Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 43.008 and 93.433
Federal Award Identification Number: NNX15AP43A-2023, 90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement
method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar
days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably
believes the request to be improper. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: During our testing of 28 subrecipient payments, from a statistically valid sample, we identified 2
payments were not submitted within 30 days after receiving invoice from the subrecipients. One payment
was 39 days beyond the required 30 days and the second payment was 565 days beyond the required 30
days.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient payments were paid
timely.
Effect: The University was not in compliance with the regulation to make payments to subrecipients within
the required timeframe.
Repeat finding: No
Recommendation: We recommend that the University review and update current procedures to ensure
subrecipient payments are paid timely.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 43.008 and 93.433
Federal Award Identification Number: NNX15AP43A-2023, 90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement
method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar
days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably
believes the request to be improper. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: During our testing of 28 subrecipient payments, from a statistically valid sample, we identified 2
payments were not submitted within 30 days after receiving invoice from the subrecipients. One payment
was 39 days beyond the required 30 days and the second payment was 565 days beyond the required 30
days.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient payments were paid
timely.
Effect: The University was not in compliance with the regulation to make payments to subrecipients within
the required timeframe.
Repeat finding: No
Recommendation: We recommend that the University review and update current procedures to ensure
subrecipient payments are paid timely.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 43.008 and 93.433
Federal Award Identification Number: NNX15AP43A-2023, 90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement
method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar
days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably
believes the request to be improper. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: During our testing of 28 subrecipient payments, from a statistically valid sample, we identified 2
payments were not submitted within 30 days after receiving invoice from the subrecipients. One payment
was 39 days beyond the required 30 days and the second payment was 565 days beyond the required 30
days.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient payments were paid
timely.
Effect: The University was not in compliance with the regulation to make payments to subrecipients within
the required timeframe.
Repeat finding: No
Recommendation: We recommend that the University review and update current procedures to ensure
subrecipient payments are paid timely.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 43.008 and 93.433
Federal Award Identification Number: NNX15AP43A-2023, 90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement
method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar
days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably
believes the request to be improper. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: During our testing of 28 subrecipient payments, from a statistically valid sample, we identified 2
payments were not submitted within 30 days after receiving invoice from the subrecipients. One payment
was 39 days beyond the required 30 days and the second payment was 565 days beyond the required 30
days.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient payments were paid
timely.
Effect: The University was not in compliance with the regulation to make payments to subrecipients within
the required timeframe.
Repeat finding: No
Recommendation: We recommend that the University review and update current procedures to ensure
subrecipient payments are paid timely.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 43.008 and 93.433
Federal Award Identification Number: NNX15AP43A-2023, 90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement
method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar
days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably
believes the request to be improper. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: During our testing of 28 subrecipient payments, from a statistically valid sample, we identified 2
payments were not submitted within 30 days after receiving invoice from the subrecipients. One payment
was 39 days beyond the required 30 days and the second payment was 565 days beyond the required 30
days.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient payments were paid
timely.
Effect: The University was not in compliance with the regulation to make payments to subrecipients within
the required timeframe.
Repeat finding: No
Recommendation: We recommend that the University review and update current procedures to ensure
subrecipient payments are paid timely.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 43.008 and 93.433
Federal Award Identification Number: NNX15AP43A-2023, 90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement
method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar
days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably
believes the request to be improper. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: During our testing of 28 subrecipient payments, from a statistically valid sample, we identified 2
payments were not submitted within 30 days after receiving invoice from the subrecipients. One payment
was 39 days beyond the required 30 days and the second payment was 565 days beyond the required 30
days.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient payments were paid
timely.
Effect: The University was not in compliance with the regulation to make payments to subrecipients within
the required timeframe.
Repeat finding: No
Recommendation: We recommend that the University review and update current procedures to ensure
subrecipient payments are paid timely.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs eligibility verification procedures.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: The University uses a third party to perform their verification procedures to assess Title IV student
eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other
documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-018
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs eligibility verification procedures.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: The University uses a third party to perform their verification procedures to assess Title IV student
eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other
documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-018
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs eligibility verification procedures.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: The University uses a third party to perform their verification procedures to assess Title IV student
eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other
documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-018
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs eligibility verification procedures.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: The University uses a third party to perform their verification procedures to assess Title IV student
eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other
documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-018
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs eligibility verification procedures.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: The University uses a third party to perform their verification procedures to assess Title IV student
eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other
documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-018
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs eligibility verification procedures.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: The University uses a third party to perform their verification procedures to assess Title IV student
eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other
documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-018
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs eligibility verification procedures.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: The University uses a third party to perform their verification procedures to assess Title IV student
eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other
documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-018
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs eligibility verification procedures.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: The University uses a third party to perform their verification procedures to assess Title IV student
eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other
documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-018
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly notify students when loans were credited to the student's ledger
account.
