Audit 304642

Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - 84.063 Federal Pell Grant Program, 84.268 Federal Direct Student Loan Program Federal Award Identification Number and Year - 2022-2023 Pass through Entity - Not applicable Finding Type - Significant deficiency Repeat Finding - No Criteria - Schools may use a servicer or financial institution to deliver Title IV credit balances to a card or other access device. A School's Tier Two arrangements under 34 CFR 668.164 are subject to certain disclosures and other requirements: a. A school must disclose conspicuously on its Web site the contract(s) establishing the Tier Two arrangement (34 CFR 668.164(f)(4)(iii)). b. A school must also provide to U.S. Department of Education (ED) an up to date URL for the contract for publication in a centralized database accessible to the public.(34 CFR 668.164(f)(4)(iii)(B)) c. A school maintains documentation of that the school is performing such reviews at least every two years to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates (34 CFR 668.164(f)(4)(viii)(A)) d. Required cost information related to the arrangement must exist on the school’s website and that the cost information was updated within 60 days after the end of each award year (34 CFR 668.164(f)(4)(iv)(B)) Condition - The College did not follow all the Tier Two arrangement requirements and disclosures. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - The College did not: a. Post the Tier Two arrangement contract on its website b. Provide a URL for the contract to ED for publication in the Cash Management Contracts Database c. Document the due diligence review at least every two years to ascertain whether the fees imposed under the agreement are consistent with or below prevailing market rates d. Post the required cost information related to the arrangement on its website Cause and Effect - The College did not have a control in place to ensure all requirements and disclosures related to the Tier Two arrangements were met. As a result, these requirements were not met during the audit period. Recommendation - We recommend a control be put in place to ensure all requirements and disclosures are made related to the Tier Two arrangement. Views of Responsible Officials and Corrective Action Plan - The College will ensure that regulations related to Tier Two arrangements are reviewed. On a semiannual basis, the College will review all arrangements service providers for compliance with regulations. In addition, the College will review cash management regulations and references such as Dear Colleague letters on the subject matter to remain current with requirements.

Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - 84.063 Federal Pell Grant Program, 84.268 Federal Direct Student Loan Program Federal Award Identification Number and Year - 2022-2023 Pass through Entity - Not applicable Finding Type - Significant deficiency Repeat Finding - No Criteria - Schools may use a servicer or financial institution to deliver Title IV credit balances to a card or other access device. A School's Tier Two arrangements under 34 CFR 668.164 are subject to certain disclosures and other requirements: a. A school must disclose conspicuously on its Web site the contract(s) establishing the Tier Two arrangement (34 CFR 668.164(f)(4)(iii)). b. A school must also provide to U.S. Department of Education (ED) an up to date URL for the contract for publication in a centralized database accessible to the public.(34 CFR 668.164(f)(4)(iii)(B)) c. A school maintains documentation of that the school is performing such reviews at least every two years to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates (34 CFR 668.164(f)(4)(viii)(A)) d. Required cost information related to the arrangement must exist on the school’s website and that the cost information was updated within 60 days after the end of each award year (34 CFR 668.164(f)(4)(iv)(B)) Condition - The College did not follow all the Tier Two arrangement requirements and disclosures. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - The College did not: a. Post the Tier Two arrangement contract on its website b. Provide a URL for the contract to ED for publication in the Cash Management Contracts Database c. Document the due diligence review at least every two years to ascertain whether the fees imposed under the agreement are consistent with or below prevailing market rates d. Post the required cost information related to the arrangement on its website Cause and Effect - The College did not have a control in place to ensure all requirements and disclosures related to the Tier Two arrangements were met. As a result, these requirements were not met during the audit period. Recommendation - We recommend a control be put in place to ensure all requirements and disclosures are made related to the Tier Two arrangement. Views of Responsible Officials and Corrective Action Plan - The College will ensure that regulations related to Tier Two arrangements are reviewed. On a semiannual basis, the College will review all arrangements service providers for compliance with regulations. In addition, the College will review cash management regulations and references such as Dear Colleague letters on the subject matter to remain current with requirements.

Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - 84.063 Federal Pell Grant Program, 84.268 Federal Direct Student Loan Program Federal Award Identification Number and Year - 2022-2023 Pass through Entity - Not applicable Finding Type - Significant deficiency Repeat Finding - No Criteria - Schools may use a servicer or financial institution to deliver Title IV credit balances to a card or other access device. A School's Tier Two arrangements under 34 CFR 668.164 are subject to certain disclosures and other requirements: a. A school must disclose conspicuously on its Web site the contract(s) establishing the Tier Two arrangement (34 CFR 668.164(f)(4)(iii)). b. A school must also provide to U.S. Department of Education (ED) an up to date URL for the contract for publication in a centralized database accessible to the public.(34 CFR 668.164(f)(4)(iii)(B)) c. A school maintains documentation of that the school is performing such reviews at least every two years to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates (34 CFR 668.164(f)(4)(viii)(A)) d. Required cost information related to the arrangement must exist on the school’s website and that the cost information was updated within 60 days after the end of each award year (34 CFR 668.164(f)(4)(iv)(B)) Condition - The College did not follow all the Tier Two arrangement requirements and disclosures. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - The College did not: a. Post the Tier Two arrangement contract on its website b. Provide a URL for the contract to ED for publication in the Cash Management Contracts Database c. Document the due diligence review at least every two years to ascertain whether the fees imposed under the agreement are consistent with or below prevailing market rates d. Post the required cost information related to the arrangement on its website Cause and Effect - The College did not have a control in place to ensure all requirements and disclosures related to the Tier Two arrangements were met. As a result, these requirements were not met during the audit period. Recommendation - We recommend a control be put in place to ensure all requirements and disclosures are made related to the Tier Two arrangement. Views of Responsible Officials and Corrective Action Plan - The College will ensure that regulations related to Tier Two arrangements are reviewed. On a semiannual basis, the College will review all arrangements service providers for compliance with regulations. In addition, the College will review cash management regulations and references such as Dear Colleague letters on the subject matter to remain current with requirements.

Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - 84.063 Federal Pell Grant Program, 84.268 Federal Direct Student Loan Program Federal Award Identification Number and Year - 2022-2023 Pass through Entity - Not applicable Finding Type - Significant deficiency Repeat Finding - No Criteria - Schools may use a servicer or financial institution to deliver Title IV credit balances to a card or other access device. A School's Tier Two arrangements under 34 CFR 668.164 are subject to certain disclosures and other requirements: a. A school must disclose conspicuously on its Web site the contract(s) establishing the Tier Two arrangement (34 CFR 668.164(f)(4)(iii)). b. A school must also provide to U.S. Department of Education (ED) an up to date URL for the contract for publication in a centralized database accessible to the public.(34 CFR 668.164(f)(4)(iii)(B)) c. A school maintains documentation of that the school is performing such reviews at least every two years to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates (34 CFR 668.164(f)(4)(viii)(A)) d. Required cost information related to the arrangement must exist on the school’s website and that the cost information was updated within 60 days after the end of each award year (34 CFR 668.164(f)(4)(iv)(B)) Condition - The College did not follow all the Tier Two arrangement requirements and disclosures. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - The College did not: a. Post the Tier Two arrangement contract on its website b. Provide a URL for the contract to ED for publication in the Cash Management Contracts Database c. Document the due diligence review at least every two years to ascertain whether the fees imposed under the agreement are consistent with or below prevailing market rates d. Post the required cost information related to the arrangement on its website Cause and Effect - The College did not have a control in place to ensure all requirements and disclosures related to the Tier Two arrangements were met. As a result, these requirements were not met during the audit period. Recommendation - We recommend a control be put in place to ensure all requirements and disclosures are made related to the Tier Two arrangement. Views of Responsible Officials and Corrective Action Plan - The College will ensure that regulations related to Tier Two arrangements are reviewed. On a semiannual basis, the College will review all arrangements service providers for compliance with regulations. In addition, the College will review cash management regulations and references such as Dear Colleague letters on the subject matter to remain current with requirements.

Assistance Listing, Federal Agency, and Program Name - 93.354 U.S. Department of Health and Human Services, Research & Development (R&D) Cluster, Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response Federal Award Identification Number and Year - PH-2-533 Pass through Entity - Clemson University Finding Type - Significant deficiency Repeat Finding - No Criteria Per 2 CFR 200.510(b) - The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with § 200.502. Condition - The schedule of expenditures of federal awards (SEFA) was not complete. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Several versions of the SEFA were provided during the audit period and in the final review, the College identified a missing grant to be reported in the R&D cluster, which resulted in additional audit testing. For the R&D Cluster, ALN 93.354 (Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response), expenditures reported on the SEFA were understated by $229,506. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. For the R&D Cluster, ALN 93.354 (Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response), expenditures reported on the SEFA were understated by $229,506. This error has has been corrected on the SEFA as of June 30, 2023. Recommendation - The College should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - The College will ensure that the schedule of federal awards (SEFA) is reviewed for completeness. Going forward, the SEFA will compared with the prior year SEFA and a separate schedule of new awards for the current fiscal period. The results of this comparison will be reviewed by the grants office, the controller’s office and the Vice President’s office. This will increase the level of reviews to a three tiered process which should address issues of completeness of the SEFA.

Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - 84.063 Federal Pell Grant Program, 84.268 Federal Direct Student Loan Program Federal Award Identification Number and Year - 2022-2023 Pass through Entity - Not applicable Finding Type - Significant deficiency Repeat Finding - No Criteria - Schools may use a servicer or financial institution to deliver Title IV credit balances to a card or other access device. A School's Tier Two arrangements under 34 CFR 668.164 are subject to certain disclosures and other requirements: a. A school must disclose conspicuously on its Web site the contract(s) establishing the Tier Two arrangement (34 CFR 668.164(f)(4)(iii)). b. A school must also provide to U.S. Department of Education (ED) an up to date URL for the contract for publication in a centralized database accessible to the public.(34 CFR 668.164(f)(4)(iii)(B)) c. A school maintains documentation of that the school is performing such reviews at least every two years to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates (34 CFR 668.164(f)(4)(viii)(A)) d. Required cost information related to the arrangement must exist on the school’s website and that the cost information was updated within 60 days after the end of each award year (34 CFR 668.164(f)(4)(iv)(B)) Condition - The College did not follow all the Tier Two arrangement requirements and disclosures. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - The College did not: a. Post the Tier Two arrangement contract on its website b. Provide a URL for the contract to ED for publication in the Cash Management Contracts Database c. Document the due diligence review at least every two years to ascertain whether the fees imposed under the agreement are consistent with or below prevailing market rates d. Post the required cost information related to the arrangement on its website Cause and Effect - The College did not have a control in place to ensure all requirements and disclosures related to the Tier Two arrangements were met. As a result, these requirements were not met during the audit period. Recommendation - We recommend a control be put in place to ensure all requirements and disclosures are made related to the Tier Two arrangement. Views of Responsible Officials and Corrective Action Plan - The College will ensure that regulations related to Tier Two arrangements are reviewed. On a semiannual basis, the College will review all arrangements service providers for compliance with regulations. In addition, the College will review cash management regulations and references such as Dear Colleague letters on the subject matter to remain current with requirements.

Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - 84.063 Federal Pell Grant Program, 84.268 Federal Direct Student Loan Program Federal Award Identification Number and Year - 2022-2023 Pass through Entity - Not applicable Finding Type - Significant deficiency Repeat Finding - No Criteria - Schools may use a servicer or financial institution to deliver Title IV credit balances to a card or other access device. A School's Tier Two arrangements under 34 CFR 668.164 are subject to certain disclosures and other requirements: a. A school must disclose conspicuously on its Web site the contract(s) establishing the Tier Two arrangement (34 CFR 668.164(f)(4)(iii)). b. A school must also provide to U.S. Department of Education (ED) an up to date URL for the contract for publication in a centralized database accessible to the public.(34 CFR 668.164(f)(4)(iii)(B)) c. A school maintains documentation of that the school is performing such reviews at least every two years to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates (34 CFR 668.164(f)(4)(viii)(A)) d. Required cost information related to the arrangement must exist on the school’s website and that the cost information was updated within 60 days after the end of each award year (34 CFR 668.164(f)(4)(iv)(B)) Condition - The College did not follow all the Tier Two arrangement requirements and disclosures. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - The College did not: a. Post the Tier Two arrangement contract on its website b. Provide a URL for the contract to ED for publication in the Cash Management Contracts Database c. Document the due diligence review at least every two years to ascertain whether the fees imposed under the agreement are consistent with or below prevailing market rates d. Post the required cost information related to the arrangement on its website Cause and Effect - The College did not have a control in place to ensure all requirements and disclosures related to the Tier Two arrangements were met. As a result, these requirements were not met during the audit period. Recommendation - We recommend a control be put in place to ensure all requirements and disclosures are made related to the Tier Two arrangement. Views of Responsible Officials and Corrective Action Plan - The College will ensure that regulations related to Tier Two arrangements are reviewed. On a semiannual basis, the College will review all arrangements service providers for compliance with regulations. In addition, the College will review cash management regulations and references such as Dear Colleague letters on the subject matter to remain current with requirements.

Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - 84.063 Federal Pell Grant Program, 84.268 Federal Direct Student Loan Program Federal Award Identification Number and Year - 2022-2023 Pass through Entity - Not applicable Finding Type - Significant deficiency Repeat Finding - No Criteria - Schools may use a servicer or financial institution to deliver Title IV credit balances to a card or other access device. A School's Tier Two arrangements under 34 CFR 668.164 are subject to certain disclosures and other requirements: a. A school must disclose conspicuously on its Web site the contract(s) establishing the Tier Two arrangement (34 CFR 668.164(f)(4)(iii)). b. A school must also provide to U.S. Department of Education (ED) an up to date URL for the contract for publication in a centralized database accessible to the public.(34 CFR 668.164(f)(4)(iii)(B)) c. A school maintains documentation of that the school is performing such reviews at least every two years to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates (34 CFR 668.164(f)(4)(viii)(A)) d. Required cost information related to the arrangement must exist on the school’s website and that the cost information was updated within 60 days after the end of each award year (34 CFR 668.164(f)(4)(iv)(B)) Condition - The College did not follow all the Tier Two arrangement requirements and disclosures. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - The College did not: a. Post the Tier Two arrangement contract on its website b. Provide a URL for the contract to ED for publication in the Cash Management Contracts Database c. Document the due diligence review at least every two years to ascertain whether the fees imposed under the agreement are consistent with or below prevailing market rates d. Post the required cost information related to the arrangement on its website Cause and Effect - The College did not have a control in place to ensure all requirements and disclosures related to the Tier Two arrangements were met. As a result, these requirements were not met during the audit period. Recommendation - We recommend a control be put in place to ensure all requirements and disclosures are made related to the Tier Two arrangement. Views of Responsible Officials and Corrective Action Plan - The College will ensure that regulations related to Tier Two arrangements are reviewed. On a semiannual basis, the College will review all arrangements service providers for compliance with regulations. In addition, the College will review cash management regulations and references such as Dear Colleague letters on the subject matter to remain current with requirements.

Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - 84.063 Federal Pell Grant Program, 84.268 Federal Direct Student Loan Program Federal Award Identification Number and Year - 2022-2023 Pass through Entity - Not applicable Finding Type - Significant deficiency Repeat Finding - No Criteria - Schools may use a servicer or financial institution to deliver Title IV credit balances to a card or other access device. A School's Tier Two arrangements under 34 CFR 668.164 are subject to certain disclosures and other requirements: a. A school must disclose conspicuously on its Web site the contract(s) establishing the Tier Two arrangement (34 CFR 668.164(f)(4)(iii)). b. A school must also provide to U.S. Department of Education (ED) an up to date URL for the contract for publication in a centralized database accessible to the public.(34 CFR 668.164(f)(4)(iii)(B)) c. A school maintains documentation of that the school is performing such reviews at least every two years to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates (34 CFR 668.164(f)(4)(viii)(A)) d. Required cost information related to the arrangement must exist on the school’s website and that the cost information was updated within 60 days after the end of each award year (34 CFR 668.164(f)(4)(iv)(B)) Condition - The College did not follow all the Tier Two arrangement requirements and disclosures. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - The College did not: a. Post the Tier Two arrangement contract on its website b. Provide a URL for the contract to ED for publication in the Cash Management Contracts Database c. Document the due diligence review at least every two years to ascertain whether the fees imposed under the agreement are consistent with or below prevailing market rates d. Post the required cost information related to the arrangement on its website Cause and Effect - The College did not have a control in place to ensure all requirements and disclosures related to the Tier Two arrangements were met. As a result, these requirements were not met during the audit period. Recommendation - We recommend a control be put in place to ensure all requirements and disclosures are made related to the Tier Two arrangement. Views of Responsible Officials and Corrective Action Plan - The College will ensure that regulations related to Tier Two arrangements are reviewed. On a semiannual basis, the College will review all arrangements service providers for compliance with regulations. In addition, the College will review cash management regulations and references such as Dear Colleague letters on the subject matter to remain current with requirements.

Assistance Listing, Federal Agency, and Program Name - 93.354 U.S. Department of Health and Human Services, Research & Development (R&D) Cluster, Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response Federal Award Identification Number and Year - PH-2-533 Pass through Entity - Clemson University Finding Type - Significant deficiency Repeat Finding - No Criteria Per 2 CFR 200.510(b) - The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with § 200.502. Condition - The schedule of expenditures of federal awards (SEFA) was not complete. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Several versions of the SEFA were provided during the audit period and in the final review, the College identified a missing grant to be reported in the R&D cluster, which resulted in additional audit testing. For the R&D Cluster, ALN 93.354 (Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response), expenditures reported on the SEFA were understated by $229,506. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. For the R&D Cluster, ALN 93.354 (Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response), expenditures reported on the SEFA were understated by $229,506. This error has has been corrected on the SEFA as of June 30, 2023. Recommendation - The College should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - The College will ensure that the schedule of federal awards (SEFA) is reviewed for completeness. Going forward, the SEFA will compared with the prior year SEFA and a separate schedule of new awards for the current fiscal period. The results of this comparison will be reviewed by the grants office, the controller’s office and the Vice President’s office. This will increase the level of reviews to a three tiered process which should address issues of completeness of the SEFA.