comply with, all federal purchasing rules and regulations. The GSPAR will ensure the appropriate documentation related to debarment, sole source justification and bidding process are received, or attached to the purchasing requisition, prior to approving purchases. In addition, the grant onboarding process will be revised to emphasize key federal regulations and emphasize the importance of compliance. Reminders will also be provided during GSPAR’s semi-annual grant compliance workshops.

Federal Program Information: Higher Education Institutional Aid: Strengthening Historically Black Colleges and Universities Program (ALN: 84.031B and 84.031E) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48). Condition: The University was unable to provide documentation supporting an appropriate competitive bidding process, sole source justification and/or appropriate review of the federal suspension and debarment database prior to the disbursement of funds. Cause: Insufficient administrative oversight and internal controls over procurement compliance requirements. Effect or Potential Effect: The University was not in compliance with procurement compliance requirements. Questioned Costs: None. Context: For 5 of 5 procurement transactions tested, the University was unable to provide documentation supporting an appropriate competitive bidding process, sole source justification and/or appropriate review of the federal suspension and debarment database prior to the disbursement of funds. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations. Views of Responsible Officials: The University eliminated the position of Procurement Manager several years back, which decentralized the responsibility for procurement. The change led to a loss of institutional knowledge, and interrupted policy and process enforcement campus wide. GSPAR will enhance its internal controls and implement formal policies and procedures to ensure that those responsible for procurement activities are aware of, and comply with, all federal purchasing rules and regulations. The GSPAR will ensure the appropriate documentation related to debarment, sole source justification and bidding process are received, or attached to the purchasing requisition, prior to approving purchases. In addition, the grant onboarding process will be revised to emphasize key federal regulations and emphasize the importance of compliance. Reminders will also be provided during GSPAR’s semi-annual grant compliance workshops.

Federal Program Information: Higher Education Institutional Aid: Strengthening Historically Black Colleges and Universities Program (ALN: 84.031B and 84.031E) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment records shall be maintained, a physical inventory of equipment shall be taken at least once every 2 years and reconciled to the equipment records, an appropriate control system shall be used to safeguard equipment, and equipment shall be adequately maintained. Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. The Uniform Guidance further requires that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: The University did not comply with the requirements of equipment and real property management. Cause: Insufficient administrative oversight and internal controls with respect to equipment and real property management. Effect or Potential Effect: The University did not comply with the requirements of equipment and real property management. Questioned Costs: None. Context: The University was unable to provide documentation supporting the completion of a physical inventory of equipment and real property purchased with federal funds during the most recent two fiscal years. Additionally, for 1 of 2 sampled items, the University was unable to provide documentation supporting the required tagging and appropriate maintenance of property records for federally funded equipment. Identification as a Repeat Finding: No similar findings noted in the prior year.   Recommendation: We recommend that the University enhance its internal controls and procedures over the equipment and real property management compliance requirements. Views of Responsible Officials: The University eliminated the position of Procurement Manager several years back, which decentralized the responsibility for procurement. The change led to a loss of institutional knowledge, and interrupted policy and process enforcement campus wide. While Government Sponsored Programs and Research (“GSPAR”) has a process for recording and inventorying federal purchases, the information was not updated timely and did not provide required information. GSPAR will enhance update its inventory tracking process to capture required information. In addition, the grant onboarding process will be revised to emphasize key federal regulations and emphasize the importance of compliance. Reminders will also be provided during GSPAR’s semi-annual grant compliance workshops.

