2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-011 – Activities Allowed/Unallowed and Allowable Costs/Cost Principles
Federal Program Information:
Funding Agency: National Aeronautics and Space Administration, U.S.
Department of Education, and U.S. Department of Interior
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions, Indian
Post Secondary Schools
Assistance Listing Number: 43.008, 84.245, 15.058
Award Period: June 1, 2022 – May 31, 2023
Criteria: To be allowable under Federal awards, costs must be necessary and reasonable for the
performance and administration of the federal award. Costs must meet the following criteria: 1)
necessary and reasonable; 2) consistent with policies and procedures; 3) accorded consistent
treatment; and 4) are adequately documented.
Condition: We found the following in our review of federal expenditures:
Research and Development Cluster –
• One payroll transaction totaling $1,875 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Two transactions totaling $3,475 did not have accurate source documentation to support
the group insurance expenditures charged to the program.
• Two payroll transactions totaling $8,957 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Indian Post Secondary Schools
• One transaction totaling $212 did not have accurate source documentation to support the
travel expenditures charged to the program.
Questioned Costs: None exceeding $25,000.
Context: One of twenty-five payroll transactions tested for the Research and Development
Cluster. Four of fifty payroll and non-payroll transactions tested for the Tribally Controlled
Postsecondary Career and Technical Institutions program. One of twenty-five non-payroll
transactions tested for the Indian Post Secondary Schools.
Cause and Effect: NTU did not have effective internal controls to ensure federal expenditures are
accurately charged in accordance with federal activities allowed/unallowed and allowable
costs/cost principles requirements. As a result, NTU was not in compliance with these federal
requirements for the Research and Development Cluster, Tribally Controlled Post Secondary
Career and Technical Institutions and Indian Post Secondary programs.
Auditor’s Recommendation: Improve internal controls to ensure expenditures are allowable
under federal program requirements. This includes maintaining source documentation to support
the allocation of payroll costs.
Management’s Response: NTU will implement a monthly review process for all grant
expenditures to ensure that amounts charged to federal awards are accurately posted and
reflected in the accounting system. The Accounting Manager and Senior Accountant will review
all journal entries for accuracy. Payroll allocations provided by the Human Resources office will
also be included in the monthly review to verify the accuracy of payroll expenditures.
Additionally, Principal Investigators and program managers will be given read-only access to the
accounting system to review expenditure postings for accuracy.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-011 – Activities Allowed/Unallowed and Allowable Costs/Cost Principles
Federal Program Information:
Funding Agency: National Aeronautics and Space Administration, U.S.
Department of Education, and U.S. Department of Interior
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions, Indian
Post Secondary Schools
Assistance Listing Number: 43.008, 84.245, 15.058
Award Period: June 1, 2022 – May 31, 2023
Criteria: To be allowable under Federal awards, costs must be necessary and reasonable for the
performance and administration of the federal award. Costs must meet the following criteria: 1)
necessary and reasonable; 2) consistent with policies and procedures; 3) accorded consistent
treatment; and 4) are adequately documented.
Condition: We found the following in our review of federal expenditures:
Research and Development Cluster –
• One payroll transaction totaling $1,875 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Two transactions totaling $3,475 did not have accurate source documentation to support
the group insurance expenditures charged to the program.
• Two payroll transactions totaling $8,957 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Indian Post Secondary Schools
• One transaction totaling $212 did not have accurate source documentation to support the
travel expenditures charged to the program.
Questioned Costs: None exceeding $25,000.
Context: One of twenty-five payroll transactions tested for the Research and Development
Cluster. Four of fifty payroll and non-payroll transactions tested for the Tribally Controlled
Postsecondary Career and Technical Institutions program. One of twenty-five non-payroll
transactions tested for the Indian Post Secondary Schools.
Cause and Effect: NTU did not have effective internal controls to ensure federal expenditures are
accurately charged in accordance with federal activities allowed/unallowed and allowable
costs/cost principles requirements. As a result, NTU was not in compliance with these federal
requirements for the Research and Development Cluster, Tribally Controlled Post Secondary
Career and Technical Institutions and Indian Post Secondary programs.
Auditor’s Recommendation: Improve internal controls to ensure expenditures are allowable
under federal program requirements. This includes maintaining source documentation to support
the allocation of payroll costs.
Management’s Response: NTU will implement a monthly review process for all grant
expenditures to ensure that amounts charged to federal awards are accurately posted and
reflected in the accounting system. The Accounting Manager and Senior Accountant will review
all journal entries for accuracy. Payroll allocations provided by the Human Resources office will
also be included in the monthly review to verify the accuracy of payroll expenditures.
Additionally, Principal Investigators and program managers will be given read-only access to the
accounting system to review expenditure postings for accuracy.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-011 – Activities Allowed/Unallowed and Allowable Costs/Cost Principles
Federal Program Information:
Funding Agency: National Aeronautics and Space Administration, U.S.
Department of Education, and U.S. Department of Interior
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions, Indian
Post Secondary Schools
Assistance Listing Number: 43.008, 84.245, 15.058
Award Period: June 1, 2022 – May 31, 2023
Criteria: To be allowable under Federal awards, costs must be necessary and reasonable for the
performance and administration of the federal award. Costs must meet the following criteria: 1)
necessary and reasonable; 2) consistent with policies and procedures; 3) accorded consistent
treatment; and 4) are adequately documented.
Condition: We found the following in our review of federal expenditures:
Research and Development Cluster –
• One payroll transaction totaling $1,875 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Two transactions totaling $3,475 did not have accurate source documentation to support
the group insurance expenditures charged to the program.
• Two payroll transactions totaling $8,957 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Indian Post Secondary Schools
• One transaction totaling $212 did not have accurate source documentation to support the
travel expenditures charged to the program.
Questioned Costs: None exceeding $25,000.
Context: One of twenty-five payroll transactions tested for the Research and Development
Cluster. Four of fifty payroll and non-payroll transactions tested for the Tribally Controlled
Postsecondary Career and Technical Institutions program. One of twenty-five non-payroll
transactions tested for the Indian Post Secondary Schools.
Cause and Effect: NTU did not have effective internal controls to ensure federal expenditures are
accurately charged in accordance with federal activities allowed/unallowed and allowable
costs/cost principles requirements. As a result, NTU was not in compliance with these federal
requirements for the Research and Development Cluster, Tribally Controlled Post Secondary
Career and Technical Institutions and Indian Post Secondary programs.
Auditor’s Recommendation: Improve internal controls to ensure expenditures are allowable
under federal program requirements. This includes maintaining source documentation to support
the allocation of payroll costs.
Management’s Response: NTU will implement a monthly review process for all grant
expenditures to ensure that amounts charged to federal awards are accurately posted and
reflected in the accounting system. The Accounting Manager and Senior Accountant will review
all journal entries for accuracy. Payroll allocations provided by the Human Resources office will
also be included in the monthly review to verify the accuracy of payroll expenditures.
Additionally, Principal Investigators and program managers will be given read-only access to the
accounting system to review expenditure postings for accuracy.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-011 – Activities Allowed/Unallowed and Allowable Costs/Cost Principles
Federal Program Information:
Funding Agency: National Aeronautics and Space Administration, U.S.
Department of Education, and U.S. Department of Interior
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions, Indian
Post Secondary Schools
Assistance Listing Number: 43.008, 84.245, 15.058
Award Period: June 1, 2022 – May 31, 2023
Criteria: To be allowable under Federal awards, costs must be necessary and reasonable for the
performance and administration of the federal award. Costs must meet the following criteria: 1)
necessary and reasonable; 2) consistent with policies and procedures; 3) accorded consistent
treatment; and 4) are adequately documented.
Condition: We found the following in our review of federal expenditures:
Research and Development Cluster –
• One payroll transaction totaling $1,875 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Two transactions totaling $3,475 did not have accurate source documentation to support
the group insurance expenditures charged to the program.
• Two payroll transactions totaling $8,957 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Indian Post Secondary Schools
• One transaction totaling $212 did not have accurate source documentation to support the
travel expenditures charged to the program.
Questioned Costs: None exceeding $25,000.
Context: One of twenty-five payroll transactions tested for the Research and Development
Cluster. Four of fifty payroll and non-payroll transactions tested for the Tribally Controlled
Postsecondary Career and Technical Institutions program. One of twenty-five non-payroll
transactions tested for the Indian Post Secondary Schools.
Cause and Effect: NTU did not have effective internal controls to ensure federal expenditures are
accurately charged in accordance with federal activities allowed/unallowed and allowable
costs/cost principles requirements. As a result, NTU was not in compliance with these federal
requirements for the Research and Development Cluster, Tribally Controlled Post Secondary
Career and Technical Institutions and Indian Post Secondary programs.
Auditor’s Recommendation: Improve internal controls to ensure expenditures are allowable
under federal program requirements. This includes maintaining source documentation to support
the allocation of payroll costs.
Management’s Response: NTU will implement a monthly review process for all grant
expenditures to ensure that amounts charged to federal awards are accurately posted and
reflected in the accounting system. The Accounting Manager and Senior Accountant will review
all journal entries for accuracy. Payroll allocations provided by the Human Resources office will
also be included in the monthly review to verify the accuracy of payroll expenditures.
Additionally, Principal Investigators and program managers will be given read-only access to the
accounting system to review expenditure postings for accuracy.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-011 – Activities Allowed/Unallowed and Allowable Costs/Cost Principles
Federal Program Information:
Funding Agency: National Aeronautics and Space Administration, U.S.
Department of Education, and U.S. Department of Interior
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions, Indian
Post Secondary Schools
Assistance Listing Number: 43.008, 84.245, 15.058
Award Period: June 1, 2022 – May 31, 2023
Criteria: To be allowable under Federal awards, costs must be necessary and reasonable for the
performance and administration of the federal award. Costs must meet the following criteria: 1)
necessary and reasonable; 2) consistent with policies and procedures; 3) accorded consistent
treatment; and 4) are adequately documented.
Condition: We found the following in our review of federal expenditures:
Research and Development Cluster –
• One payroll transaction totaling $1,875 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Two transactions totaling $3,475 did not have accurate source documentation to support
the group insurance expenditures charged to the program.
• Two payroll transactions totaling $8,957 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Indian Post Secondary Schools
• One transaction totaling $212 did not have accurate source documentation to support the
travel expenditures charged to the program.
Questioned Costs: None exceeding $25,000.
Context: One of twenty-five payroll transactions tested for the Research and Development
Cluster. Four of fifty payroll and non-payroll transactions tested for the Tribally Controlled
Postsecondary Career and Technical Institutions program. One of twenty-five non-payroll
transactions tested for the Indian Post Secondary Schools.
Cause and Effect: NTU did not have effective internal controls to ensure federal expenditures are
accurately charged in accordance with federal activities allowed/unallowed and allowable
costs/cost principles requirements. As a result, NTU was not in compliance with these federal
requirements for the Research and Development Cluster, Tribally Controlled Post Secondary
Career and Technical Institutions and Indian Post Secondary programs.
Auditor’s Recommendation: Improve internal controls to ensure expenditures are allowable
under federal program requirements. This includes maintaining source documentation to support
the allocation of payroll costs.
Management’s Response: NTU will implement a monthly review process for all grant
expenditures to ensure that amounts charged to federal awards are accurately posted and
reflected in the accounting system. The Accounting Manager and Senior Accountant will review
all journal entries for accuracy. Payroll allocations provided by the Human Resources office will
also be included in the monthly review to verify the accuracy of payroll expenditures.
Additionally, Principal Investigators and program managers will be given read-only access to the
accounting system to review expenditure postings for accuracy.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-011 – Activities Allowed/Unallowed and Allowable Costs/Cost Principles
Federal Program Information:
Funding Agency: National Aeronautics and Space Administration, U.S.
Department of Education, and U.S. Department of Interior
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions, Indian
Post Secondary Schools
Assistance Listing Number: 43.008, 84.245, 15.058
Award Period: June 1, 2022 – May 31, 2023
Criteria: To be allowable under Federal awards, costs must be necessary and reasonable for the
performance and administration of the federal award. Costs must meet the following criteria: 1)
necessary and reasonable; 2) consistent with policies and procedures; 3) accorded consistent
treatment; and 4) are adequately documented.
Condition: We found the following in our review of federal expenditures:
Research and Development Cluster –
• One payroll transaction totaling $1,875 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Two transactions totaling $3,475 did not have accurate source documentation to support
the group insurance expenditures charged to the program.
• Two payroll transactions totaling $8,957 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Indian Post Secondary Schools
• One transaction totaling $212 did not have accurate source documentation to support the
travel expenditures charged to the program.
Questioned Costs: None exceeding $25,000.
Context: One of twenty-five payroll transactions tested for the Research and Development
Cluster. Four of fifty payroll and non-payroll transactions tested for the Tribally Controlled
Postsecondary Career and Technical Institutions program. One of twenty-five non-payroll
transactions tested for the Indian Post Secondary Schools.
