Audit 30718

Criteria or specific requirement: At the time an institution makes a TEACH disbursement to a student, it must confirm that the student is eligible for the funds being disbursed (34 CFR 668.164(b)(3)). With the exception of FWS, disbursements are made on a payment period basis and the disbursement must be made during the current payment period (34 CFR 668.164(b)(1)). Condition: During our testing of disbursements to eligible students, we noted one instance of a TEACH award not being properly disbursed. Questioned costs: None reported. Context: In our eligibility sample of 40, one student received a TEACH award. The student did not receive the full award they were eligible for because the student had a four-term budget and the system automatically disburses based on a three-term budget. When a student has more than a three-term budget, the University must manually lock the disbursements. The University did not do that for this student. Cause: The student receiving TEACH funds was enrolled in four-terms, and the system automatically determines disbursements based on a three-term budget. Effect: The University did not disburse the full TEACH funds awarded to an eligible student until it was noted as part of the audit process. Repeat Finding: No. Recommendation: We recommend that the University disburses the remaining award to the student and implement procedures to ensure awards are properly disbursed to students who have more than a three-term budget.

Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.320 and 200.318(i); a nonfederal entity must have procedures that document the rationale for the method of procurement, selection of the contract type, basis for contractor selection, and the basis for the contract price. In addition, the guidance for the micro-purchase threshold is $10,000 unless other provisions have been followed allowing a higher threshold. Condition: During our testing of procurement procedures, we noted one item for which procurement procedures required for items purchased with federal funding were not followed. Questioned costs: None reported. Context: One of six samples tested did not have documentation to support the basis for the contractor selected for a small purchase transaction. Cause: The University did not follow procurement procedures required to be used when purchasing goods or services with federal funds because initially the item was purchased with non-federal funding. At a later time, a portion of the purchases was paid for with HEERF institutional funding. Effect: The University is not in compliance with procurement requirements to properly document the procurement rationale for goods or services paid for with federal funds. Repeat Finding: Yes. Prior year finding 2021-002 Recommendation: We recommend the University revise their processes to establish procedures that will ensure procurement policies are properly followed and documented for all general disbursements paid for by federal funds. View of Responsible Official: The University agrees with the finding.

Criteria or specific requirement: At the time an institution makes a TEACH disbursement to a student, it must confirm that the student is eligible for the funds being disbursed (34 CFR 668.164(b)(3)). With the exception of FWS, disbursements are made on a payment period basis and the disbursement must be made during the current payment period (34 CFR 668.164(b)(1)). Condition: During our testing of disbursements to eligible students, we noted one instance of a TEACH award not being properly disbursed. Questioned costs: None reported. Context: In our eligibility sample of 40, one student received a TEACH award. The student did not receive the full award they were eligible for because the student had a four-term budget and the system automatically disburses based on a three-term budget. When a student has more than a three-term budget, the University must manually lock the disbursements. The University did not do that for this student. Cause: The student receiving TEACH funds was enrolled in four-terms, and the system automatically determines disbursements based on a three-term budget. Effect: The University did not disburse the full TEACH funds awarded to an eligible student until it was noted as part of the audit process. Repeat Finding: No. Recommendation: We recommend that the University disburses the remaining award to the student and implement procedures to ensure awards are properly disbursed to students who have more than a three-term budget.

Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.320 and 200.318(i); a nonfederal entity must have procedures that document the rationale for the method of procurement, selection of the contract type, basis for contractor selection, and the basis for the contract price. In addition, the guidance for the micro-purchase threshold is $10,000 unless other provisions have been followed allowing a higher threshold. Condition: During our testing of procurement procedures, we noted one item for which procurement procedures required for items purchased with federal funding were not followed. Questioned costs: None reported. Context: One of six samples tested did not have documentation to support the basis for the contractor selected for a small purchase transaction. Cause: The University did not follow procurement procedures required to be used when purchasing goods or services with federal funds because initially the item was purchased with non-federal funding. At a later time, a portion of the purchases was paid for with HEERF institutional funding. Effect: The University is not in compliance with procurement requirements to properly document the procurement rationale for goods or services paid for with federal funds. Repeat Finding: Yes. Prior year finding 2021-002 Recommendation: We recommend the University revise their processes to establish procedures that will ensure procurement policies are properly followed and documented for all general disbursements paid for by federal funds. View of Responsible Official: The University agrees with the finding.