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or
parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to
cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder
of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the
student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or
TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are
disbursed by EFT payment or master check. Additionally per 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: During our Eligibility testing of 60 students, we noted that there were 43 students that received
loan disbursements however, all 43 students did not receive the required notification for each loan
disbursement.
Questioned costs: N/A
Cause: The University did not send loan disbursement notifications.
Effect: Students were not made aware of the anticipated date and amount of loan disbursement for the right
to cancel all or a portion of the loan in the required amount of time.
Repeat finding: Yes, 2022-013
Recommendation: We recommend the University evaluate its procedures around disbursements of loans
and ensure that notifications of disbursements are sent and contain all the required elements outlined in the
FSA handbook.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly notify students when loans were credited to the student's ledger
account.
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or
parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to
cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder
of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the
student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or
TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are
disbursed by EFT payment or master check. Additionally per 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: During our Eligibility testing of 60 students, we noted that there were 43 students that received
loan disbursements however, all 43 students did not receive the required notification for each loan
disbursement.
Questioned costs: N/A
Cause: The University did not send loan disbursement notifications.
Effect: Students were not made aware of the anticipated date and amount of loan disbursement for the right
to cancel all or a portion of the loan in the required amount of time.
Repeat finding: Yes, 2022-013
Recommendation: We recommend the University evaluate its procedures around disbursements of loans
and ensure that notifications of disbursements are sent and contain all the required elements outlined in the
FSA handbook.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly notify students when loans were credited to the student's ledger
account.
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or
parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to
cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder
of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the
student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or
TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are
disbursed by EFT payment or master check. Additionally per 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: During our Eligibility testing of 60 students, we noted that there were 43 students that received
loan disbursements however, all 43 students did not receive the required notification for each loan
disbursement.
Questioned costs: N/A
Cause: The University did not send loan disbursement notifications.
Effect: Students were not made aware of the anticipated date and amount of loan disbursement for the right
to cancel all or a portion of the loan in the required amount of time.
Repeat finding: Yes, 2022-013
Recommendation: We recommend the University evaluate its procedures around disbursements of loans
and ensure that notifications of disbursements are sent and contain all the required elements outlined in the
FSA handbook.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly notify students when loans were credited to the student's ledger
account.
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or
parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to
cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder
of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the
student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or
TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are
disbursed by EFT payment or master check. Additionally per 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: During our Eligibility testing of 60 students, we noted that there were 43 students that received
loan disbursements however, all 43 students did not receive the required notification for each loan
disbursement.
Questioned costs: N/A
Cause: The University did not send loan disbursement notifications.
Effect: Students were not made aware of the anticipated date and amount of loan disbursement for the right
to cancel all or a portion of the loan in the required amount of time.
Repeat finding: Yes, 2022-013
Recommendation: We recommend the University evaluate its procedures around disbursements of loans
and ensure that notifications of disbursements are sent and contain all the required elements outlined in the
FSA handbook.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly notify students when loans were credited to the student's ledger
account.
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or
parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to
cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder
of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the
student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or
TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are
disbursed by EFT payment or master check. Additionally per 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: During our Eligibility testing of 60 students, we noted that there were 43 students that received
loan disbursements however, all 43 students did not receive the required notification for each loan
disbursement.
Questioned costs: N/A
Cause: The University did not send loan disbursement notifications.
Effect: Students were not made aware of the anticipated date and amount of loan disbursement for the right
to cancel all or a portion of the loan in the required amount of time.
Repeat finding: Yes, 2022-013
Recommendation: We recommend the University evaluate its procedures around disbursements of loans
and ensure that notifications of disbursements are sent and contain all the required elements outlined in the
FSA handbook.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly notify students when loans were credited to the student's ledger
account.
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or
parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to
cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder
of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the
student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or
TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are
disbursed by EFT payment or master check. Additionally per 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: During our Eligibility testing of 60 students, we noted that there were 43 students that received
loan disbursements however, all 43 students did not receive the required notification for each loan
disbursement.
Questioned costs: N/A
Cause: The University did not send loan disbursement notifications.
Effect: Students were not made aware of the anticipated date and amount of loan disbursement for the right
to cancel all or a portion of the loan in the required amount of time.
Repeat finding: Yes, 2022-013
Recommendation: We recommend the University evaluate its procedures around disbursements of loans
and ensure that notifications of disbursements are sent and contain all the required elements outlined in the
FSA handbook.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly notify students when loans were credited to the student's ledger
account.
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or
parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to
cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder
of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the
student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or
TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are
disbursed by EFT payment or master check. Additionally per 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: During our Eligibility testing of 60 students, we noted that there were 43 students that received
loan disbursements however, all 43 students did not receive the required notification for each loan
disbursement.
Questioned costs: N/A
Cause: The University did not send loan disbursement notifications.
Effect: Students were not made aware of the anticipated date and amount of loan disbursement for the right
to cancel all or a portion of the loan in the required amount of time.