Cause and Effect: NTU did not have effective internal controls to ensure federal expenditures are
accurately charged in accordance with federal activities allowed/unallowed and allowable
costs/cost principles requirements. As a result, NTU was not in compliance with these federal
requirements for the Research and Development Cluster, Tribally Controlled Post Secondary
Career and Technical Institutions and Indian Post Secondary programs.
Auditor’s Recommendation: Improve internal controls to ensure expenditures are allowable
under federal program requirements. This includes maintaining source documentation to support
the allocation of payroll costs.
Management’s Response: NTU will implement a monthly review process for all grant
expenditures to ensure that amounts charged to federal awards are accurately posted and
reflected in the accounting system. The Accounting Manager and Senior Accountant will review
all journal entries for accuracy. Payroll allocations provided by the Human Resources office will
also be included in the monthly review to verify the accuracy of payroll expenditures.
Additionally, Principal Investigators and program managers will be given read-only access to the
accounting system to review expenditure postings for accuracy.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-011 – Activities Allowed/Unallowed and Allowable Costs/Cost Principles
Federal Program Information:
Funding Agency: National Aeronautics and Space Administration, U.S.
Department of Education, and U.S. Department of Interior
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions, Indian
Post Secondary Schools
Assistance Listing Number: 43.008, 84.245, 15.058
Award Period: June 1, 2022 – May 31, 2023
Criteria: To be allowable under Federal awards, costs must be necessary and reasonable for the
performance and administration of the federal award. Costs must meet the following criteria: 1)
necessary and reasonable; 2) consistent with policies and procedures; 3) accorded consistent
treatment; and 4) are adequately documented.
Condition: We found the following in our review of federal expenditures:
Research and Development Cluster –
• One payroll transaction totaling $1,875 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Two transactions totaling $3,475 did not have accurate source documentation to support
the group insurance expenditures charged to the program.
• Two payroll transactions totaling $8,957 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Indian Post Secondary Schools
• One transaction totaling $212 did not have accurate source documentation to support the
travel expenditures charged to the program.
Questioned Costs: None exceeding $25,000.
Context: One of twenty-five payroll transactions tested for the Research and Development
Cluster. Four of fifty payroll and non-payroll transactions tested for the Tribally Controlled
Postsecondary Career and Technical Institutions program. One of twenty-five non-payroll
transactions tested for the Indian Post Secondary Schools.
Cause and Effect: NTU did not have effective internal controls to ensure federal expenditures are
accurately charged in accordance with federal activities allowed/unallowed and allowable
costs/cost principles requirements. As a result, NTU was not in compliance with these federal
requirements for the Research and Development Cluster, Tribally Controlled Post Secondary
Career and Technical Institutions and Indian Post Secondary programs.
Auditor’s Recommendation: Improve internal controls to ensure expenditures are allowable
under federal program requirements. This includes maintaining source documentation to support
the allocation of payroll costs.
Management’s Response: NTU will implement a monthly review process for all grant
expenditures to ensure that amounts charged to federal awards are accurately posted and
reflected in the accounting system. The Accounting Manager and Senior Accountant will review
all journal entries for accuracy. Payroll allocations provided by the Human Resources office will
also be included in the monthly review to verify the accuracy of payroll expenditures.
Additionally, Principal Investigators and program managers will be given read-only access to the
accounting system to review expenditure postings for accuracy.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-011 – Activities Allowed/Unallowed and Allowable Costs/Cost Principles
Federal Program Information:
Funding Agency: National Aeronautics and Space Administration, U.S.
Department of Education, and U.S. Department of Interior
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions, Indian
Post Secondary Schools
Assistance Listing Number: 43.008, 84.245, 15.058
Award Period: June 1, 2022 – May 31, 2023
Criteria: To be allowable under Federal awards, costs must be necessary and reasonable for the
performance and administration of the federal award. Costs must meet the following criteria: 1)
necessary and reasonable; 2) consistent with policies and procedures; 3) accorded consistent
treatment; and 4) are adequately documented.
Condition: We found the following in our review of federal expenditures:
Research and Development Cluster –
• One payroll transaction totaling $1,875 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Two transactions totaling $3,475 did not have accurate source documentation to support
the group insurance expenditures charged to the program.
• Two payroll transactions totaling $8,957 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Indian Post Secondary Schools
• One transaction totaling $212 did not have accurate source documentation to support the
travel expenditures charged to the program.
Questioned Costs: None exceeding $25,000.
Context: One of twenty-five payroll transactions tested for the Research and Development
Cluster. Four of fifty payroll and non-payroll transactions tested for the Tribally Controlled
Postsecondary Career and Technical Institutions program. One of twenty-five non-payroll
transactions tested for the Indian Post Secondary Schools.
Cause and Effect: NTU did not have effective internal controls to ensure federal expenditures are
accurately charged in accordance with federal activities allowed/unallowed and allowable
costs/cost principles requirements. As a result, NTU was not in compliance with these federal
requirements for the Research and Development Cluster, Tribally Controlled Post Secondary
Career and Technical Institutions and Indian Post Secondary programs.
Auditor’s Recommendation: Improve internal controls to ensure expenditures are allowable
under federal program requirements. This includes maintaining source documentation to support
the allocation of payroll costs.
Management’s Response: NTU will implement a monthly review process for all grant
expenditures to ensure that amounts charged to federal awards are accurately posted and
reflected in the accounting system. The Accounting Manager and Senior Accountant will review
all journal entries for accuracy. Payroll allocations provided by the Human Resources office will
also be included in the monthly review to verify the accuracy of payroll expenditures.
Additionally, Principal Investigators and program managers will be given read-only access to the
accounting system to review expenditure postings for accuracy.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-011 – Activities Allowed/Unallowed and Allowable Costs/Cost Principles
Federal Program Information:
Funding Agency: National Aeronautics and Space Administration, U.S.
Department of Education, and U.S. Department of Interior
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions, Indian
Post Secondary Schools
Assistance Listing Number: 43.008, 84.245, 15.058
Award Period: June 1, 2022 – May 31, 2023
Criteria: To be allowable under Federal awards, costs must be necessary and reasonable for the
performance and administration of the federal award. Costs must meet the following criteria: 1)
necessary and reasonable; 2) consistent with policies and procedures; 3) accorded consistent
treatment; and 4) are adequately documented.
Condition: We found the following in our review of federal expenditures:
Research and Development Cluster –
• One payroll transaction totaling $1,875 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Two transactions totaling $3,475 did not have accurate source documentation to support
the group insurance expenditures charged to the program.
• Two payroll transactions totaling $8,957 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Indian Post Secondary Schools
• One transaction totaling $212 did not have accurate source documentation to support the
travel expenditures charged to the program.
Questioned Costs: None exceeding $25,000.
Context: One of twenty-five payroll transactions tested for the Research and Development
Cluster. Four of fifty payroll and non-payroll transactions tested for the Tribally Controlled
Postsecondary Career and Technical Institutions program. One of twenty-five non-payroll
transactions tested for the Indian Post Secondary Schools.
Cause and Effect: NTU did not have effective internal controls to ensure federal expenditures are
accurately charged in accordance with federal activities allowed/unallowed and allowable
costs/cost principles requirements. As a result, NTU was not in compliance with these federal
requirements for the Research and Development Cluster, Tribally Controlled Post Secondary
Career and Technical Institutions and Indian Post Secondary programs.
Auditor’s Recommendation: Improve internal controls to ensure expenditures are allowable
under federal program requirements. This includes maintaining source documentation to support
the allocation of payroll costs.
Management’s Response: NTU will implement a monthly review process for all grant
expenditures to ensure that amounts charged to federal awards are accurately posted and
reflected in the accounting system. The Accounting Manager and Senior Accountant will review
all journal entries for accuracy. Payroll allocations provided by the Human Resources office will
also be included in the monthly review to verify the accuracy of payroll expenditures.
Additionally, Principal Investigators and program managers will be given read-only access to the
accounting system to review expenditure postings for accuracy.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-007 –Eligibility
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place to determine if students at NTU are eligible to receive
PELL and FSEOG. A student must (1) Qualify as an eligible student under 34 CFR Part 668,
Subpart C, (2) Is enrolled in an eligible undergraduate program and (3) Has financial need.
Condition: During our testing of 40 students, we noted the following:
• One student was awarded and disbursed more PELL funding than what a student with
their parental contribution should have been.
• Eight students did not have adequate supporting documentation to support the students
were eligible for PELL and/or FSEOG.
Questioned Costs: None.
Context: Nine out of forty students selected for eligibility testing during fiscal year 2023.
Cause and Effect: Internal controls were not implemented to ensure PELL funding provided to
students was accurate and documentation was available to support student eligibility under the
Student Financial Aid Cluster. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
PELL awards to students are accurately calculated and documentation is maintained to support
student eligibility determinations made by NTU for financial assistance.
Management’s Response: NTU will improve processes to ensure proper maintenance of source
documentation supporting student eligibility determinations. Additionally, staff will receive
comprehensive training sessions on eligibility determination and documentation requirements.
Responsible Party: Gary Segaye, Financial Aid Director and Dr. Delores Becenti, Director of
Enrollment
Anticipated Completion: July 2024
2023-008 – Special Tests and Provisions (Return of Title IV Funds)
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063
Award Period: June 1, 2022 – May 31, 2023
Criteria: When a recipient of Title IV grant or loan assistance withdraws from an institution
during a payment period or period of enrollment in which the recipient began attendance, the
institution must determine the amount of Title IV aid earned by the student as of the withdrawal
date. If the total amount of Title IV assistance earned by the student is less than the amount that
was disbursed to the student or on his or her behalf as of the date of the institution’s
determination that the student withdrew, the difference must be returned to the Title IV programs
no later than 45 days after the date of determination of a student’s withdrawal.
Condition: During our evaluation of Return of Title IV funds, we noted the following:
• NTU did not return funds to Title IV programs within the required 45-day timeframe. In
April 2024, $27,108 was remitted back to the U.S. Department of Education related to
Title IV programs for fiscal year 2023, which was well beyond the 45-day timeframe.
• Ten students tested did not have documentation to support that an R2T4 calculation was
performed.
Questioned Costs: None.
Context: Ten out of ten students tested that received Title IV student financial aid and did not
earn any credits in one of the semesters in fiscal year 2023.
Cause and Effect: NTU did not have effective internal controls to ensure return to Title IV funds
were performed timely and in accordance with federal requirements. Additionally, source
documentation was not maintained to support R2T4 calculations performed.
Auditor’s Recommendation: Establish formal procedures to ensure compliance with federal
student aid requirements. These policies and procedures should address students that withdrawal
from classes without notifying NTU. Consider performing student file audits to ensure Return of
Title IV calculations are performed. Lastly, consider increasing coordination efforts between the
finance department and the student financial aid department to ensure amounts due back to Title
IV programs are determined and remitted timely.
Management’s Response: NTU will establish formal policies and procedures for the Return of
Title IV Funds, ensuring alignment with U.S. Department of Education requirements. These
procedures will cover student withdrawals and the necessary data entry and monitoring within
the student information system. The Accounting Manager in the Student Accounts section of
NTU’s Business Office will review all student enrollment transactions to ensure compliance with
Return to Title IV requirements.
Responsible Party: Gary Segaye, Financial Aid Director, Delores Becenti, Enrollment Director,
and Geraldine Gamble, Accounting Manager
Anticipated Completion: July 2024
2023-009 – Special Tests and Provisions (Enrollment Reporting)
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063
Award Period: June 1, 2022 – May 31, 2023
Criteria: Institutions are required to report enrollment information under the Pell grant via the
National Student Loan Data System (NSLDS). Institutions must review, update, and verify
student enrollment statuses, program information, and effective dates that appear on the
Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS
Professional Access (NSLDSFAP) website.
Condition: During our evaluation of NSLDS enrollment reporting, we noted the following:
• Ten students did not have adequate supporting documentation to support their records
were updated in the NSLDS database.
Questioned Costs: None.
Context: Ten out of ten students that had an enrollment status change in fiscal year 2023.
Cause and Effect: Internal controls have not been designed and implemented to ensure
compliance with enrollment reporting requirements of the Student Financial Aid Cluster. 34 CFR
690.83(c) states, “In accordance with 34 CFR 668.84, the Secretary may impose a fine on the
institution if the institution fails to comply with the (reporting) requirements specified”. There is
a risk that NTU could face a potential fine if the required information is not being reported.
Auditors’ Recommendation: Develop and implement internal controls to ensure the enrollment
reporting requirements of the Student Financial Aid Cluster are met.
Management’s Response: NTU will develop formal policies and procedures regarding
enrollment reporting. This will include identifying the necessary enrollment data to update the
National Student Loan Database System (NSLDS) on a timely basis in accordance with the
Student Financial Aid Cluster requirements. NTU will be hiring an additional Financial Aid
Technician and a Financial Aid Counselor to assist in addressing this finding.
