FAC Explorer

Audit 304975

FY End
2023-07-31
Total Expended
$1.30M
Findings
4
Programs
1
Organization: The Institute of World Politics (DC)
Year: 2023 Accepted: 2024-04-30
Auditor: Rsm US LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
395041 2023-002 Material Weakness - N
395042 2023-003 Material Weakness Yes ACELN
971483 2023-002 Material Weakness - N
971484 2023-003 Material Weakness Yes ACELN

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $1.30M Yes 2

Contacts

Name Title Type
HSLRE3E8BEP5 Walter Brown Auditee
2024622101 Thomas J. Sneeringer Auditor
No contacts on file

Notes to SEFA

Title: Basis of Presentation Accounting Policies: Expenditures reported on the schedule of expenditures of federal awards are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Expenditures for student financial aid programs are recognized when incurred and include the federal share of direct loan disbursements and administrative cost allowances, where applicable. De Minimis Rate Used: N Rate Explanation: The Institute participates in the Direct Loan Program and there is no overhead charges applicable for this type of federal award. The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal award activity of The Institute of World Politics (the Institute) under programs of the federal government for the year ended July 31, 2023. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the Institute, it is not intended to and does not present the financial position, changes in net assets, or cash flows of the Institute.
Title: Summary of Significant Accounting Policies Accounting Policies: Expenditures reported on the schedule of expenditures of federal awards are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Expenditures for student financial aid programs are recognized when incurred and include the federal share of direct loan disbursements and administrative cost allowances, where applicable. De Minimis Rate Used: N Rate Explanation: The Institute participates in the Direct Loan Program and there is no overhead charges applicable for this type of federal award. Expenditures reported on the schedule of expenditures of federal awards are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Expenditures for student financial aid programs are recognized when incurred and include the federal share of direct loan disbursements and administrative cost allowances, where applicable.
Title: Indirect Cost Rate Accounting Policies: Expenditures reported on the schedule of expenditures of federal awards are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Expenditures for student financial aid programs are recognized when incurred and include the federal share of direct loan disbursements and administrative cost allowances, where applicable. De Minimis Rate Used: N Rate Explanation: The Institute participates in the Direct Loan Program and there is no overhead charges applicable for this type of federal award. The Institute does not charge indirect costs to its federal awards. As such, the Institute has not elected to use the 10% de minimus indirect cost rate as allowed under the Uniform Guidance.
Title: Amounts to Subrecipients Accounting Policies: Expenditures reported on the schedule of expenditures of federal awards are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Expenditures for student financial aid programs are recognized when incurred and include the federal share of direct loan disbursements and administrative cost allowances, where applicable. De Minimis Rate Used: N Rate Explanation: The Institute participates in the Direct Loan Program and there is no overhead charges applicable for this type of federal award. There were no amounts paid to subrecipients for the year ended July 31, 2023.