Repeat finding: Yes, 2022-013
Recommendation: We recommend the University evaluate its procedures around disbursements of loans
and ensure that notifications of disbursements are sent and contain all the required elements outlined in the
FSA handbook.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly notify students when loans were credited to the student's ledger
account.
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or
parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to
cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder
of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the
student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or
TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are
disbursed by EFT payment or master check. Additionally per 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: During our Eligibility testing of 60 students, we noted that there were 43 students that received
loan disbursements however, all 43 students did not receive the required notification for each loan
disbursement.
Questioned costs: N/A
Cause: The University did not send loan disbursement notifications.
Effect: Students were not made aware of the anticipated date and amount of loan disbursement for the right
to cancel all or a portion of the loan in the required amount of time.
Repeat finding: Yes, 2022-013
Recommendation: We recommend the University evaluate its procedures around disbursements of loans
and ensure that notifications of disbursements are sent and contain all the required elements outlined in the
FSA handbook.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University has a Written information Security Program; however, the University did not meet
the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not
designate a qualified individual responsible for overseeing and implementing the information and security
program.
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to
explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314).
The regulation states that the college must designate a qualified individual responsible for overseeing and
implementing your information security program and enforcing your information security program. (16 CFR
314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and
implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s
written information security program must address the implementation of the minimum safeguards identified
in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written
security program provides for the institution to regularly test or otherwise monitor the effectiveness of the
safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal
awards are required to establish and maintain internal controls designed to reasonably ensure compliance
with federal laws, regulations, and program compliance requirements.
Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were seven
elements missing from their Written Information Security Program.
Questioned costs: N/A
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure
compliance.
Effect: The University was not in compliance with Gramm-Leach-Bliley compliance standards.
Repeat finding: Yes, 2022-017
Recommendation: We recommend that the University review the updated GLBA requirements and ensure
their WISP includes all required elements.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University has a Written information Security Program; however, the University did not meet
the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not
designate a qualified individual responsible for overseeing and implementing the information and security
program.
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to
explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314).
The regulation states that the college must designate a qualified individual responsible for overseeing and
implementing your information security program and enforcing your information security program. (16 CFR
314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and
implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s
written information security program must address the implementation of the minimum safeguards identified
in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written
security program provides for the institution to regularly test or otherwise monitor the effectiveness of the
safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal
awards are required to establish and maintain internal controls designed to reasonably ensure compliance
with federal laws, regulations, and program compliance requirements.
Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were seven
elements missing from their Written Information Security Program.
Questioned costs: N/A
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure
compliance.
Effect: The University was not in compliance with Gramm-Leach-Bliley compliance standards.
Repeat finding: Yes, 2022-017
Recommendation: We recommend that the University review the updated GLBA requirements and ensure
their WISP includes all required elements.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University has a Written information Security Program; however, the University did not meet
the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not
designate a qualified individual responsible for overseeing and implementing the information and security
program.
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to
explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314).
The regulation states that the college must designate a qualified individual responsible for overseeing and
implementing your information security program and enforcing your information security program. (16 CFR
314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and
implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s
written information security program must address the implementation of the minimum safeguards identified
in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written
security program provides for the institution to regularly test or otherwise monitor the effectiveness of the
safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal
awards are required to establish and maintain internal controls designed to reasonably ensure compliance
with federal laws, regulations, and program compliance requirements.
Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were seven
elements missing from their Written Information Security Program.
Questioned costs: N/A
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure
compliance.
Effect: The University was not in compliance with Gramm-Leach-Bliley compliance standards.
Repeat finding: Yes, 2022-017
Recommendation: We recommend that the University review the updated GLBA requirements and ensure
their WISP includes all required elements.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University has a Written information Security Program; however, the University did not meet
the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not
designate a qualified individual responsible for overseeing and implementing the information and security
program.
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to
explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314).
The regulation states that the college must designate a qualified individual responsible for overseeing and
implementing your information security program and enforcing your information security program. (16 CFR
314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and
implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s
written information security program must address the implementation of the minimum safeguards identified
in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written
security program provides for the institution to regularly test or otherwise monitor the effectiveness of the
safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal
awards are required to establish and maintain internal controls designed to reasonably ensure compliance
with federal laws, regulations, and program compliance requirements.
Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were seven
elements missing from their Written Information Security Program.
Questioned costs: N/A
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure
compliance.
Effect: The University was not in compliance with Gramm-Leach-Bliley compliance standards.
Repeat finding: Yes, 2022-017
Recommendation: We recommend that the University review the updated GLBA requirements and ensure
their WISP includes all required elements.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University has a Written information Security Program; however, the University did not meet
the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not
designate a qualified individual responsible for overseeing and implementing the information and security
program.
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to
explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314).
The regulation states that the college must designate a qualified individual responsible for overseeing and
implementing your information security program and enforcing your information security program. (16 CFR
314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and
implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s
written information security program must address the implementation of the minimum safeguards identified
in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written
security program provides for the institution to regularly test or otherwise monitor the effectiveness of the
safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal
awards are required to establish and maintain internal controls designed to reasonably ensure compliance
with federal laws, regulations, and program compliance requirements.
Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were seven
elements missing from their Written Information Security Program.
Questioned costs: N/A
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure
compliance.
Effect: The University was not in compliance with Gramm-Leach-Bliley compliance standards.
Repeat finding: Yes, 2022-017
Recommendation: We recommend that the University review the updated GLBA requirements and ensure
their WISP includes all required elements.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University has a Written information Security Program; however, the University did not meet
the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not
designate a qualified individual responsible for overseeing and implementing the information and security
program.
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to
explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314).
The regulation states that the college must designate a qualified individual responsible for overseeing and
implementing your information security program and enforcing your information security program. (16 CFR
314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and
implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s
written information security program must address the implementation of the minimum safeguards identified
in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written
security program provides for the institution to regularly test or otherwise monitor the effectiveness of the
safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal
awards are required to establish and maintain internal controls designed to reasonably ensure compliance
with federal laws, regulations, and program compliance requirements.
Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were seven
elements missing from their Written Information Security Program.
Questioned costs: N/A
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure
compliance.
Effect: The University was not in compliance with Gramm-Leach-Bliley compliance standards.
Repeat finding: Yes, 2022-017
Recommendation: We recommend that the University review the updated GLBA requirements and ensure
their WISP includes all required elements.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University has a Written information Security Program; however, the University did not meet
the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not
designate a qualified individual responsible for overseeing and implementing the information and security
program.
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to
explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314).
The regulation states that the college must designate a qualified individual responsible for overseeing and
implementing your information security program and enforcing your information security program. (16 CFR
314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and
implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s
written information security program must address the implementation of the minimum safeguards identified
in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written
security program provides for the institution to regularly test or otherwise monitor the effectiveness of the
safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal
awards are required to establish and maintain internal controls designed to reasonably ensure compliance
with federal laws, regulations, and program compliance requirements.
Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were seven
elements missing from their Written Information Security Program.
Questioned costs: N/A
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure
compliance.
Effect: The University was not in compliance with Gramm-Leach-Bliley compliance standards.
Repeat finding: Yes, 2022-017
Recommendation: We recommend that the University review the updated GLBA requirements and ensure
their WISP includes all required elements.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University has a Written information Security Program; however, the University did not meet
the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not
designate a qualified individual responsible for overseeing and implementing the information and security
program.
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to
explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314).
The regulation states that the college must designate a qualified individual responsible for overseeing and
implementing your information security program and enforcing your information security program. (16 CFR
314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and
implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s
written information security program must address the implementation of the minimum safeguards identified
in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written
security program provides for the institution to regularly test or otherwise monitor the effectiveness of the
safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal
awards are required to establish and maintain internal controls designed to reasonably ensure compliance
with federal laws, regulations, and program compliance requirements.
Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were seven
elements missing from their Written Information Security Program.
Questioned costs: N/A
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure
compliance.
Effect: The University was not in compliance with Gramm-Leach-Bliley compliance standards.
Repeat finding: Yes, 2022-017
Recommendation: We recommend that the University review the updated GLBA requirements and ensure
their WISP includes all required elements.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: Langston University had 2 instance of Title IV refund checks to students that were outstanding
longer than 240 days as of June 30, 2023.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an
institution that attempts to disburse funds by check and the check is not cashed, the institution must return
the funds to the Secretary no later than 240 days after the date it issued that check. The Code of Federal
Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award.
Context: During the testing of the outstanding Title IV student check listing CLA observed two instances of
stale checks at Langston that were aged greater than 240 days.
Questioned costs: N/A
Cause: The University did not return checks that were not cashed within 240 days.
Effect: Funds are not returned to the Department of Education in a timely manner.
Repeat finding: No
Recommendation: We recommend that the University establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award and that stale federal aid checks are returned
to the Department of Education with 240 days after the date of issuance if not cashed.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: Langston University had 2 instance of Title IV refund checks to students that were outstanding
longer than 240 days as of June 30, 2023.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an
institution that attempts to disburse funds by check and the check is not cashed, the institution must return
the funds to the Secretary no later than 240 days after the date it issued that check. The Code of Federal
Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award.
Context: During the testing of the outstanding Title IV student check listing CLA observed two instances of
stale checks at Langston that were aged greater than 240 days.
Questioned costs: N/A
Cause: The University did not return checks that were not cashed within 240 days.
Effect: Funds are not returned to the Department of Education in a timely manner.
Repeat finding: No
Recommendation: We recommend that the University establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award and that stale federal aid checks are returned
to the Department of Education with 240 days after the date of issuance if not cashed.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: Langston University had 2 instance of Title IV refund checks to students that were outstanding
longer than 240 days as of June 30, 2023.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an
institution that attempts to disburse funds by check and the check is not cashed, the institution must return
the funds to the Secretary no later than 240 days after the date it issued that check. The Code of Federal
Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award.