Responsible Party: Delores Becenti, Enrollment Director
Anticipated Completion: July 2024
2023-010 – Special Tests and Provisions (Gramm-Leach-Bliley Act – Student Information Security)
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063
Award Period: June 1, 2022 – May 31, 2023
Criteria: Title IV-eligible institutions are subject to the Gramm-Leach-Bliley Act (the “Act”). The Act
requires institutions to perform the following:
• Develop, implement, and maintain a written information security program.
• Designate the employee(s) responsible for coordinating the information security program.
• Identify and assess risks to customer information.
• Design and implement an information safeguards program
Condition: We found that NTU has developed an information security plan, however this plan has not been
formally adopted and implemented by NTU.
Questioned Costs: None.
Context: Evaluation of NTU’s information security protocols as it relates to the Gramm-Leach-Bliley Act
requirements of the Student Financial Aid Cluster.
Cause and Effect: NTU has not formally adopted and implemented an information security plan that
addresses the requirements of the Gramm-Leach-Bliley Act. NTU did not comply with OMB Uniform
Guidance related to special tests and provisions for the Student Financial Aid Cluster.
Auditor’s Recommendation: Formally adopt and implement an information security plan that adequately
address the requirements of the Student Financial Assistance Cluster.
Management’s Response: NTU has developed an information security plan, the plan will be presented to
NTU Board of Regents for ratification and adoption
Responsible Party: Jared Ribble, Information Technology Director
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-007 –Eligibility
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place to determine if students at NTU are eligible to receive
PELL and FSEOG. A student must (1) Qualify as an eligible student under 34 CFR Part 668,
Subpart C, (2) Is enrolled in an eligible undergraduate program and (3) Has financial need.
Condition: During our testing of 40 students, we noted the following:
• One student was awarded and disbursed more PELL funding than what a student with
their parental contribution should have been.
• Eight students did not have adequate supporting documentation to support the students
were eligible for PELL and/or FSEOG.
Questioned Costs: None.
Context: Nine out of forty students selected for eligibility testing during fiscal year 2023.
Cause and Effect: Internal controls were not implemented to ensure PELL funding provided to
students was accurate and documentation was available to support student eligibility under the
Student Financial Aid Cluster. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
PELL awards to students are accurately calculated and documentation is maintained to support
student eligibility determinations made by NTU for financial assistance.
Management’s Response: NTU will improve processes to ensure proper maintenance of source
documentation supporting student eligibility determinations. Additionally, staff will receive
comprehensive training sessions on eligibility determination and documentation requirements.
Responsible Party: Gary Segaye, Financial Aid Director and Dr. Delores Becenti, Director of
Enrollment
Anticipated Completion: July 2024
2023-008 – Special Tests and Provisions (Return of Title IV Funds)
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063
Award Period: June 1, 2022 – May 31, 2023
Criteria: When a recipient of Title IV grant or loan assistance withdraws from an institution
during a payment period or period of enrollment in which the recipient began attendance, the
institution must determine the amount of Title IV aid earned by the student as of the withdrawal
date. If the total amount of Title IV assistance earned by the student is less than the amount that
was disbursed to the student or on his or her behalf as of the date of the institution’s
determination that the student withdrew, the difference must be returned to the Title IV programs
no later than 45 days after the date of determination of a student’s withdrawal.
Condition: During our evaluation of Return of Title IV funds, we noted the following:
• NTU did not return funds to Title IV programs within the required 45-day timeframe. In
April 2024, $27,108 was remitted back to the U.S. Department of Education related to
Title IV programs for fiscal year 2023, which was well beyond the 45-day timeframe.
• Ten students tested did not have documentation to support that an R2T4 calculation was
performed.
Questioned Costs: None.
Context: Ten out of ten students tested that received Title IV student financial aid and did not
earn any credits in one of the semesters in fiscal year 2023.
Cause and Effect: NTU did not have effective internal controls to ensure return to Title IV funds
were performed timely and in accordance with federal requirements. Additionally, source
documentation was not maintained to support R2T4 calculations performed.
Auditor’s Recommendation: Establish formal procedures to ensure compliance with federal
student aid requirements. These policies and procedures should address students that withdrawal
from classes without notifying NTU. Consider performing student file audits to ensure Return of
Title IV calculations are performed. Lastly, consider increasing coordination efforts between the
finance department and the student financial aid department to ensure amounts due back to Title
IV programs are determined and remitted timely.
Management’s Response: NTU will establish formal policies and procedures for the Return of
Title IV Funds, ensuring alignment with U.S. Department of Education requirements. These
procedures will cover student withdrawals and the necessary data entry and monitoring within
the student information system. The Accounting Manager in the Student Accounts section of
NTU’s Business Office will review all student enrollment transactions to ensure compliance with
Return to Title IV requirements.
Responsible Party: Gary Segaye, Financial Aid Director, Delores Becenti, Enrollment Director,
and Geraldine Gamble, Accounting Manager
Anticipated Completion: July 2024
2023-009 – Special Tests and Provisions (Enrollment Reporting)
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063
Award Period: June 1, 2022 – May 31, 2023
Criteria: Institutions are required to report enrollment information under the Pell grant via the
National Student Loan Data System (NSLDS). Institutions must review, update, and verify
student enrollment statuses, program information, and effective dates that appear on the
Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS
Professional Access (NSLDSFAP) website.
Condition: During our evaluation of NSLDS enrollment reporting, we noted the following:
• Ten students did not have adequate supporting documentation to support their records
were updated in the NSLDS database.
Questioned Costs: None.
Context: Ten out of ten students that had an enrollment status change in fiscal year 2023.
Cause and Effect: Internal controls have not been designed and implemented to ensure
compliance with enrollment reporting requirements of the Student Financial Aid Cluster. 34 CFR
690.83(c) states, “In accordance with 34 CFR 668.84, the Secretary may impose a fine on the
institution if the institution fails to comply with the (reporting) requirements specified”. There is
a risk that NTU could face a potential fine if the required information is not being reported.
Auditors’ Recommendation: Develop and implement internal controls to ensure the enrollment
reporting requirements of the Student Financial Aid Cluster are met.
Management’s Response: NTU will develop formal policies and procedures regarding
enrollment reporting. This will include identifying the necessary enrollment data to update the
National Student Loan Database System (NSLDS) on a timely basis in accordance with the
Student Financial Aid Cluster requirements. NTU will be hiring an additional Financial Aid
Technician and a Financial Aid Counselor to assist in addressing this finding.
Responsible Party: Delores Becenti, Enrollment Director
Anticipated Completion: July 2024
2023-010 – Special Tests and Provisions (Gramm-Leach-Bliley Act – Student Information Security)
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063
Award Period: June 1, 2022 – May 31, 2023
Criteria: Title IV-eligible institutions are subject to the Gramm-Leach-Bliley Act (the “Act”). The Act
requires institutions to perform the following:
• Develop, implement, and maintain a written information security program.
• Designate the employee(s) responsible for coordinating the information security program.
• Identify and assess risks to customer information.
• Design and implement an information safeguards program
Condition: We found that NTU has developed an information security plan, however this plan has not been
formally adopted and implemented by NTU.
Questioned Costs: None.
Context: Evaluation of NTU’s information security protocols as it relates to the Gramm-Leach-Bliley Act
requirements of the Student Financial Aid Cluster.
Cause and Effect: NTU has not formally adopted and implemented an information security plan that
addresses the requirements of the Gramm-Leach-Bliley Act. NTU did not comply with OMB Uniform
Guidance related to special tests and provisions for the Student Financial Aid Cluster.
Auditor’s Recommendation: Formally adopt and implement an information security plan that adequately
address the requirements of the Student Financial Assistance Cluster.
Management’s Response: NTU has developed an information security plan, the plan will be presented to
NTU Board of Regents for ratification and adoption
Responsible Party: Jared Ribble, Information Technology Director
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-007 –Eligibility
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place to determine if students at NTU are eligible to receive
PELL and FSEOG. A student must (1) Qualify as an eligible student under 34 CFR Part 668,
Subpart C, (2) Is enrolled in an eligible undergraduate program and (3) Has financial need.
Condition: During our testing of 40 students, we noted the following:
• One student was awarded and disbursed more PELL funding than what a student with
their parental contribution should have been.
• Eight students did not have adequate supporting documentation to support the students
were eligible for PELL and/or FSEOG.
Questioned Costs: None.
Context: Nine out of forty students selected for eligibility testing during fiscal year 2023.
Cause and Effect: Internal controls were not implemented to ensure PELL funding provided to
students was accurate and documentation was available to support student eligibility under the
Student Financial Aid Cluster. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
PELL awards to students are accurately calculated and documentation is maintained to support
student eligibility determinations made by NTU for financial assistance.
Management’s Response: NTU will improve processes to ensure proper maintenance of source
documentation supporting student eligibility determinations. Additionally, staff will receive
comprehensive training sessions on eligibility determination and documentation requirements.
Responsible Party: Gary Segaye, Financial Aid Director and Dr. Delores Becenti, Director of
Enrollment
Anticipated Completion: July 2024
2023-008 – Special Tests and Provisions (Return of Title IV Funds)
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063
Award Period: June 1, 2022 – May 31, 2023
Criteria: When a recipient of Title IV grant or loan assistance withdraws from an institution
during a payment period or period of enrollment in which the recipient began attendance, the
institution must determine the amount of Title IV aid earned by the student as of the withdrawal
date. If the total amount of Title IV assistance earned by the student is less than the amount that
was disbursed to the student or on his or her behalf as of the date of the institution’s
determination that the student withdrew, the difference must be returned to the Title IV programs
no later than 45 days after the date of determination of a student’s withdrawal.
Condition: During our evaluation of Return of Title IV funds, we noted the following:
• NTU did not return funds to Title IV programs within the required 45-day timeframe. In
April 2024, $27,108 was remitted back to the U.S. Department of Education related to
Title IV programs for fiscal year 2023, which was well beyond the 45-day timeframe.
• Ten students tested did not have documentation to support that an R2T4 calculation was
performed.
Questioned Costs: None.
Context: Ten out of ten students tested that received Title IV student financial aid and did not
earn any credits in one of the semesters in fiscal year 2023.
Cause and Effect: NTU did not have effective internal controls to ensure return to Title IV funds
were performed timely and in accordance with federal requirements. Additionally, source
documentation was not maintained to support R2T4 calculations performed.
Auditor’s Recommendation: Establish formal procedures to ensure compliance with federal
student aid requirements. These policies and procedures should address students that withdrawal
from classes without notifying NTU. Consider performing student file audits to ensure Return of
Title IV calculations are performed. Lastly, consider increasing coordination efforts between the
finance department and the student financial aid department to ensure amounts due back to Title
IV programs are determined and remitted timely.
Management’s Response: NTU will establish formal policies and procedures for the Return of
Title IV Funds, ensuring alignment with U.S. Department of Education requirements. These
procedures will cover student withdrawals and the necessary data entry and monitoring within
the student information system. The Accounting Manager in the Student Accounts section of
NTU’s Business Office will review all student enrollment transactions to ensure compliance with
Return to Title IV requirements.
Responsible Party: Gary Segaye, Financial Aid Director, Delores Becenti, Enrollment Director,
and Geraldine Gamble, Accounting Manager
Anticipated Completion: July 2024
2023-009 – Special Tests and Provisions (Enrollment Reporting)
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063
Award Period: June 1, 2022 – May 31, 2023
Criteria: Institutions are required to report enrollment information under the Pell grant via the
National Student Loan Data System (NSLDS). Institutions must review, update, and verify
student enrollment statuses, program information, and effective dates that appear on the
Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS
Professional Access (NSLDSFAP) website.
Condition: During our evaluation of NSLDS enrollment reporting, we noted the following:
• Ten students did not have adequate supporting documentation to support their records
were updated in the NSLDS database.
Questioned Costs: None.
Context: Ten out of ten students that had an enrollment status change in fiscal year 2023.
Cause and Effect: Internal controls have not been designed and implemented to ensure
compliance with enrollment reporting requirements of the Student Financial Aid Cluster. 34 CFR
690.83(c) states, “In accordance with 34 CFR 668.84, the Secretary may impose a fine on the
institution if the institution fails to comply with the (reporting) requirements specified”. There is
a risk that NTU could face a potential fine if the required information is not being reported.
Auditors’ Recommendation: Develop and implement internal controls to ensure the enrollment
reporting requirements of the Student Financial Aid Cluster are met.
Management’s Response: NTU will develop formal policies and procedures regarding
enrollment reporting. This will include identifying the necessary enrollment data to update the
National Student Loan Database System (NSLDS) on a timely basis in accordance with the
Student Financial Aid Cluster requirements. NTU will be hiring an additional Financial Aid
Technician and a Financial Aid Counselor to assist in addressing this finding.