Federal Program Information: Higher Education Institutional Aid: Strengthening Historically Black Colleges and Universities Program (ALN: 84.031B and 84.031E) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): F. Equipment and Real Property Management - Equipment records shall be maintained, a physical inventory of equipment shall be taken at least once every 2 years and reconciled to the equipment records, an appropriate control system shall be used to safeguard equipment, and equipment shall be adequately maintained. Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. The Uniform Guidance further requires that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership. Condition: The University did not comply with the requirements of equipment and real property management. Cause: Insufficient administrative oversight and internal controls with respect to equipment and real property management. Effect or Potential Effect: The University did not comply with the requirements of equipment and real property management. Questioned Costs: None. Context: The University was unable to provide documentation supporting the completion of a physical inventory of equipment and real property purchased with federal funds during the most recent two fiscal years. Additionally, for 1 of 2 sampled items, the University was unable to provide documentation supporting the required tagging and appropriate maintenance of property records for federally funded equipment. Identification as a Repeat Finding: No similar findings noted in the prior year.   Recommendation: We recommend that the University enhance its internal controls and procedures over the equipment and real property management compliance requirements. Views of Responsible Officials: The University eliminated the position of Procurement Manager several years back, which decentralized the responsibility for procurement. The change led to a loss of institutional knowledge, and interrupted policy and process enforcement campus wide. While Government Sponsored Programs and Research (“GSPAR”) has a process for recording and inventorying federal purchases, the information was not updated timely and did not provide required information. GSPAR will enhance update its inventory tracking process to capture required information. In addition, the grant onboarding process will be revised to emphasize key federal regulations and emphasize the importance of compliance. Reminders will also be provided during GSPAR’s semi-annual grant compliance workshops.

Federal Program Information: TRIO Cluster (“TRIO”) (ALN: 84.042A and 84.217A) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility – Under the McNair Post-Baccalaureate Achievement (“McNair”) program, the University may award stipends of up to $2,800 per year for students engaged in approved research internships. Per 34 CFR 646.30(i), Student Support Services (“SSS”) grant aid may be provided to students who have completed their first two years of postsecondary education and who are receiving Federal Pell Grants under subpart 1 of part A of title IV of the Act if the institution demonstrates to the satisfaction of the Secretary that: • These students are at high risk of dropping out; and • It will first meet the needs of all its eligible first- and second-year students for services under this paragraph. Additionally, eligible participants for the SSS Program must meet the following requirements: • Is a citizen or national of the United States or meets the residency requirements for federal student financial assistance; • Is enrolled at the grantee institution or accepted for enrollment in the next academic term at that institution; • Has a need for academic support as determined by the grantee in order to pursue successfully a postsecondary educational program; and • Is a low-income individual, a first-generation college student, or an individual with disabilities (34 CFR sections 646.3 and 646.7) Condition: The University was unable to provide documentation supporting certain students’ eligibility to participate in the TRIO program or the amounts awarded for certain stipends. Cause: Insufficient administrative oversight and internal controls over TRIO program eligibility requirements. Effect or Potential Effect: The University was not in compliance with TRIO program eligibility requirements. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions during our testing: • For 3 of 16 student selected for testing, the University was unable to provide documentation supporting that approval was obtained from the U.S. Department of Education to increase the stipend amount awarded under the McNair program above the allowed annual maximum during the year before disbursements were made to the students. • For 1 of 4 students selected for testing, the University was not able to demonstrate that the criteria for awarding SSS TRIO grant aid to a student who had previously completed their first two years of postsecondary education was appropriately satisfied. • For 2 of 25 students selected for testing, the University was unable to provide documentation supporting the students’ eligibility for the TRIO program. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that documentation supporting TRIO program eligibility is appropriately retained as required. Views of Responsible Officials: The University experienced significant staffing changes in the TRIO programs. The changes in staffing lead to a loss of institutional knowledge, and interrupted policy and process enforcement. In many instance the documentation wasn’t available due to the transition of key individuals. During the period of staff transition for the McNair program, original communication showing previous approval from the Program Officer was not accessible. While the Department of Education provided correspondence granting McNair projects permission to reallocate travel funding to increase stipends for participants, given the limitations on travel capabilities due to the COVID-19 pandemic, which was subsequently confirmed by the Program Officer, we encountered difficulty locating explicit documentation approving the specific stipend increase amount. Continuous monitoring of program records will be implemented to ensure compliance with federal, Institutional and program requirements. The programs will review existing program operating procedures manuals to identify needed updates to current policies and procedures to align with federal, institutional and program requirements. The program stall will also engage in professional development opportunities to improve grant management.