Context: During the testing of the outstanding Title IV student check listing CLA observed two instances of
stale checks at Langston that were aged greater than 240 days.
Questioned costs: N/A
Cause: The University did not return checks that were not cashed within 240 days.
Effect: Funds are not returned to the Department of Education in a timely manner.
Repeat finding: No
Recommendation: We recommend that the University establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award and that stale federal aid checks are returned
to the Department of Education with 240 days after the date of issuance if not cashed.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: Langston University had 2 instance of Title IV refund checks to students that were outstanding
longer than 240 days as of June 30, 2023.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an
institution that attempts to disburse funds by check and the check is not cashed, the institution must return
the funds to the Secretary no later than 240 days after the date it issued that check. The Code of Federal
Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award.
Context: During the testing of the outstanding Title IV student check listing CLA observed two instances of
stale checks at Langston that were aged greater than 240 days.
Questioned costs: N/A
Cause: The University did not return checks that were not cashed within 240 days.
Effect: Funds are not returned to the Department of Education in a timely manner.
Repeat finding: No
Recommendation: We recommend that the University establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award and that stale federal aid checks are returned
to the Department of Education with 240 days after the date of issuance if not cashed.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: Langston University had 2 instance of Title IV refund checks to students that were outstanding
longer than 240 days as of June 30, 2023.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an
institution that attempts to disburse funds by check and the check is not cashed, the institution must return
the funds to the Secretary no later than 240 days after the date it issued that check. The Code of Federal
Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award.
Context: During the testing of the outstanding Title IV student check listing CLA observed two instances of
stale checks at Langston that were aged greater than 240 days.
Questioned costs: N/A
Cause: The University did not return checks that were not cashed within 240 days.
Effect: Funds are not returned to the Department of Education in a timely manner.
Repeat finding: No
Recommendation: We recommend that the University establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award and that stale federal aid checks are returned
to the Department of Education with 240 days after the date of issuance if not cashed.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: Langston University had 2 instance of Title IV refund checks to students that were outstanding
longer than 240 days as of June 30, 2023.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an
institution that attempts to disburse funds by check and the check is not cashed, the institution must return
the funds to the Secretary no later than 240 days after the date it issued that check. The Code of Federal
Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award.
Context: During the testing of the outstanding Title IV student check listing CLA observed two instances of
stale checks at Langston that were aged greater than 240 days.
Questioned costs: N/A
Cause: The University did not return checks that were not cashed within 240 days.
Effect: Funds are not returned to the Department of Education in a timely manner.
Repeat finding: No
Recommendation: We recommend that the University establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award and that stale federal aid checks are returned
to the Department of Education with 240 days after the date of issuance if not cashed.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: Langston University had 2 instance of Title IV refund checks to students that were outstanding
longer than 240 days as of June 30, 2023.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an
institution that attempts to disburse funds by check and the check is not cashed, the institution must return
the funds to the Secretary no later than 240 days after the date it issued that check. The Code of Federal
Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award.
Context: During the testing of the outstanding Title IV student check listing CLA observed two instances of
stale checks at Langston that were aged greater than 240 days.
Questioned costs: N/A
Cause: The University did not return checks that were not cashed within 240 days.
Effect: Funds are not returned to the Department of Education in a timely manner.
Repeat finding: No
Recommendation: We recommend that the University establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award and that stale federal aid checks are returned
to the Department of Education with 240 days after the date of issuance if not cashed.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: Langston University had 2 instance of Title IV refund checks to students that were outstanding
longer than 240 days as of June 30, 2023.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an
institution that attempts to disburse funds by check and the check is not cashed, the institution must return
the funds to the Secretary no later than 240 days after the date it issued that check. The Code of Federal
Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award.
Context: During the testing of the outstanding Title IV student check listing CLA observed two instances of
stale checks at Langston that were aged greater than 240 days.
Questioned costs: N/A
Cause: The University did not return checks that were not cashed within 240 days.
Effect: Funds are not returned to the Department of Education in a timely manner.
Repeat finding: No
Recommendation: We recommend that the University establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award and that stale federal aid checks are returned
to the Department of Education with 240 days after the date of issuance if not cashed.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University incorrectly calculated Return to Title IV (R2T4) calculations, did not have
documentation of withdrawal and did not have formal procedures in place to review the R2T4 calculations.
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Per 34 CFR 668.22(f)(2)(i), the total number of
calendar days in a payment period or period of enrollment includes all days within the period that the student
was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded
from the total number of calendar days in a payment period or period of enrollment and the number of
calendar days completed in that period.
Context: During our testing of 13 R2T4 calculations, we identified that 7 had mechanically incorrect
calculations by using the incorrect number of scheduled break days in the Spring term. Also, during our
testing, we identified 2 instances of no documentation to support withdrawal date used for the R2T4
calculation. Furthermore, we were unable to identify a formal control procedure related to Return to Title IV
transactions.