Responsible Party: Delores Becenti, Enrollment Director
Anticipated Completion: July 2024
2023-010 – Special Tests and Provisions (Gramm-Leach-Bliley Act – Student Information Security)
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063
Award Period: June 1, 2022 – May 31, 2023
Criteria: Title IV-eligible institutions are subject to the Gramm-Leach-Bliley Act (the “Act”). The Act
requires institutions to perform the following:
• Develop, implement, and maintain a written information security program.
• Designate the employee(s) responsible for coordinating the information security program.
• Identify and assess risks to customer information.
• Design and implement an information safeguards program
Condition: We found that NTU has developed an information security plan, however this plan has not been
formally adopted and implemented by NTU.
Questioned Costs: None.
Context: Evaluation of NTU’s information security protocols as it relates to the Gramm-Leach-Bliley Act
requirements of the Student Financial Aid Cluster.
Cause and Effect: NTU has not formally adopted and implemented an information security plan that
addresses the requirements of the Gramm-Leach-Bliley Act. NTU did not comply with OMB Uniform
Guidance related to special tests and provisions for the Student Financial Aid Cluster.
Auditor’s Recommendation: Formally adopt and implement an information security plan that adequately
address the requirements of the Student Financial Assistance Cluster.
Management’s Response: NTU has developed an information security plan, the plan will be presented to
NTU Board of Regents for ratification and adoption
Responsible Party: Jared Ribble, Information Technology Director
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-011 – Activities Allowed/Unallowed and Allowable Costs/Cost Principles
Federal Program Information:
Funding Agency: National Aeronautics and Space Administration, U.S.
Department of Education, and U.S. Department of Interior
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions, Indian
Post Secondary Schools
Assistance Listing Number: 43.008, 84.245, 15.058
Award Period: June 1, 2022 – May 31, 2023
Criteria: To be allowable under Federal awards, costs must be necessary and reasonable for the
performance and administration of the federal award. Costs must meet the following criteria: 1)
necessary and reasonable; 2) consistent with policies and procedures; 3) accorded consistent
treatment; and 4) are adequately documented.
Condition: We found the following in our review of federal expenditures:
Research and Development Cluster –
• One payroll transaction totaling $1,875 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Two transactions totaling $3,475 did not have accurate source documentation to support
the group insurance expenditures charged to the program.
• Two payroll transactions totaling $8,957 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Indian Post Secondary Schools
• One transaction totaling $212 did not have accurate source documentation to support the
travel expenditures charged to the program.
Questioned Costs: None exceeding $25,000.
Context: One of twenty-five payroll transactions tested for the Research and Development
Cluster. Four of fifty payroll and non-payroll transactions tested for the Tribally Controlled
Postsecondary Career and Technical Institutions program. One of twenty-five non-payroll
transactions tested for the Indian Post Secondary Schools.
Cause and Effect: NTU did not have effective internal controls to ensure federal expenditures are
accurately charged in accordance with federal activities allowed/unallowed and allowable
costs/cost principles requirements. As a result, NTU was not in compliance with these federal
requirements for the Research and Development Cluster, Tribally Controlled Post Secondary
Career and Technical Institutions and Indian Post Secondary programs.
Auditor’s Recommendation: Improve internal controls to ensure expenditures are allowable
under federal program requirements. This includes maintaining source documentation to support
the allocation of payroll costs.
Management’s Response: NTU will implement a monthly review process for all grant
expenditures to ensure that amounts charged to federal awards are accurately posted and
reflected in the accounting system. The Accounting Manager and Senior Accountant will review
all journal entries for accuracy. Payroll allocations provided by the Human Resources office will
also be included in the monthly review to verify the accuracy of payroll expenditures.
Additionally, Principal Investigators and program managers will be given read-only access to the
accounting system to review expenditure postings for accuracy.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-013 – Reporting
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Tribally Controlled Postsecondary Career and Technical
Institutions, Higher Education Emergency Relief Fund
(HEERF), Indian Post Secondary Schools
Assistance Listing Number: 84.245 and 84.425
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place to ensure performance and financial reporting
requirements for federal award programs are met
Condition: During our assessment of reporting requirements, we found the following:
Tribally Controlled Postsecondary Career and Technical Institutions –
• The annual performance report for the Tribally Controlled Postsecondary Career and
Technical Institutions was not available for review at the time of fieldwork.
Higher Education Emergency Relief Fund (HERF) –
• The annual performance for HEERF was not available for review at the time of
fieldwork.
Indian Post Secondary Schools –
• Two of two quarterly SF-425 were not available for our review at the time of fieldwork.
Questioned Costs: None
Context: One of one annual performance report required for the Tribally Controlled
Postsecondary Career and Technical Institutions, one of one annual performance reports required
by the HEERF program, two of four quarterly SF-425 reports required by the Indian Post
Secondary Schools.
Cause and Effect: Internal controls were not designed and implemented to ensure reporting
requirements were met. NTU did not comply with OMB Uniform Guidance related to reporting
for these programs.
Auditors’ Recommendation: Establish formal reporting procedures to ensure compliance with
federal reporting requirements.
Management’s Response: Formal policies and procedures for grants reporting will be developed
by NTU. NTU is developing a master file that will have a detailed schedules by funding source
which will identify the reporting requirements and deadlines for submission. Communication of
reporting due dates to appropriate NTU financial and programmatic personnel will be improved.
This will help ensure all financial and administrative reports are submitted in a timely manner.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-013 – Reporting
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Tribally Controlled Postsecondary Career and Technical
Institutions, Higher Education Emergency Relief Fund
(HEERF), Indian Post Secondary Schools
Assistance Listing Number: 84.245 and 84.425
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place to ensure performance and financial reporting
requirements for federal award programs are met
Condition: During our assessment of reporting requirements, we found the following:
Tribally Controlled Postsecondary Career and Technical Institutions –
• The annual performance report for the Tribally Controlled Postsecondary Career and
Technical Institutions was not available for review at the time of fieldwork.
Higher Education Emergency Relief Fund (HERF) –
• The annual performance for HEERF was not available for review at the time of
fieldwork.
Indian Post Secondary Schools –
• Two of two quarterly SF-425 were not available for our review at the time of fieldwork.
Questioned Costs: None
Context: One of one annual performance report required for the Tribally Controlled
Postsecondary Career and Technical Institutions, one of one annual performance reports required
by the HEERF program, two of four quarterly SF-425 reports required by the Indian Post
Secondary Schools.
Cause and Effect: Internal controls were not designed and implemented to ensure reporting
requirements were met. NTU did not comply with OMB Uniform Guidance related to reporting
for these programs.
Auditors’ Recommendation: Establish formal reporting procedures to ensure compliance with
federal reporting requirements.
Management’s Response: Formal policies and procedures for grants reporting will be developed
by NTU. NTU is developing a master file that will have a detailed schedules by funding source
which will identify the reporting requirements and deadlines for submission. Communication of
reporting due dates to appropriate NTU financial and programmatic personnel will be improved.
This will help ensure all financial and administrative reports are submitted in a timely manner.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-013 – Reporting
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Tribally Controlled Postsecondary Career and Technical
Institutions, Higher Education Emergency Relief Fund
(HEERF), Indian Post Secondary Schools
Assistance Listing Number: 84.245 and 84.425
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place to ensure performance and financial reporting
requirements for federal award programs are met
Condition: During our assessment of reporting requirements, we found the following:
Tribally Controlled Postsecondary Career and Technical Institutions –
• The annual performance report for the Tribally Controlled Postsecondary Career and
Technical Institutions was not available for review at the time of fieldwork.
Higher Education Emergency Relief Fund (HERF) –
• The annual performance for HEERF was not available for review at the time of
fieldwork.
Indian Post Secondary Schools –
• Two of two quarterly SF-425 were not available for our review at the time of fieldwork.
Questioned Costs: None
Context: One of one annual performance report required for the Tribally Controlled
Postsecondary Career and Technical Institutions, one of one annual performance reports required
by the HEERF program, two of four quarterly SF-425 reports required by the Indian Post
Secondary Schools.
Cause and Effect: Internal controls were not designed and implemented to ensure reporting
requirements were met. NTU did not comply with OMB Uniform Guidance related to reporting
for these programs.
Auditors’ Recommendation: Establish formal reporting procedures to ensure compliance with
federal reporting requirements.
Management’s Response: Formal policies and procedures for grants reporting will be developed
by NTU. NTU is developing a master file that will have a detailed schedules by funding source
which will identify the reporting requirements and deadlines for submission. Communication of
reporting due dates to appropriate NTU financial and programmatic personnel will be improved.
This will help ensure all financial and administrative reports are submitted in a timely manner.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-013 – Reporting
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Tribally Controlled Postsecondary Career and Technical
Institutions, Higher Education Emergency Relief Fund
(HEERF), Indian Post Secondary Schools
Assistance Listing Number: 84.245 and 84.425
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place to ensure performance and financial reporting
requirements for federal award programs are met
Condition: During our assessment of reporting requirements, we found the following:
Tribally Controlled Postsecondary Career and Technical Institutions –
• The annual performance report for the Tribally Controlled Postsecondary Career and
Technical Institutions was not available for review at the time of fieldwork.
Higher Education Emergency Relief Fund (HERF) –
• The annual performance for HEERF was not available for review at the time of
fieldwork.
Indian Post Secondary Schools –
• Two of two quarterly SF-425 were not available for our review at the time of fieldwork.
Questioned Costs: None
Context: One of one annual performance report required for the Tribally Controlled
Postsecondary Career and Technical Institutions, one of one annual performance reports required
by the HEERF program, two of four quarterly SF-425 reports required by the Indian Post
Secondary Schools.
Cause and Effect: Internal controls were not designed and implemented to ensure reporting
requirements were met. NTU did not comply with OMB Uniform Guidance related to reporting
for these programs.
Auditors’ Recommendation: Establish formal reporting procedures to ensure compliance with
federal reporting requirements.
Management’s Response: Formal policies and procedures for grants reporting will be developed
by NTU. NTU is developing a master file that will have a detailed schedules by funding source
which will identify the reporting requirements and deadlines for submission. Communication of
reporting due dates to appropriate NTU financial and programmatic personnel will be improved.
This will help ensure all financial and administrative reports are submitted in a timely manner.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-011 – Activities Allowed/Unallowed and Allowable Costs/Cost Principles
Federal Program Information:
Funding Agency: National Aeronautics and Space Administration, U.S.
Department of Education, and U.S. Department of Interior
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions, Indian
Post Secondary Schools
Assistance Listing Number: 43.008, 84.245, 15.058
Award Period: June 1, 2022 – May 31, 2023
Criteria: To be allowable under Federal awards, costs must be necessary and reasonable for the
performance and administration of the federal award. Costs must meet the following criteria: 1)
necessary and reasonable; 2) consistent with policies and procedures; 3) accorded consistent
treatment; and 4) are adequately documented.
Condition: We found the following in our review of federal expenditures:
Research and Development Cluster –
• One payroll transaction totaling $1,875 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Two transactions totaling $3,475 did not have accurate source documentation to support
the group insurance expenditures charged to the program.
• Two payroll transactions totaling $8,957 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Indian Post Secondary Schools
• One transaction totaling $212 did not have accurate source documentation to support the
travel expenditures charged to the program.
Questioned Costs: None exceeding $25,000.
Context: One of twenty-five payroll transactions tested for the Research and Development
Cluster. Four of fifty payroll and non-payroll transactions tested for the Tribally Controlled
Postsecondary Career and Technical Institutions program. One of twenty-five non-payroll
transactions tested for the Indian Post Secondary Schools.
Cause and Effect: NTU did not have effective internal controls to ensure federal expenditures are
accurately charged in accordance with federal activities allowed/unallowed and allowable
costs/cost principles requirements. As a result, NTU was not in compliance with these federal
requirements for the Research and Development Cluster, Tribally Controlled Post Secondary
Career and Technical Institutions and Indian Post Secondary programs.
Auditor’s Recommendation: Improve internal controls to ensure expenditures are allowable
under federal program requirements. This includes maintaining source documentation to support
the allocation of payroll costs.
Management’s Response: NTU will implement a monthly review process for all grant
expenditures to ensure that amounts charged to federal awards are accurately posted and
reflected in the accounting system. The Accounting Manager and Senior Accountant will review
all journal entries for accuracy. Payroll allocations provided by the Human Resources office will
also be included in the monthly review to verify the accuracy of payroll expenditures.
Additionally, Principal Investigators and program managers will be given read-only access to the
accounting system to review expenditure postings for accuracy.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-011 – Activities Allowed/Unallowed and Allowable Costs/Cost Principles
Federal Program Information:
Funding Agency: National Aeronautics and Space Administration, U.S.