Federal Program Information: TRIO Cluster (“TRIO”) (ALN: 84.042A and 84.217A) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility – Under the McNair Post-Baccalaureate Achievement (“McNair”) program, the University may award stipends of up to $2,800 per year for students engaged in approved research internships. Per 34 CFR 646.30(i), Student Support Services (“SSS”) grant aid may be provided to students who have completed their first two years of postsecondary education and who are receiving Federal Pell Grants under subpart 1 of part A of title IV of the Act if the institution demonstrates to the satisfaction of the Secretary that: • These students are at high risk of dropping out; and • It will first meet the needs of all its eligible first- and second-year students for services under this paragraph. Additionally, eligible participants for the SSS Program must meet the following requirements: • Is a citizen or national of the United States or meets the residency requirements for federal student financial assistance; • Is enrolled at the grantee institution or accepted for enrollment in the next academic term at that institution; • Has a need for academic support as determined by the grantee in order to pursue successfully a postsecondary educational program; and • Is a low-income individual, a first-generation college student, or an individual with disabilities (34 CFR sections 646.3 and 646.7) Condition: The University was unable to provide documentation supporting certain students’ eligibility to participate in the TRIO program or the amounts awarded for certain stipends. Cause: Insufficient administrative oversight and internal controls over TRIO program eligibility requirements. Effect or Potential Effect: The University was not in compliance with TRIO program eligibility requirements. Questioned Costs: Below reporting threshold. Context: We noted the following exceptions during our testing: • For 3 of 16 student selected for testing, the University was unable to provide documentation supporting that approval was obtained from the U.S. Department of Education to increase the stipend amount awarded under the McNair program above the allowed annual maximum during the year before disbursements were made to the students. • For 1 of 4 students selected for testing, the University was not able to demonstrate that the criteria for awarding SSS TRIO grant aid to a student who had previously completed their first two years of postsecondary education was appropriately satisfied. • For 2 of 25 students selected for testing, the University was unable to provide documentation supporting the students’ eligibility for the TRIO program. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that documentation supporting TRIO program eligibility is appropriately retained as required. Views of Responsible Officials: The University experienced significant staffing changes in the TRIO programs. The changes in staffing lead to a loss of institutional knowledge, and interrupted policy and process enforcement. In many instance the documentation wasn’t available due to the transition of key individuals. During the period of staff transition for the McNair program, original communication showing previous approval from the Program Officer was not accessible. While the Department of Education provided correspondence granting McNair projects permission to reallocate travel funding to increase stipends for participants, given the limitations on travel capabilities due to the COVID-19 pandemic, which was subsequently confirmed by the Program Officer, we encountered difficulty locating explicit documentation approving the specific stipend increase amount. Continuous monitoring of program records will be implemented to ensure compliance with federal, Institutional and program requirements. The programs will review existing program operating procedures manuals to identify needed updates to current policies and procedures to align with federal, institutional and program requirements. The program stall will also engage in professional development opportunities to improve grant management.

Federal Program Information: TRIO Cluster (“TRIO”) (84.047A, 84.042A and 84.217A) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - Grantees must submit an annual performance report to Department of Education each year of the project period. Certain key items contain critical information that should be included within the report and such information should be reconciled to the institution’s underlying records. Condition: The University did not include certain key line items in its annual TRIO reports and was unable to provide documentation supporting certain other information included within the reports. Cause: Insufficient administrative oversight and internal controls over TRIO program reporting requirements. Effect or Potential Effect: The University was not in compliance with TRIO program reporting requirements. Questioned Costs: None. Context: During our audit procedures, we noted that the University did not include certain key line items within their annual TRIO reports and was unable to provide documentation supporting certain other information included within the reports. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that TRIO reports are prepared in accordance with federal regulations and that supporting documentation is appropriately retained as required.   Views of Responsible Officials: The University experienced significant staffing changes in the TRIO programs. The changes in staffing lead to a loss of institutional knowledge, and interrupted policy and process enforcement. In many instance the documentation wasn’t available due to the transition of key individuals. Continuous monitoring of program records will be implemented to ensure compliance with federal, Institutional and program requirements. The programs will review existing program operating procedures manuals to identify needed updates to current policies and procedures to align with federal, institutional and program requirements. The program stall will also engage in professional development opportunities to improve grant management.