Questioned costs: $1,363
Cause: The University was using the incorrect number of scheduled break days for Spring Term.
Effect: The University could return incorrect amounts based off of their calculations, which could affect
student repayment amounts based off of amount earned.
Repeat finding: Yes, 2022-015
Recommendation: We recommend that the University review policies and procedures related to R2T4
calculations to ensure calculations are performed correctly and timely. We also recommend the University
implement formal review procedures to document the Return of Title IV calculations are being performed to
minimize the likelihood that errors may go undetected and not be corrected in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University incorrectly calculated Return to Title IV (R2T4) calculations, did not have
documentation of withdrawal and did not have formal procedures in place to review the R2T4 calculations.
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Per 34 CFR 668.22(f)(2)(i), the total number of
calendar days in a payment period or period of enrollment includes all days within the period that the student
was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded
from the total number of calendar days in a payment period or period of enrollment and the number of
calendar days completed in that period.
Context: During our testing of 13 R2T4 calculations, we identified that 7 had mechanically incorrect
calculations by using the incorrect number of scheduled break days in the Spring term. Also, during our
testing, we identified 2 instances of no documentation to support withdrawal date used for the R2T4
calculation. Furthermore, we were unable to identify a formal control procedure related to Return to Title IV
transactions.
Questioned costs: $1,363
Cause: The University was using the incorrect number of scheduled break days for Spring Term.
Effect: The University could return incorrect amounts based off of their calculations, which could affect
student repayment amounts based off of amount earned.
Repeat finding: Yes, 2022-015
Recommendation: We recommend that the University review policies and procedures related to R2T4
calculations to ensure calculations are performed correctly and timely. We also recommend the University
implement formal review procedures to document the Return of Title IV calculations are being performed to
minimize the likelihood that errors may go undetected and not be corrected in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University incorrectly calculated Return to Title IV (R2T4) calculations, did not have
documentation of withdrawal and did not have formal procedures in place to review the R2T4 calculations.
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Per 34 CFR 668.22(f)(2)(i), the total number of
calendar days in a payment period or period of enrollment includes all days within the period that the student
was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded
from the total number of calendar days in a payment period or period of enrollment and the number of
calendar days completed in that period.
Context: During our testing of 13 R2T4 calculations, we identified that 7 had mechanically incorrect
calculations by using the incorrect number of scheduled break days in the Spring term. Also, during our
testing, we identified 2 instances of no documentation to support withdrawal date used for the R2T4
calculation. Furthermore, we were unable to identify a formal control procedure related to Return to Title IV
transactions.
Questioned costs: $1,363
Cause: The University was using the incorrect number of scheduled break days for Spring Term.
Effect: The University could return incorrect amounts based off of their calculations, which could affect
student repayment amounts based off of amount earned.
Repeat finding: Yes, 2022-015
Recommendation: We recommend that the University review policies and procedures related to R2T4
calculations to ensure calculations are performed correctly and timely. We also recommend the University
implement formal review procedures to document the Return of Title IV calculations are being performed to
minimize the likelihood that errors may go undetected and not be corrected in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University incorrectly calculated Return to Title IV (R2T4) calculations, did not have
documentation of withdrawal and did not have formal procedures in place to review the R2T4 calculations.
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Per 34 CFR 668.22(f)(2)(i), the total number of
calendar days in a payment period or period of enrollment includes all days within the period that the student
was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded
from the total number of calendar days in a payment period or period of enrollment and the number of
calendar days completed in that period.
Context: During our testing of 13 R2T4 calculations, we identified that 7 had mechanically incorrect
calculations by using the incorrect number of scheduled break days in the Spring term. Also, during our
testing, we identified 2 instances of no documentation to support withdrawal date used for the R2T4
calculation. Furthermore, we were unable to identify a formal control procedure related to Return to Title IV
transactions.
Questioned costs: $1,363
Cause: The University was using the incorrect number of scheduled break days for Spring Term.
Effect: The University could return incorrect amounts based off of their calculations, which could affect
student repayment amounts based off of amount earned.
Repeat finding: Yes, 2022-015
Recommendation: We recommend that the University review policies and procedures related to R2T4
calculations to ensure calculations are performed correctly and timely. We also recommend the University
implement formal review procedures to document the Return of Title IV calculations are being performed to
minimize the likelihood that errors may go undetected and not be corrected in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University incorrectly calculated Return to Title IV (R2T4) calculations, did not have
documentation of withdrawal and did not have formal procedures in place to review the R2T4 calculations.
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Per 34 CFR 668.22(f)(2)(i), the total number of
calendar days in a payment period or period of enrollment includes all days within the period that the student
was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded
from the total number of calendar days in a payment period or period of enrollment and the number of
calendar days completed in that period.
Context: During our testing of 13 R2T4 calculations, we identified that 7 had mechanically incorrect
calculations by using the incorrect number of scheduled break days in the Spring term. Also, during our
testing, we identified 2 instances of no documentation to support withdrawal date used for the R2T4
calculation. Furthermore, we were unable to identify a formal control procedure related to Return to Title IV
transactions.