Department of Education, and U.S. Department of Interior
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions, Indian
Post Secondary Schools
Assistance Listing Number: 43.008, 84.245, 15.058
Award Period: June 1, 2022 – May 31, 2023
Criteria: To be allowable under Federal awards, costs must be necessary and reasonable for the
performance and administration of the federal award. Costs must meet the following criteria: 1)
necessary and reasonable; 2) consistent with policies and procedures; 3) accorded consistent
treatment; and 4) are adequately documented.
Condition: We found the following in our review of federal expenditures:
Research and Development Cluster –
• One payroll transaction totaling $1,875 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Two transactions totaling $3,475 did not have accurate source documentation to support
the group insurance expenditures charged to the program.
• Two payroll transactions totaling $8,957 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Indian Post Secondary Schools
• One transaction totaling $212 did not have accurate source documentation to support the
travel expenditures charged to the program.
Questioned Costs: None exceeding $25,000.
Context: One of twenty-five payroll transactions tested for the Research and Development
Cluster. Four of fifty payroll and non-payroll transactions tested for the Tribally Controlled
Postsecondary Career and Technical Institutions program. One of twenty-five non-payroll
transactions tested for the Indian Post Secondary Schools.
Cause and Effect: NTU did not have effective internal controls to ensure federal expenditures are
accurately charged in accordance with federal activities allowed/unallowed and allowable
costs/cost principles requirements. As a result, NTU was not in compliance with these federal
requirements for the Research and Development Cluster, Tribally Controlled Post Secondary
Career and Technical Institutions and Indian Post Secondary programs.
Auditor’s Recommendation: Improve internal controls to ensure expenditures are allowable
under federal program requirements. This includes maintaining source documentation to support
the allocation of payroll costs.
Management’s Response: NTU will implement a monthly review process for all grant
expenditures to ensure that amounts charged to federal awards are accurately posted and
reflected in the accounting system. The Accounting Manager and Senior Accountant will review
all journal entries for accuracy. Payroll allocations provided by the Human Resources office will
also be included in the monthly review to verify the accuracy of payroll expenditures.
Additionally, Principal Investigators and program managers will be given read-only access to the
accounting system to review expenditure postings for accuracy.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-011 – Activities Allowed/Unallowed and Allowable Costs/Cost Principles
Federal Program Information:
Funding Agency: National Aeronautics and Space Administration, U.S.
Department of Education, and U.S. Department of Interior
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions, Indian
Post Secondary Schools
Assistance Listing Number: 43.008, 84.245, 15.058
Award Period: June 1, 2022 – May 31, 2023
Criteria: To be allowable under Federal awards, costs must be necessary and reasonable for the
performance and administration of the federal award. Costs must meet the following criteria: 1)
necessary and reasonable; 2) consistent with policies and procedures; 3) accorded consistent
treatment; and 4) are adequately documented.
Condition: We found the following in our review of federal expenditures:
Research and Development Cluster –
• One payroll transaction totaling $1,875 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Two transactions totaling $3,475 did not have accurate source documentation to support
the group insurance expenditures charged to the program.
• Two payroll transactions totaling $8,957 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Indian Post Secondary Schools
• One transaction totaling $212 did not have accurate source documentation to support the
travel expenditures charged to the program.
Questioned Costs: None exceeding $25,000.
Context: One of twenty-five payroll transactions tested for the Research and Development
Cluster. Four of fifty payroll and non-payroll transactions tested for the Tribally Controlled
Postsecondary Career and Technical Institutions program. One of twenty-five non-payroll
transactions tested for the Indian Post Secondary Schools.
Cause and Effect: NTU did not have effective internal controls to ensure federal expenditures are
accurately charged in accordance with federal activities allowed/unallowed and allowable
costs/cost principles requirements. As a result, NTU was not in compliance with these federal
requirements for the Research and Development Cluster, Tribally Controlled Post Secondary
Career and Technical Institutions and Indian Post Secondary programs.
Auditor’s Recommendation: Improve internal controls to ensure expenditures are allowable
under federal program requirements. This includes maintaining source documentation to support
the allocation of payroll costs.
Management’s Response: NTU will implement a monthly review process for all grant
expenditures to ensure that amounts charged to federal awards are accurately posted and
reflected in the accounting system. The Accounting Manager and Senior Accountant will review
all journal entries for accuracy. Payroll allocations provided by the Human Resources office will
also be included in the monthly review to verify the accuracy of payroll expenditures.
Additionally, Principal Investigators and program managers will be given read-only access to the
accounting system to review expenditure postings for accuracy.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-011 – Activities Allowed/Unallowed and Allowable Costs/Cost Principles
Federal Program Information:
Funding Agency: National Aeronautics and Space Administration, U.S.
Department of Education, and U.S. Department of Interior
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions, Indian
Post Secondary Schools
Assistance Listing Number: 43.008, 84.245, 15.058
Award Period: June 1, 2022 – May 31, 2023
Criteria: To be allowable under Federal awards, costs must be necessary and reasonable for the
performance and administration of the federal award. Costs must meet the following criteria: 1)
necessary and reasonable; 2) consistent with policies and procedures; 3) accorded consistent
treatment; and 4) are adequately documented.
Condition: We found the following in our review of federal expenditures:
Research and Development Cluster –
• One payroll transaction totaling $1,875 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Two transactions totaling $3,475 did not have accurate source documentation to support
the group insurance expenditures charged to the program.
• Two payroll transactions totaling $8,957 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Indian Post Secondary Schools
• One transaction totaling $212 did not have accurate source documentation to support the
travel expenditures charged to the program.
Questioned Costs: None exceeding $25,000.
Context: One of twenty-five payroll transactions tested for the Research and Development
Cluster. Four of fifty payroll and non-payroll transactions tested for the Tribally Controlled
Postsecondary Career and Technical Institutions program. One of twenty-five non-payroll
transactions tested for the Indian Post Secondary Schools.
Cause and Effect: NTU did not have effective internal controls to ensure federal expenditures are
accurately charged in accordance with federal activities allowed/unallowed and allowable
costs/cost principles requirements. As a result, NTU was not in compliance with these federal
requirements for the Research and Development Cluster, Tribally Controlled Post Secondary
Career and Technical Institutions and Indian Post Secondary programs.
Auditor’s Recommendation: Improve internal controls to ensure expenditures are allowable
under federal program requirements. This includes maintaining source documentation to support
the allocation of payroll costs.
Management’s Response: NTU will implement a monthly review process for all grant
expenditures to ensure that amounts charged to federal awards are accurately posted and
reflected in the accounting system. The Accounting Manager and Senior Accountant will review
all journal entries for accuracy. Payroll allocations provided by the Human Resources office will
also be included in the monthly review to verify the accuracy of payroll expenditures.
Additionally, Principal Investigators and program managers will be given read-only access to the
accounting system to review expenditure postings for accuracy.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-011 – Activities Allowed/Unallowed and Allowable Costs/Cost Principles
Federal Program Information:
Funding Agency: National Aeronautics and Space Administration, U.S.
Department of Education, and U.S. Department of Interior
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions, Indian
Post Secondary Schools
Assistance Listing Number: 43.008, 84.245, 15.058
Award Period: June 1, 2022 – May 31, 2023
Criteria: To be allowable under Federal awards, costs must be necessary and reasonable for the
performance and administration of the federal award. Costs must meet the following criteria: 1)
necessary and reasonable; 2) consistent with policies and procedures; 3) accorded consistent
treatment; and 4) are adequately documented.
Condition: We found the following in our review of federal expenditures:
Research and Development Cluster –
• One payroll transaction totaling $1,875 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Two transactions totaling $3,475 did not have accurate source documentation to support
the group insurance expenditures charged to the program.
• Two payroll transactions totaling $8,957 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Indian Post Secondary Schools
• One transaction totaling $212 did not have accurate source documentation to support the
travel expenditures charged to the program.
Questioned Costs: None exceeding $25,000.
Context: One of twenty-five payroll transactions tested for the Research and Development
Cluster. Four of fifty payroll and non-payroll transactions tested for the Tribally Controlled
Postsecondary Career and Technical Institutions program. One of twenty-five non-payroll
transactions tested for the Indian Post Secondary Schools.
Cause and Effect: NTU did not have effective internal controls to ensure federal expenditures are
accurately charged in accordance with federal activities allowed/unallowed and allowable
costs/cost principles requirements. As a result, NTU was not in compliance with these federal
requirements for the Research and Development Cluster, Tribally Controlled Post Secondary
Career and Technical Institutions and Indian Post Secondary programs.
Auditor’s Recommendation: Improve internal controls to ensure expenditures are allowable
under federal program requirements. This includes maintaining source documentation to support
the allocation of payroll costs.
Management’s Response: NTU will implement a monthly review process for all grant
expenditures to ensure that amounts charged to federal awards are accurately posted and
reflected in the accounting system. The Accounting Manager and Senior Accountant will review
all journal entries for accuracy. Payroll allocations provided by the Human Resources office will
also be included in the monthly review to verify the accuracy of payroll expenditures.
Additionally, Principal Investigators and program managers will be given read-only access to the
accounting system to review expenditure postings for accuracy.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-011 – Activities Allowed/Unallowed and Allowable Costs/Cost Principles
Federal Program Information:
Funding Agency: National Aeronautics and Space Administration, U.S.
Department of Education, and U.S. Department of Interior
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions, Indian
Post Secondary Schools
Assistance Listing Number: 43.008, 84.245, 15.058
Award Period: June 1, 2022 – May 31, 2023
Criteria: To be allowable under Federal awards, costs must be necessary and reasonable for the
performance and administration of the federal award. Costs must meet the following criteria: 1)
necessary and reasonable; 2) consistent with policies and procedures; 3) accorded consistent
treatment; and 4) are adequately documented.
Condition: We found the following in our review of federal expenditures:
Research and Development Cluster –
• One payroll transaction totaling $1,875 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Two transactions totaling $3,475 did not have accurate source documentation to support
the group insurance expenditures charged to the program.
• Two payroll transactions totaling $8,957 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Indian Post Secondary Schools
• One transaction totaling $212 did not have accurate source documentation to support the
travel expenditures charged to the program.
Questioned Costs: None exceeding $25,000.
Context: One of twenty-five payroll transactions tested for the Research and Development
Cluster. Four of fifty payroll and non-payroll transactions tested for the Tribally Controlled
Postsecondary Career and Technical Institutions program. One of twenty-five non-payroll
transactions tested for the Indian Post Secondary Schools.
Cause and Effect: NTU did not have effective internal controls to ensure federal expenditures are
accurately charged in accordance with federal activities allowed/unallowed and allowable
costs/cost principles requirements. As a result, NTU was not in compliance with these federal
requirements for the Research and Development Cluster, Tribally Controlled Post Secondary
Career and Technical Institutions and Indian Post Secondary programs.
Auditor’s Recommendation: Improve internal controls to ensure expenditures are allowable
under federal program requirements. This includes maintaining source documentation to support
the allocation of payroll costs.
Management’s Response: NTU will implement a monthly review process for all grant
expenditures to ensure that amounts charged to federal awards are accurately posted and
reflected in the accounting system. The Accounting Manager and Senior Accountant will review
all journal entries for accuracy. Payroll allocations provided by the Human Resources office will
also be included in the monthly review to verify the accuracy of payroll expenditures.
Additionally, Principal Investigators and program managers will be given read-only access to the
accounting system to review expenditure postings for accuracy.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-011 – Activities Allowed/Unallowed and Allowable Costs/Cost Principles
Federal Program Information:
Funding Agency: National Aeronautics and Space Administration, U.S.
Department of Education, and U.S. Department of Interior
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions, Indian
Post Secondary Schools
Assistance Listing Number: 43.008, 84.245, 15.058
Award Period: June 1, 2022 – May 31, 2023
Criteria: To be allowable under Federal awards, costs must be necessary and reasonable for the
performance and administration of the federal award. Costs must meet the following criteria: 1)
necessary and reasonable; 2) consistent with policies and procedures; 3) accorded consistent
treatment; and 4) are adequately documented.
Condition: We found the following in our review of federal expenditures:
Research and Development Cluster –
• One payroll transaction totaling $1,875 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Two transactions totaling $3,475 did not have accurate source documentation to support
the group insurance expenditures charged to the program.
• Two payroll transactions totaling $8,957 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Indian Post Secondary Schools
• One transaction totaling $212 did not have accurate source documentation to support the
travel expenditures charged to the program.
Questioned Costs: None exceeding $25,000.
Context: One of twenty-five payroll transactions tested for the Research and Development
Cluster. Four of fifty payroll and non-payroll transactions tested for the Tribally Controlled
Postsecondary Career and Technical Institutions program. One of twenty-five non-payroll
transactions tested for the Indian Post Secondary Schools.