Federal Program Information: TRIO Cluster (“TRIO”) (84.047A, 84.042A and 84.217A) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - Grantees must submit an annual performance report to Department of Education each year of the project period. Certain key items contain critical information that should be included within the report and such information should be reconciled to the institution’s underlying records. Condition: The University did not include certain key line items in its annual TRIO reports and was unable to provide documentation supporting certain other information included within the reports. Cause: Insufficient administrative oversight and internal controls over TRIO program reporting requirements. Effect or Potential Effect: The University was not in compliance with TRIO program reporting requirements. Questioned Costs: None. Context: During our audit procedures, we noted that the University did not include certain key line items within their annual TRIO reports and was unable to provide documentation supporting certain other information included within the reports. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that TRIO reports are prepared in accordance with federal regulations and that supporting documentation is appropriately retained as required.   Views of Responsible Officials: The University experienced significant staffing changes in the TRIO programs. The changes in staffing lead to a loss of institutional knowledge, and interrupted policy and process enforcement. In many instance the documentation wasn’t available due to the transition of key individuals. Continuous monitoring of program records will be implemented to ensure compliance with federal, Institutional and program requirements. The programs will review existing program operating procedures manuals to identify needed updates to current policies and procedures to align with federal, institutional and program requirements. The program stall will also engage in professional development opportunities to improve grant management.

Federal Program Information: TRIO Cluster (“TRIO”) (84.047A, 84.042A and 84.217A) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting - Grantees must submit an annual performance report to Department of Education each year of the project period. Certain key items contain critical information that should be included within the report and such information should be reconciled to the institution’s underlying records. Condition: The University did not include certain key line items in its annual TRIO reports and was unable to provide documentation supporting certain other information included within the reports. Cause: Insufficient administrative oversight and internal controls over TRIO program reporting requirements. Effect or Potential Effect: The University was not in compliance with TRIO program reporting requirements. Questioned Costs: None. Context: During our audit procedures, we noted that the University did not include certain key line items within their annual TRIO reports and was unable to provide documentation supporting certain other information included within the reports. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that TRIO reports are prepared in accordance with federal regulations and that supporting documentation is appropriately retained as required.   Views of Responsible Officials: The University experienced significant staffing changes in the TRIO programs. The changes in staffing lead to a loss of institutional knowledge, and interrupted policy and process enforcement. In many instance the documentation wasn’t available due to the transition of key individuals. Continuous monitoring of program records will be implemented to ensure compliance with federal, Institutional and program requirements. The programs will review existing program operating procedures manuals to identify needed updates to current policies and procedures to align with federal, institutional and program requirements. The program stall will also engage in professional development opportunities to improve grant management.

Federal Program Information: Federal Perkins Loan program (“Perkins”) (84.038) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - A school must ensure that all of its loans are properly accounted for and updated on the National Student Loan Data System (“NSLDS”). It is the school's responsibility to ensure that the required reporting to NSLDS, including Perkins Loan account detail, is completed timely and accurately. The school should request a Perkins Loan Reconciliation Report (REC005) from the NSLDS Professional Access website and reconcile its records against the report to ensure its outstanding portfolio has been accurately reported to NSLDS. The total amount of loans and number of borrowers on NSLDS should reconcile with the school’s records, its third-party servicer records, and what is reported on its Fiscal Operations Report and Application to Participate (“FISAP”). Condition: The University was unable to provide a record of the total amount of loans and number of borrowers that reconciled with the amounts reported per the most recent FISAP and the Perkins Intent and Closeout form. Cause: Insufficient administrative oversight over the Perkins program liquidation requirements. Effect or Potential Effect: The total amount of loans and number of borrowers reported per the most recent FISAP and the Perkins Intent and Closeout form did not reconcile as required. Questioned Costs: Below reporting threshold. Context: The University was unable to provide records supporting the total amount of loans and number of borrowers that were reported during the closeout process for its Perkins loan program and in the latest reported FISAP. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its policies and procedures to ensure that the amount of loans and number of borrowers in the Perkins program are properly reconciled and accurately reported, in accordance with federal regulations. Views of Responsible Officials: Due to limitation on the FISAP, once the number of borrowers and loan balances are entered they cannot be changes, as a result there were minor differences, approximately 5 students and less than $10,000, that had been carried forward for several years. The Department of Education program officer, as well as the University’s loan servicer ECSI, have communicated that some of the numbers may differ due to payments or cancellations made after the loans were recorded. The Department of Education has accepted the information as final. The University has completed the Perkins Loan program liquidation process. The re-assignment of eligible loans to the Department of Education has been completed. Those not eligible for re-assignment have been deemed uncollectible and written-off. Once the University’s audit has been submitted we anticipated receiving the final close out letter from the Department of Education, which will officially close the Perkins Loan program at the University.