Questioned costs: $1,363
Cause: The University was using the incorrect number of scheduled break days for Spring Term.
Effect: The University could return incorrect amounts based off of their calculations, which could affect
student repayment amounts based off of amount earned.
Repeat finding: Yes, 2022-015
Recommendation: We recommend that the University review policies and procedures related to R2T4
calculations to ensure calculations are performed correctly and timely. We also recommend the University
implement formal review procedures to document the Return of Title IV calculations are being performed to
minimize the likelihood that errors may go undetected and not be corrected in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University incorrectly calculated Return to Title IV (R2T4) calculations, did not have
documentation of withdrawal and did not have formal procedures in place to review the R2T4 calculations.
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Per 34 CFR 668.22(f)(2)(i), the total number of
calendar days in a payment period or period of enrollment includes all days within the period that the student
was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded
from the total number of calendar days in a payment period or period of enrollment and the number of
calendar days completed in that period.
Context: During our testing of 13 R2T4 calculations, we identified that 7 had mechanically incorrect
calculations by using the incorrect number of scheduled break days in the Spring term. Also, during our
testing, we identified 2 instances of no documentation to support withdrawal date used for the R2T4
calculation. Furthermore, we were unable to identify a formal control procedure related to Return to Title IV
transactions.
Questioned costs: $1,363
Cause: The University was using the incorrect number of scheduled break days for Spring Term.
Effect: The University could return incorrect amounts based off of their calculations, which could affect
student repayment amounts based off of amount earned.
Repeat finding: Yes, 2022-015
Recommendation: We recommend that the University review policies and procedures related to R2T4
calculations to ensure calculations are performed correctly and timely. We also recommend the University
implement formal review procedures to document the Return of Title IV calculations are being performed to
minimize the likelihood that errors may go undetected and not be corrected in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University incorrectly calculated Return to Title IV (R2T4) calculations, did not have
documentation of withdrawal and did not have formal procedures in place to review the R2T4 calculations.
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Per 34 CFR 668.22(f)(2)(i), the total number of
calendar days in a payment period or period of enrollment includes all days within the period that the student
was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded
from the total number of calendar days in a payment period or period of enrollment and the number of
calendar days completed in that period.
Context: During our testing of 13 R2T4 calculations, we identified that 7 had mechanically incorrect
calculations by using the incorrect number of scheduled break days in the Spring term. Also, during our
testing, we identified 2 instances of no documentation to support withdrawal date used for the R2T4
calculation. Furthermore, we were unable to identify a formal control procedure related to Return to Title IV
transactions.
Questioned costs: $1,363
Cause: The University was using the incorrect number of scheduled break days for Spring Term.
Effect: The University could return incorrect amounts based off of their calculations, which could affect
student repayment amounts based off of amount earned.
Repeat finding: Yes, 2022-015
Recommendation: We recommend that the University review policies and procedures related to R2T4
calculations to ensure calculations are performed correctly and timely. We also recommend the University
implement formal review procedures to document the Return of Title IV calculations are being performed to
minimize the likelihood that errors may go undetected and not be corrected in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University incorrectly calculated Return to Title IV (R2T4) calculations, did not have
documentation of withdrawal and did not have formal procedures in place to review the R2T4 calculations.
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Per 34 CFR 668.22(f)(2)(i), the total number of
calendar days in a payment period or period of enrollment includes all days within the period that the student
was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded
from the total number of calendar days in a payment period or period of enrollment and the number of
calendar days completed in that period.
Context: During our testing of 13 R2T4 calculations, we identified that 7 had mechanically incorrect
calculations by using the incorrect number of scheduled break days in the Spring term. Also, during our
testing, we identified 2 instances of no documentation to support withdrawal date used for the R2T4
calculation. Furthermore, we were unable to identify a formal control procedure related to Return to Title IV
transactions.
Questioned costs: $1,363
Cause: The University was using the incorrect number of scheduled break days for Spring Term.
Effect: The University could return incorrect amounts based off of their calculations, which could affect
student repayment amounts based off of amount earned.
Repeat finding: Yes, 2022-015
Recommendation: We recommend that the University review policies and procedures related to R2T4
calculations to ensure calculations are performed correctly and timely. We also recommend the University
implement formal review procedures to document the Return of Title IV calculations are being performed to
minimize the likelihood that errors may go undetected and not be corrected in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly report student enrollment changes for students who received
federal student aid to the National Student Loan Data System (NSLDS).
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Additionally, 34 CFR 682.610, states that
institutions must report accurately the enrollment status of all students regardless of if they receive aid from
the institution or not. Changes to said status are required to be reported within 30 days of becoming aware
of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is
within 60 days.