Cause and Effect: NTU did not have effective internal controls to ensure federal expenditures are
accurately charged in accordance with federal activities allowed/unallowed and allowable
costs/cost principles requirements. As a result, NTU was not in compliance with these federal
requirements for the Research and Development Cluster, Tribally Controlled Post Secondary
Career and Technical Institutions and Indian Post Secondary programs.
Auditor’s Recommendation: Improve internal controls to ensure expenditures are allowable
under federal program requirements. This includes maintaining source documentation to support
the allocation of payroll costs.
Management’s Response: NTU will implement a monthly review process for all grant
expenditures to ensure that amounts charged to federal awards are accurately posted and
reflected in the accounting system. The Accounting Manager and Senior Accountant will review
all journal entries for accuracy. Payroll allocations provided by the Human Resources office will
also be included in the monthly review to verify the accuracy of payroll expenditures.
Additionally, Principal Investigators and program managers will be given read-only access to the
accounting system to review expenditure postings for accuracy.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-011 – Activities Allowed/Unallowed and Allowable Costs/Cost Principles
Federal Program Information:
Funding Agency: National Aeronautics and Space Administration, U.S.
Department of Education, and U.S. Department of Interior
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions, Indian
Post Secondary Schools
Assistance Listing Number: 43.008, 84.245, 15.058
Award Period: June 1, 2022 – May 31, 2023
Criteria: To be allowable under Federal awards, costs must be necessary and reasonable for the
performance and administration of the federal award. Costs must meet the following criteria: 1)
necessary and reasonable; 2) consistent with policies and procedures; 3) accorded consistent
treatment; and 4) are adequately documented.
Condition: We found the following in our review of federal expenditures:
Research and Development Cluster –
• One payroll transaction totaling $1,875 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Two transactions totaling $3,475 did not have accurate source documentation to support
the group insurance expenditures charged to the program.
• Two payroll transactions totaling $8,957 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Indian Post Secondary Schools
• One transaction totaling $212 did not have accurate source documentation to support the
travel expenditures charged to the program.
Questioned Costs: None exceeding $25,000.
Context: One of twenty-five payroll transactions tested for the Research and Development
Cluster. Four of fifty payroll and non-payroll transactions tested for the Tribally Controlled
Postsecondary Career and Technical Institutions program. One of twenty-five non-payroll
transactions tested for the Indian Post Secondary Schools.
Cause and Effect: NTU did not have effective internal controls to ensure federal expenditures are
accurately charged in accordance with federal activities allowed/unallowed and allowable
costs/cost principles requirements. As a result, NTU was not in compliance with these federal
requirements for the Research and Development Cluster, Tribally Controlled Post Secondary
Career and Technical Institutions and Indian Post Secondary programs.
Auditor’s Recommendation: Improve internal controls to ensure expenditures are allowable
under federal program requirements. This includes maintaining source documentation to support
the allocation of payroll costs.
Management’s Response: NTU will implement a monthly review process for all grant
expenditures to ensure that amounts charged to federal awards are accurately posted and
reflected in the accounting system. The Accounting Manager and Senior Accountant will review
all journal entries for accuracy. Payroll allocations provided by the Human Resources office will
also be included in the monthly review to verify the accuracy of payroll expenditures.
Additionally, Principal Investigators and program managers will be given read-only access to the
accounting system to review expenditure postings for accuracy.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-011 – Activities Allowed/Unallowed and Allowable Costs/Cost Principles
Federal Program Information:
Funding Agency: National Aeronautics and Space Administration, U.S.
Department of Education, and U.S. Department of Interior
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions, Indian
Post Secondary Schools
Assistance Listing Number: 43.008, 84.245, 15.058
Award Period: June 1, 2022 – May 31, 2023
Criteria: To be allowable under Federal awards, costs must be necessary and reasonable for the
performance and administration of the federal award. Costs must meet the following criteria: 1)
necessary and reasonable; 2) consistent with policies and procedures; 3) accorded consistent
treatment; and 4) are adequately documented.
Condition: We found the following in our review of federal expenditures:
Research and Development Cluster –
• One payroll transaction totaling $1,875 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Two transactions totaling $3,475 did not have accurate source documentation to support
the group insurance expenditures charged to the program.
• Two payroll transactions totaling $8,957 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Indian Post Secondary Schools
• One transaction totaling $212 did not have accurate source documentation to support the
travel expenditures charged to the program.
Questioned Costs: None exceeding $25,000.
Context: One of twenty-five payroll transactions tested for the Research and Development
Cluster. Four of fifty payroll and non-payroll transactions tested for the Tribally Controlled
Postsecondary Career and Technical Institutions program. One of twenty-five non-payroll
transactions tested for the Indian Post Secondary Schools.
Cause and Effect: NTU did not have effective internal controls to ensure federal expenditures are
accurately charged in accordance with federal activities allowed/unallowed and allowable
costs/cost principles requirements. As a result, NTU was not in compliance with these federal
requirements for the Research and Development Cluster, Tribally Controlled Post Secondary
Career and Technical Institutions and Indian Post Secondary programs.
Auditor’s Recommendation: Improve internal controls to ensure expenditures are allowable
under federal program requirements. This includes maintaining source documentation to support
the allocation of payroll costs.
Management’s Response: NTU will implement a monthly review process for all grant
expenditures to ensure that amounts charged to federal awards are accurately posted and
reflected in the accounting system. The Accounting Manager and Senior Accountant will review
all journal entries for accuracy. Payroll allocations provided by the Human Resources office will
also be included in the monthly review to verify the accuracy of payroll expenditures.
Additionally, Principal Investigators and program managers will be given read-only access to the
accounting system to review expenditure postings for accuracy.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-007 –Eligibility
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place to determine if students at NTU are eligible to receive
PELL and FSEOG. A student must (1) Qualify as an eligible student under 34 CFR Part 668,
Subpart C, (2) Is enrolled in an eligible undergraduate program and (3) Has financial need.
Condition: During our testing of 40 students, we noted the following:
• One student was awarded and disbursed more PELL funding than what a student with
their parental contribution should have been.
• Eight students did not have adequate supporting documentation to support the students
were eligible for PELL and/or FSEOG.
Questioned Costs: None.
Context: Nine out of forty students selected for eligibility testing during fiscal year 2023.
Cause and Effect: Internal controls were not implemented to ensure PELL funding provided to
students was accurate and documentation was available to support student eligibility under the
Student Financial Aid Cluster. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
PELL awards to students are accurately calculated and documentation is maintained to support
student eligibility determinations made by NTU for financial assistance.
Management’s Response: NTU will improve processes to ensure proper maintenance of source
documentation supporting student eligibility determinations. Additionally, staff will receive
comprehensive training sessions on eligibility determination and documentation requirements.
Responsible Party: Gary Segaye, Financial Aid Director and Dr. Delores Becenti, Director of
Enrollment
Anticipated Completion: July 2024
2023-008 – Special Tests and Provisions (Return of Title IV Funds)
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063
Award Period: June 1, 2022 – May 31, 2023
Criteria: When a recipient of Title IV grant or loan assistance withdraws from an institution
during a payment period or period of enrollment in which the recipient began attendance, the
institution must determine the amount of Title IV aid earned by the student as of the withdrawal
date. If the total amount of Title IV assistance earned by the student is less than the amount that
was disbursed to the student or on his or her behalf as of the date of the institution’s
determination that the student withdrew, the difference must be returned to the Title IV programs
no later than 45 days after the date of determination of a student’s withdrawal.
Condition: During our evaluation of Return of Title IV funds, we noted the following:
• NTU did not return funds to Title IV programs within the required 45-day timeframe. In
April 2024, $27,108 was remitted back to the U.S. Department of Education related to
Title IV programs for fiscal year 2023, which was well beyond the 45-day timeframe.
• Ten students tested did not have documentation to support that an R2T4 calculation was
performed.
Questioned Costs: None.
Context: Ten out of ten students tested that received Title IV student financial aid and did not
earn any credits in one of the semesters in fiscal year 2023.
Cause and Effect: NTU did not have effective internal controls to ensure return to Title IV funds
were performed timely and in accordance with federal requirements. Additionally, source
documentation was not maintained to support R2T4 calculations performed.
Auditor’s Recommendation: Establish formal procedures to ensure compliance with federal
student aid requirements. These policies and procedures should address students that withdrawal
from classes without notifying NTU. Consider performing student file audits to ensure Return of
Title IV calculations are performed. Lastly, consider increasing coordination efforts between the
finance department and the student financial aid department to ensure amounts due back to Title
IV programs are determined and remitted timely.
Management’s Response: NTU will establish formal policies and procedures for the Return of
Title IV Funds, ensuring alignment with U.S. Department of Education requirements. These
procedures will cover student withdrawals and the necessary data entry and monitoring within
the student information system. The Accounting Manager in the Student Accounts section of
NTU’s Business Office will review all student enrollment transactions to ensure compliance with
Return to Title IV requirements.
Responsible Party: Gary Segaye, Financial Aid Director, Delores Becenti, Enrollment Director,
and Geraldine Gamble, Accounting Manager
Anticipated Completion: July 2024
2023-009 – Special Tests and Provisions (Enrollment Reporting)
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063
Award Period: June 1, 2022 – May 31, 2023
Criteria: Institutions are required to report enrollment information under the Pell grant via the
National Student Loan Data System (NSLDS). Institutions must review, update, and verify
student enrollment statuses, program information, and effective dates that appear on the
Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS
Professional Access (NSLDSFAP) website.
Condition: During our evaluation of NSLDS enrollment reporting, we noted the following:
• Ten students did not have adequate supporting documentation to support their records
were updated in the NSLDS database.
Questioned Costs: None.
Context: Ten out of ten students that had an enrollment status change in fiscal year 2023.
Cause and Effect: Internal controls have not been designed and implemented to ensure
compliance with enrollment reporting requirements of the Student Financial Aid Cluster. 34 CFR
690.83(c) states, “In accordance with 34 CFR 668.84, the Secretary may impose a fine on the
institution if the institution fails to comply with the (reporting) requirements specified”. There is
a risk that NTU could face a potential fine if the required information is not being reported.
Auditors’ Recommendation: Develop and implement internal controls to ensure the enrollment
reporting requirements of the Student Financial Aid Cluster are met.
Management’s Response: NTU will develop formal policies and procedures regarding
enrollment reporting. This will include identifying the necessary enrollment data to update the
National Student Loan Database System (NSLDS) on a timely basis in accordance with the
Student Financial Aid Cluster requirements. NTU will be hiring an additional Financial Aid
Technician and a Financial Aid Counselor to assist in addressing this finding.
Responsible Party: Delores Becenti, Enrollment Director
Anticipated Completion: July 2024
2023-010 – Special Tests and Provisions (Gramm-Leach-Bliley Act – Student Information Security)
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063
Award Period: June 1, 2022 – May 31, 2023
Criteria: Title IV-eligible institutions are subject to the Gramm-Leach-Bliley Act (the “Act”). The Act
requires institutions to perform the following:
• Develop, implement, and maintain a written information security program.
• Designate the employee(s) responsible for coordinating the information security program.
• Identify and assess risks to customer information.
• Design and implement an information safeguards program
Condition: We found that NTU has developed an information security plan, however this plan has not been
formally adopted and implemented by NTU.
Questioned Costs: None.
Context: Evaluation of NTU’s information security protocols as it relates to the Gramm-Leach-Bliley Act
requirements of the Student Financial Aid Cluster.
Cause and Effect: NTU has not formally adopted and implemented an information security plan that
addresses the requirements of the Gramm-Leach-Bliley Act. NTU did not comply with OMB Uniform
Guidance related to special tests and provisions for the Student Financial Aid Cluster.
Auditor’s Recommendation: Formally adopt and implement an information security plan that adequately
address the requirements of the Student Financial Assistance Cluster.
Management’s Response: NTU has developed an information security plan, the plan will be presented to
NTU Board of Regents for ratification and adoption
Responsible Party: Jared Ribble, Information Technology Director
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-007 –Eligibility
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place to determine if students at NTU are eligible to receive
PELL and FSEOG. A student must (1) Qualify as an eligible student under 34 CFR Part 668,
Subpart C, (2) Is enrolled in an eligible undergraduate program and (3) Has financial need.
Condition: During our testing of 40 students, we noted the following:
• One student was awarded and disbursed more PELL funding than what a student with
their parental contribution should have been.
• Eight students did not have adequate supporting documentation to support the students
were eligible for PELL and/or FSEOG.
Questioned Costs: None.
Context: Nine out of forty students selected for eligibility testing during fiscal year 2023.
Cause and Effect: Internal controls were not implemented to ensure PELL funding provided to
students was accurate and documentation was available to support student eligibility under the
Student Financial Aid Cluster. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
PELL awards to students are accurately calculated and documentation is maintained to support
student eligibility determinations made by NTU for financial assistance.
Management’s Response: NTU will improve processes to ensure proper maintenance of source
documentation supporting student eligibility determinations. Additionally, staff will receive
comprehensive training sessions on eligibility determination and documentation requirements.