Finding Details

Finding 2023-002
Finding No. 2023-002 Special Tests: Enrollment Reporting and Gramm-Leach-Bliley Act Compliance/Material Weakness Federal program: Student Financial Aid Cluster – Federal Direct Student Loans (ALN 84.268), U.S. Department of Education Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, requires the auditee to comply with Federal statues, regulations, terms and conditions of Federal awards that may have a direct and material effect on each of its major programs. The enrollment reporting compliance requirement, which falls under special tests, requires the Institute to certify enrollment information under the Direct loan programs every 60 days. The Gramm-Leach-Bliley Act over student information security, which falls under special tests, requires the Institute to have a written information security program that addresses seven specific required elements. Condition: Instances of noncompliance have been identified around major compliance requirements Enrollment Reporting and Gramm-Leach-Bliley Act, which are both part of special tests identified in the 2023 Compliance Supplement. Cause: The cause is due to a lack of sufficient internal control procedures in place to ensure compliance with material compliance requirements in the 2023 Compliance Supplement for its federal award. Effect: The findings resulted in a qualified opinion on the auditor’s report issued on compliance for major programs. Questioned costs: None Context: All of the Institute’s May 2023 graduates enrollment information was not reported within the 60 day requirement. In addition, the Institute does not have a formalized written information security program in place that addresses the required elements in the 2023 Compliance Supplement. Repeat finding: No Recommendation: We recommend that the Institute review the most recent Compliance Supplement, which outlines all compliance requirements for Direct loans under the Student Financial Assistance federal program to ensure all compliance requirements are being met. We encourage the Institute to monitor for any updates to the Compliance Supplement annually. Views of responsible officials: Management agrees with the finding. See corrective action plan.
Finding 2023-003
Internal Control over Compliance Finding No. 2023-003 – Documentation of Internal Controls Material Weakness Federal program: Student Financial Aid Cluster – Federal Direct Student Loans (ALN 84.268), U.S. Department of Education Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: We noted that controls identified by management over material compliance requirements lacked sufficient documentation to conclude application of controls is in place. Cause: The cause is due to ineffective internal control procedures with no physical indication of review or an audit trail that indicates that the identified control took place. Effect: Ineffective internal control procedures resulted in compliance findings. See Finding No. 2023-002. Reportable questioned costs: None Context: Internal controls in place over material compliance requirements identified by management had no documentation in place to demonstrate application of controls. Repeat finding: This is a repeat finding of 2022-001. Recommendation: We recommend that the Institute ensures that all internal control procedures in place include documentation that demonstrates application of controls. Views of responsible officials: Management agrees with the finding. See corrective action plan.
Finding 2023-002
Finding No. 2023-002 Special Tests: Enrollment Reporting and Gramm-Leach-Bliley Act Compliance/Material Weakness Federal program: Student Financial Aid Cluster – Federal Direct Student Loans (ALN 84.268), U.S. Department of Education Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, requires the auditee to comply with Federal statues, regulations, terms and conditions of Federal awards that may have a direct and material effect on each of its major programs. The enrollment reporting compliance requirement, which falls under special tests, requires the Institute to certify enrollment information under the Direct loan programs every 60 days. The Gramm-Leach-Bliley Act over student information security, which falls under special tests, requires the Institute to have a written information security program that addresses seven specific required elements. Condition: Instances of noncompliance have been identified around major compliance requirements Enrollment Reporting and Gramm-Leach-Bliley Act, which are both part of special tests identified in the 2023 Compliance Supplement. Cause: The cause is due to a lack of sufficient internal control procedures in place to ensure compliance with material compliance requirements in the 2023 Compliance Supplement for its federal award. Effect: The findings resulted in a qualified opinion on the auditor’s report issued on compliance for major programs. Questioned costs: None Context: All of the Institute’s May 2023 graduates enrollment information was not reported within the 60 day requirement. In addition, the Institute does not have a formalized written information security program in place that addresses the required elements in the 2023 Compliance Supplement. Repeat finding: No Recommendation: We recommend that the Institute review the most recent Compliance Supplement, which outlines all compliance requirements for Direct loans under the Student Financial Assistance federal program to ensure all compliance requirements are being met. We encourage the Institute to monitor for any updates to the Compliance Supplement annually. Views of responsible officials: Management agrees with the finding. See corrective action plan.
Finding 2023-003
Internal Control over Compliance Finding No. 2023-003 – Documentation of Internal Controls Material Weakness Federal program: Student Financial Aid Cluster – Federal Direct Student Loans (ALN 84.268), U.S. Department of Education Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: We noted that controls identified by management over material compliance requirements lacked sufficient documentation to conclude application of controls is in place. Cause: The cause is due to ineffective internal control procedures with no physical indication of review or an audit trail that indicates that the identified control took place. Effect: Ineffective internal control procedures resulted in compliance findings. See Finding No. 2023-002. Reportable questioned costs: None Context: Internal controls in place over material compliance requirements identified by management had no documentation in place to demonstrate application of controls. Repeat finding: This is a repeat finding of 2022-001. Recommendation: We recommend that the Institute ensures that all internal control procedures in place include documentation that demonstrates application of controls. Views of responsible officials: Management agrees with the finding. See corrective action plan.