Responsible Party: Gary Segaye, Financial Aid Director and Dr. Delores Becenti, Director of
Enrollment
Anticipated Completion: July 2024
2023-008 – Special Tests and Provisions (Return of Title IV Funds)
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063
Award Period: June 1, 2022 – May 31, 2023
Criteria: When a recipient of Title IV grant or loan assistance withdraws from an institution
during a payment period or period of enrollment in which the recipient began attendance, the
institution must determine the amount of Title IV aid earned by the student as of the withdrawal
date. If the total amount of Title IV assistance earned by the student is less than the amount that
was disbursed to the student or on his or her behalf as of the date of the institution’s
determination that the student withdrew, the difference must be returned to the Title IV programs
no later than 45 days after the date of determination of a student’s withdrawal.
Condition: During our evaluation of Return of Title IV funds, we noted the following:
• NTU did not return funds to Title IV programs within the required 45-day timeframe. In
April 2024, $27,108 was remitted back to the U.S. Department of Education related to
Title IV programs for fiscal year 2023, which was well beyond the 45-day timeframe.
• Ten students tested did not have documentation to support that an R2T4 calculation was
performed.
Questioned Costs: None.
Context: Ten out of ten students tested that received Title IV student financial aid and did not
earn any credits in one of the semesters in fiscal year 2023.
Cause and Effect: NTU did not have effective internal controls to ensure return to Title IV funds
were performed timely and in accordance with federal requirements. Additionally, source
documentation was not maintained to support R2T4 calculations performed.
Auditor’s Recommendation: Establish formal procedures to ensure compliance with federal
student aid requirements. These policies and procedures should address students that withdrawal
from classes without notifying NTU. Consider performing student file audits to ensure Return of
Title IV calculations are performed. Lastly, consider increasing coordination efforts between the
finance department and the student financial aid department to ensure amounts due back to Title
IV programs are determined and remitted timely.
Management’s Response: NTU will establish formal policies and procedures for the Return of
Title IV Funds, ensuring alignment with U.S. Department of Education requirements. These
procedures will cover student withdrawals and the necessary data entry and monitoring within
the student information system. The Accounting Manager in the Student Accounts section of
NTU’s Business Office will review all student enrollment transactions to ensure compliance with
Return to Title IV requirements.
Responsible Party: Gary Segaye, Financial Aid Director, Delores Becenti, Enrollment Director,
and Geraldine Gamble, Accounting Manager
Anticipated Completion: July 2024
2023-009 – Special Tests and Provisions (Enrollment Reporting)
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063
Award Period: June 1, 2022 – May 31, 2023
Criteria: Institutions are required to report enrollment information under the Pell grant via the
National Student Loan Data System (NSLDS). Institutions must review, update, and verify
student enrollment statuses, program information, and effective dates that appear on the
Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS
Professional Access (NSLDSFAP) website.
Condition: During our evaluation of NSLDS enrollment reporting, we noted the following:
• Ten students did not have adequate supporting documentation to support their records
were updated in the NSLDS database.
Questioned Costs: None.
Context: Ten out of ten students that had an enrollment status change in fiscal year 2023.
Cause and Effect: Internal controls have not been designed and implemented to ensure
compliance with enrollment reporting requirements of the Student Financial Aid Cluster. 34 CFR
690.83(c) states, “In accordance with 34 CFR 668.84, the Secretary may impose a fine on the
institution if the institution fails to comply with the (reporting) requirements specified”. There is
a risk that NTU could face a potential fine if the required information is not being reported.
Auditors’ Recommendation: Develop and implement internal controls to ensure the enrollment
reporting requirements of the Student Financial Aid Cluster are met.
Management’s Response: NTU will develop formal policies and procedures regarding
enrollment reporting. This will include identifying the necessary enrollment data to update the
National Student Loan Database System (NSLDS) on a timely basis in accordance with the
Student Financial Aid Cluster requirements. NTU will be hiring an additional Financial Aid
Technician and a Financial Aid Counselor to assist in addressing this finding.
Responsible Party: Delores Becenti, Enrollment Director
Anticipated Completion: July 2024
2023-010 – Special Tests and Provisions (Gramm-Leach-Bliley Act – Student Information Security)
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063
Award Period: June 1, 2022 – May 31, 2023
Criteria: Title IV-eligible institutions are subject to the Gramm-Leach-Bliley Act (the “Act”). The Act
requires institutions to perform the following:
• Develop, implement, and maintain a written information security program.
• Designate the employee(s) responsible for coordinating the information security program.
• Identify and assess risks to customer information.
• Design and implement an information safeguards program
Condition: We found that NTU has developed an information security plan, however this plan has not been
formally adopted and implemented by NTU.
Questioned Costs: None.
Context: Evaluation of NTU’s information security protocols as it relates to the Gramm-Leach-Bliley Act
requirements of the Student Financial Aid Cluster.
Cause and Effect: NTU has not formally adopted and implemented an information security plan that
addresses the requirements of the Gramm-Leach-Bliley Act. NTU did not comply with OMB Uniform
Guidance related to special tests and provisions for the Student Financial Aid Cluster.
Auditor’s Recommendation: Formally adopt and implement an information security plan that adequately
address the requirements of the Student Financial Assistance Cluster.
Management’s Response: NTU has developed an information security plan, the plan will be presented to
NTU Board of Regents for ratification and adoption
Responsible Party: Jared Ribble, Information Technology Director
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-007 –Eligibility
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place to determine if students at NTU are eligible to receive
PELL and FSEOG. A student must (1) Qualify as an eligible student under 34 CFR Part 668,
Subpart C, (2) Is enrolled in an eligible undergraduate program and (3) Has financial need.
Condition: During our testing of 40 students, we noted the following:
• One student was awarded and disbursed more PELL funding than what a student with
their parental contribution should have been.
• Eight students did not have adequate supporting documentation to support the students
were eligible for PELL and/or FSEOG.
Questioned Costs: None.
Context: Nine out of forty students selected for eligibility testing during fiscal year 2023.
Cause and Effect: Internal controls were not implemented to ensure PELL funding provided to
students was accurate and documentation was available to support student eligibility under the
Student Financial Aid Cluster. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
PELL awards to students are accurately calculated and documentation is maintained to support
student eligibility determinations made by NTU for financial assistance.
Management’s Response: NTU will improve processes to ensure proper maintenance of source
documentation supporting student eligibility determinations. Additionally, staff will receive
comprehensive training sessions on eligibility determination and documentation requirements.
Responsible Party: Gary Segaye, Financial Aid Director and Dr. Delores Becenti, Director of
Enrollment
Anticipated Completion: July 2024
2023-008 – Special Tests and Provisions (Return of Title IV Funds)
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063
Award Period: June 1, 2022 – May 31, 2023
Criteria: When a recipient of Title IV grant or loan assistance withdraws from an institution
during a payment period or period of enrollment in which the recipient began attendance, the
institution must determine the amount of Title IV aid earned by the student as of the withdrawal
date. If the total amount of Title IV assistance earned by the student is less than the amount that
was disbursed to the student or on his or her behalf as of the date of the institution’s
determination that the student withdrew, the difference must be returned to the Title IV programs
no later than 45 days after the date of determination of a student’s withdrawal.
Condition: During our evaluation of Return of Title IV funds, we noted the following:
• NTU did not return funds to Title IV programs within the required 45-day timeframe. In
April 2024, $27,108 was remitted back to the U.S. Department of Education related to
Title IV programs for fiscal year 2023, which was well beyond the 45-day timeframe.
• Ten students tested did not have documentation to support that an R2T4 calculation was
performed.
Questioned Costs: None.
Context: Ten out of ten students tested that received Title IV student financial aid and did not
earn any credits in one of the semesters in fiscal year 2023.
Cause and Effect: NTU did not have effective internal controls to ensure return to Title IV funds
were performed timely and in accordance with federal requirements. Additionally, source
documentation was not maintained to support R2T4 calculations performed.
Auditor’s Recommendation: Establish formal procedures to ensure compliance with federal
student aid requirements. These policies and procedures should address students that withdrawal
from classes without notifying NTU. Consider performing student file audits to ensure Return of
Title IV calculations are performed. Lastly, consider increasing coordination efforts between the
finance department and the student financial aid department to ensure amounts due back to Title
IV programs are determined and remitted timely.
Management’s Response: NTU will establish formal policies and procedures for the Return of
Title IV Funds, ensuring alignment with U.S. Department of Education requirements. These
procedures will cover student withdrawals and the necessary data entry and monitoring within
the student information system. The Accounting Manager in the Student Accounts section of
NTU’s Business Office will review all student enrollment transactions to ensure compliance with
Return to Title IV requirements.
Responsible Party: Gary Segaye, Financial Aid Director, Delores Becenti, Enrollment Director,
and Geraldine Gamble, Accounting Manager
Anticipated Completion: July 2024
2023-009 – Special Tests and Provisions (Enrollment Reporting)
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063
Award Period: June 1, 2022 – May 31, 2023
Criteria: Institutions are required to report enrollment information under the Pell grant via the
National Student Loan Data System (NSLDS). Institutions must review, update, and verify
student enrollment statuses, program information, and effective dates that appear on the
Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS
Professional Access (NSLDSFAP) website.
Condition: During our evaluation of NSLDS enrollment reporting, we noted the following:
• Ten students did not have adequate supporting documentation to support their records
were updated in the NSLDS database.
Questioned Costs: None.
Context: Ten out of ten students that had an enrollment status change in fiscal year 2023.
Cause and Effect: Internal controls have not been designed and implemented to ensure
compliance with enrollment reporting requirements of the Student Financial Aid Cluster. 34 CFR
690.83(c) states, “In accordance with 34 CFR 668.84, the Secretary may impose a fine on the
institution if the institution fails to comply with the (reporting) requirements specified”. There is
a risk that NTU could face a potential fine if the required information is not being reported.
Auditors’ Recommendation: Develop and implement internal controls to ensure the enrollment
reporting requirements of the Student Financial Aid Cluster are met.
Management’s Response: NTU will develop formal policies and procedures regarding
enrollment reporting. This will include identifying the necessary enrollment data to update the
National Student Loan Database System (NSLDS) on a timely basis in accordance with the
Student Financial Aid Cluster requirements. NTU will be hiring an additional Financial Aid
Technician and a Financial Aid Counselor to assist in addressing this finding.
Responsible Party: Delores Becenti, Enrollment Director
Anticipated Completion: July 2024
2023-010 – Special Tests and Provisions (Gramm-Leach-Bliley Act – Student Information Security)
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Student Financial Aid Cluster
Assistance Listing Number: 84.007, 84.033, 84.063
Award Period: June 1, 2022 – May 31, 2023
Criteria: Title IV-eligible institutions are subject to the Gramm-Leach-Bliley Act (the “Act”). The Act
requires institutions to perform the following:
• Develop, implement, and maintain a written information security program.
• Designate the employee(s) responsible for coordinating the information security program.
• Identify and assess risks to customer information.
• Design and implement an information safeguards program
Condition: We found that NTU has developed an information security plan, however this plan has not been
formally adopted and implemented by NTU.
Questioned Costs: None.
Context: Evaluation of NTU’s information security protocols as it relates to the Gramm-Leach-Bliley Act
requirements of the Student Financial Aid Cluster.
Cause and Effect: NTU has not formally adopted and implemented an information security plan that
addresses the requirements of the Gramm-Leach-Bliley Act. NTU did not comply with OMB Uniform
Guidance related to special tests and provisions for the Student Financial Aid Cluster.
Auditor’s Recommendation: Formally adopt and implement an information security plan that adequately
address the requirements of the Student Financial Assistance Cluster.
Management’s Response: NTU has developed an information security plan, the plan will be presented to
NTU Board of Regents for ratification and adoption
Responsible Party: Jared Ribble, Information Technology Director
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-011 – Activities Allowed/Unallowed and Allowable Costs/Cost Principles
Federal Program Information:
Funding Agency: National Aeronautics and Space Administration, U.S.
Department of Education, and U.S. Department of Interior
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions, Indian
Post Secondary Schools
Assistance Listing Number: 43.008, 84.245, 15.058
Award Period: June 1, 2022 – May 31, 2023
Criteria: To be allowable under Federal awards, costs must be necessary and reasonable for the
performance and administration of the federal award. Costs must meet the following criteria: 1)
necessary and reasonable; 2) consistent with policies and procedures; 3) accorded consistent
treatment; and 4) are adequately documented.
Condition: We found the following in our review of federal expenditures:
Research and Development Cluster –
• One payroll transaction totaling $1,875 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Two transactions totaling $3,475 did not have accurate source documentation to support
the group insurance expenditures charged to the program.
• Two payroll transactions totaling $8,957 did not have accurate source documentation to
support the allocation of salaries and wages expenditures charged to the program.
Indian Post Secondary Schools
• One transaction totaling $212 did not have accurate source documentation to support the
travel expenditures charged to the program.
Questioned Costs: None exceeding $25,000.
Context: One of twenty-five payroll transactions tested for the Research and Development
Cluster. Four of fifty payroll and non-payroll transactions tested for the Tribally Controlled
Postsecondary Career and Technical Institutions program. One of twenty-five non-payroll
transactions tested for the Indian Post Secondary Schools.
Cause and Effect: NTU did not have effective internal controls to ensure federal expenditures are
accurately charged in accordance with federal activities allowed/unallowed and allowable
costs/cost principles requirements. As a result, NTU was not in compliance with these federal
requirements for the Research and Development Cluster, Tribally Controlled Post Secondary
Career and Technical Institutions and Indian Post Secondary programs.
Auditor’s Recommendation: Improve internal controls to ensure expenditures are allowable
under federal program requirements. This includes maintaining source documentation to support
the allocation of payroll costs.
Management’s Response: NTU will implement a monthly review process for all grant
expenditures to ensure that amounts charged to federal awards are accurately posted and
reflected in the accounting system. The Accounting Manager and Senior Accountant will review
all journal entries for accuracy. Payroll allocations provided by the Human Resources office will
also be included in the monthly review to verify the accuracy of payroll expenditures.
Additionally, Principal Investigators and program managers will be given read-only access to the
accounting system to review expenditure postings for accuracy.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-012 – Cash Management
Federal Program Information:
Funding Agency: National Science Foundation, National Aeronautics and
Space Administration, U.S. Department of Energy, and
U.S. Department of Education
Title: Research and Development Cluster, Tribally Controlled
Postsecondary Career and Technical Institutions
Assistance Listing Number: 43.008, 47.049, 47.067, 47.076, 81.123, 84.245
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place demonstrate that the time between the transfer of
funds from the federal entity to the non-federal entity and disbursement by the non-federal entity
has been adequately minimized. This includes ensuring reimbursement and drawdown requests
are adequately supported by underlying source documentation.
Condition: We found the following during our evaluation of cash drawdowns:
Research and Development Cluster –
• Eight drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Tribally Controlled Postsecondary Career and Technical Institutions –
• Nine drawdowns did not have adequate source documentation to support the amount of
funds drawn down.
Questioned Costs: None.
Context: Eight of ten drawdowns tested for the Research and Development and nine out of nine
drawdowns tested for the Tribally Controlled Postsecondary Career and Technical Institutions
program.
Cause and Effect: Internal controls were not designed and implemented to ensure appropriate
cash management requirements are met. NTU did not comply with the cash management
requirements of the Research and Development Cluster and Tribally Controlled Postsecondary
Career and Technical Institutions program.
Auditor’s Recommendation: Established policies and procedures should be enforced to ensure
compliance with federal cash management requirements and NTU’s policies and procedures.
Management’s Response: NTU will enforce policies and procedures for cash drawdowns to
ensure all drawdowns are properly supported. Additionally, an electronic filing system will be
developed to maintain all drawdowns and the related backup documentation, enhancing the
processing and record-keeping of drawdown documents.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-013 – Reporting
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Tribally Controlled Postsecondary Career and Technical
Institutions, Higher Education Emergency Relief Fund
(HEERF), Indian Post Secondary Schools
Assistance Listing Number: 84.245 and 84.425
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place to ensure performance and financial reporting
requirements for federal award programs are met
Condition: During our assessment of reporting requirements, we found the following:
Tribally Controlled Postsecondary Career and Technical Institutions –
• The annual performance report for the Tribally Controlled Postsecondary Career and
Technical Institutions was not available for review at the time of fieldwork.
Higher Education Emergency Relief Fund (HERF) –
• The annual performance for HEERF was not available for review at the time of
fieldwork.
Indian Post Secondary Schools –
• Two of two quarterly SF-425 were not available for our review at the time of fieldwork.
Questioned Costs: None
Context: One of one annual performance report required for the Tribally Controlled
Postsecondary Career and Technical Institutions, one of one annual performance reports required
by the HEERF program, two of four quarterly SF-425 reports required by the Indian Post
Secondary Schools.
Cause and Effect: Internal controls were not designed and implemented to ensure reporting
requirements were met. NTU did not comply with OMB Uniform Guidance related to reporting
for these programs.
Auditors’ Recommendation: Establish formal reporting procedures to ensure compliance with
federal reporting requirements.
Management’s Response: Formal policies and procedures for grants reporting will be developed
by NTU. NTU is developing a master file that will have a detailed schedules by funding source
which will identify the reporting requirements and deadlines for submission. Communication of
reporting due dates to appropriate NTU financial and programmatic personnel will be improved.
This will help ensure all financial and administrative reports are submitted in a timely manner.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-013 – Reporting
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Tribally Controlled Postsecondary Career and Technical
Institutions, Higher Education Emergency Relief Fund
(HEERF), Indian Post Secondary Schools
Assistance Listing Number: 84.245 and 84.425
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place to ensure performance and financial reporting
requirements for federal award programs are met
Condition: During our assessment of reporting requirements, we found the following:
Tribally Controlled Postsecondary Career and Technical Institutions –
• The annual performance report for the Tribally Controlled Postsecondary Career and
Technical Institutions was not available for review at the time of fieldwork.
Higher Education Emergency Relief Fund (HERF) –
• The annual performance for HEERF was not available for review at the time of
fieldwork.
Indian Post Secondary Schools –
• Two of two quarterly SF-425 were not available for our review at the time of fieldwork.
Questioned Costs: None
Context: One of one annual performance report required for the Tribally Controlled
Postsecondary Career and Technical Institutions, one of one annual performance reports required
by the HEERF program, two of four quarterly SF-425 reports required by the Indian Post
Secondary Schools.
Cause and Effect: Internal controls were not designed and implemented to ensure reporting
requirements were met. NTU did not comply with OMB Uniform Guidance related to reporting
for these programs.
Auditors’ Recommendation: Establish formal reporting procedures to ensure compliance with
federal reporting requirements.
Management’s Response: Formal policies and procedures for grants reporting will be developed
by NTU. NTU is developing a master file that will have a detailed schedules by funding source
which will identify the reporting requirements and deadlines for submission. Communication of
reporting due dates to appropriate NTU financial and programmatic personnel will be improved.
This will help ensure all financial and administrative reports are submitted in a timely manner.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-006 – Cash Management
Federal Program Information:
Funding Agency: All Major Programs
Title: All Major Programs
Assistance Listing Number: All Major Programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: Advanced grant/contract funds may not be transferred to other NTU accounts, lent to
such NTU accounts, or expended for programs not authorized. There should be sufficient
unrestricted cash and investment balances on hand to cover all unearned grant revenue associated
with federal and nonfederal programs.
Condition: NTU did not maintain cash and cash equivalents at least equal to the amount of
unspent grant funds advanced from federal and nonfederal agencies at year-end. At May 31,
2023, NTU’s unrestricted cash and cash equivalents and investments and unearned grant revenue
totaled $33,024,886 and $39,121,460, respectively. As a result, unspent grant funds held by NTU
exceeded the amount of available cash and cash equivalents and investments by $6,096,574.
Questioned Costs: None.
Context: Federal programs that have provided advanced funds to NTU.
Cause and Effect: NTU did not have effective internal controls to ensure sufficient cash and cash
equivalents are on hand to cover all unearned grant revenue associated with federal and
nonfederal programs. NTU is not in compliance with federal requirements.
Auditor’s Recommendation: Thoroughly analyze the financial position of NTU and ensure
adequate cash and cash equivalents are maintained in an amount at least equal to unearned grant
revenues from federal and nonfederal sources. NTU may need to liquidate unrestricted
investments and convert them into cash and cash equivalents or reallocate investments into
securities backed by the full faith and credit of the United States government to accomplish this.
Management’s Response: NTU has established a monthly cash management schedule to track
and identify all grant funds, detailing the total cash received in advance from grantors and
amounts due to NTU. To increase cash balances, NTU will focus on the timely collection of
outstanding grants receivable. Additionally, NTU will analyze cash requirements and may
liquidate investments held in the Capital Reserve fund to ensure adequate cash is available for
grants received in advance.
Responsible Party: Beverly Miller, Accounting Manager
Anticipated Completion: July 2024
2023-013 – Reporting
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Tribally Controlled Postsecondary Career and Technical
Institutions, Higher Education Emergency Relief Fund
(HEERF), Indian Post Secondary Schools
Assistance Listing Number: 84.245 and 84.425
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place to ensure performance and financial reporting
requirements for federal award programs are met
Condition: During our assessment of reporting requirements, we found the following:
Tribally Controlled Postsecondary Career and Technical Institutions –
• The annual performance report for the Tribally Controlled Postsecondary Career and
Technical Institutions was not available for review at the time of fieldwork.
Higher Education Emergency Relief Fund (HERF) –
• The annual performance for HEERF was not available for review at the time of
fieldwork.
Indian Post Secondary Schools –
• Two of two quarterly SF-425 were not available for our review at the time of fieldwork.
Questioned Costs: None
Context: One of one annual performance report required for the Tribally Controlled
Postsecondary Career and Technical Institutions, one of one annual performance reports required
by the HEERF program, two of four quarterly SF-425 reports required by the Indian Post
Secondary Schools.
Cause and Effect: Internal controls were not designed and implemented to ensure reporting
requirements were met. NTU did not comply with OMB Uniform Guidance related to reporting
for these programs.
Auditors’ Recommendation: Establish formal reporting procedures to ensure compliance with
federal reporting requirements.
Management’s Response: Formal policies and procedures for grants reporting will be developed
by NTU. NTU is developing a master file that will have a detailed schedules by funding source
which will identify the reporting requirements and deadlines for submission. Communication of
reporting due dates to appropriate NTU financial and programmatic personnel will be improved.
This will help ensure all financial and administrative reports are submitted in a timely manner.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-014 – Late Submission of Annual Federal Reporting Package
Federal Program Information:
Funding Agency: All major programs
Title: All major programs
Assistance Listing Number: All major programs
Award Period: June 1, 2022 – May 31, 2023
Criteria: 2 CFR 200.512 requires that the annual federal reporting package including the data
collection form be submitted within nine months after the end of the audit period.
Condition: NTU did not submit the annual federal reporting package within nine months after
May 31, 2023.
Questioned Costs: None
Context: The annual federal reporting package for the year ended May 31, 2023.
Cause and Effect: Internal controls were not designed and implemented to the annual federal
reporting package was submitted within the timeframe required by OMB Uniform Guidance.
Auditors’ Recommendation: NTU should improve internal controls to help ensure that general
ledger balances are accurately reconciled and closed out shortly after year-end to help ensure the
timely preparation and submission of the annual federal reporting package.
Management’s Response: NTU experienced key personal turnover during which affected the
start and completion of the audit. NTU has developed a comprehensive year-end financial close
and annual federal reporting plan as part of this plan, NTU will ensure that financial accounting
books and records are reconciled and closed in a timely manner prior to providing the final trial
balance to the auditor.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024
2023-013 – Reporting
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Tribally Controlled Postsecondary Career and Technical
Institutions, Higher Education Emergency Relief Fund
(HEERF), Indian Post Secondary Schools
Assistance Listing Number: 84.245 and 84.425
Award Period: June 1, 2022 – May 31, 2023
Criteria: Internal controls must be in place to ensure performance and financial reporting
requirements for federal award programs are met
Condition: During our assessment of reporting requirements, we found the following:
Tribally Controlled Postsecondary Career and Technical Institutions –
• The annual performance report for the Tribally Controlled Postsecondary Career and
Technical Institutions was not available for review at the time of fieldwork.
Higher Education Emergency Relief Fund (HERF) –
• The annual performance for HEERF was not available for review at the time of
fieldwork.
Indian Post Secondary Schools –
• Two of two quarterly SF-425 were not available for our review at the time of fieldwork.
Questioned Costs: None
Context: One of one annual performance report required for the Tribally Controlled
Postsecondary Career and Technical Institutions, one of one annual performance reports required
by the HEERF program, two of four quarterly SF-425 reports required by the Indian Post
Secondary Schools.
Cause and Effect: Internal controls were not designed and implemented to ensure reporting
requirements were met. NTU did not comply with OMB Uniform Guidance related to reporting
for these programs.
Auditors’ Recommendation: Establish formal reporting procedures to ensure compliance with
federal reporting requirements.
Management’s Response: Formal policies and procedures for grants reporting will be developed
by NTU. NTU is developing a master file that will have a detailed schedules by funding source
which will identify the reporting requirements and deadlines for submission. Communication of
reporting due dates to appropriate NTU financial and programmatic personnel will be improved.
This will help ensure all financial and administrative reports are submitted in a timely manner.
Responsible Party: Beverly Miller, Accounting Manager and Harshwal & Company, LLC
Anticipated Completion: July 2024