Context: During our testing of 60 students, we identified 5 students had the incorrect effective date, 44
students were reported past the 60-day reporting timeframe, 7 students did not have matching status change
for Campus and Program enrollment, 2 students did not have campus enrollment updated for withdrawal
status change, 2 students with the incorrect effective date on program enrollment and 1 student where
graduate status was not properly updated. Additionally, there is no evidence of review documented.
Questioned costs: N/A
Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched
the institutions records in a timely manner.
Effect: The University was not in compliance with the requirements to properly report student enrollment
data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the
repayment and interest of outstanding Title IV student loans.
Repeat finding: Yes, 2022-012
Recommendation: We recommend the University review current processes for reporting to NSLDS and
implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly report student enrollment changes for students who received
federal student aid to the National Student Loan Data System (NSLDS).
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Additionally, 34 CFR 682.610, states that
institutions must report accurately the enrollment status of all students regardless of if they receive aid from
the institution or not. Changes to said status are required to be reported within 30 days of becoming aware
of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is
within 60 days.
Context: During our testing of 60 students, we identified 5 students had the incorrect effective date, 44
students were reported past the 60-day reporting timeframe, 7 students did not have matching status change
for Campus and Program enrollment, 2 students did not have campus enrollment updated for withdrawal
status change, 2 students with the incorrect effective date on program enrollment and 1 student where
graduate status was not properly updated. Additionally, there is no evidence of review documented.
Questioned costs: N/A
Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched
the institutions records in a timely manner.
Effect: The University was not in compliance with the requirements to properly report student enrollment
data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the
repayment and interest of outstanding Title IV student loans.
Repeat finding: Yes, 2022-012
Recommendation: We recommend the University review current processes for reporting to NSLDS and
implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly report student enrollment changes for students who received
federal student aid to the National Student Loan Data System (NSLDS).
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Additionally, 34 CFR 682.610, states that
institutions must report accurately the enrollment status of all students regardless of if they receive aid from
the institution or not. Changes to said status are required to be reported within 30 days of becoming aware
of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is
within 60 days.
Context: During our testing of 60 students, we identified 5 students had the incorrect effective date, 44
students were reported past the 60-day reporting timeframe, 7 students did not have matching status change
for Campus and Program enrollment, 2 students did not have campus enrollment updated for withdrawal
status change, 2 students with the incorrect effective date on program enrollment and 1 student where
graduate status was not properly updated. Additionally, there is no evidence of review documented.
Questioned costs: N/A
Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched
the institutions records in a timely manner.
Effect: The University was not in compliance with the requirements to properly report student enrollment
data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the
repayment and interest of outstanding Title IV student loans.
Repeat finding: Yes, 2022-012
Recommendation: We recommend the University review current processes for reporting to NSLDS and
implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly report student enrollment changes for students who received
federal student aid to the National Student Loan Data System (NSLDS).
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Additionally, 34 CFR 682.610, states that
institutions must report accurately the enrollment status of all students regardless of if they receive aid from
the institution or not. Changes to said status are required to be reported within 30 days of becoming aware
of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is
within 60 days.
Context: During our testing of 60 students, we identified 5 students had the incorrect effective date, 44
students were reported past the 60-day reporting timeframe, 7 students did not have matching status change
for Campus and Program enrollment, 2 students did not have campus enrollment updated for withdrawal
status change, 2 students with the incorrect effective date on program enrollment and 1 student where
graduate status was not properly updated. Additionally, there is no evidence of review documented.
Questioned costs: N/A
Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched
the institutions records in a timely manner.
Effect: The University was not in compliance with the requirements to properly report student enrollment
data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the
repayment and interest of outstanding Title IV student loans.
Repeat finding: Yes, 2022-012
Recommendation: We recommend the University review current processes for reporting to NSLDS and
implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly report student enrollment changes for students who received
federal student aid to the National Student Loan Data System (NSLDS).
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Additionally, 34 CFR 682.610, states that
institutions must report accurately the enrollment status of all students regardless of if they receive aid from
the institution or not. Changes to said status are required to be reported within 30 days of becoming aware
of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is
within 60 days.
Context: During our testing of 60 students, we identified 5 students had the incorrect effective date, 44
students were reported past the 60-day reporting timeframe, 7 students did not have matching status change
for Campus and Program enrollment, 2 students did not have campus enrollment updated for withdrawal
status change, 2 students with the incorrect effective date on program enrollment and 1 student where
graduate status was not properly updated. Additionally, there is no evidence of review documented.
Questioned costs: N/A
Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched
the institutions records in a timely manner.
Effect: The University was not in compliance with the requirements to properly report student enrollment
data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the
repayment and interest of outstanding Title IV student loans.
Repeat finding: Yes, 2022-012
Recommendation: We recommend the University review current processes for reporting to NSLDS and
implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly report student enrollment changes for students who received
federal student aid to the National Student Loan Data System (NSLDS).
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Additionally, 34 CFR 682.610, states that
institutions must report accurately the enrollment status of all students regardless of if they receive aid from
the institution or not. Changes to said status are required to be reported within 30 days of becoming aware
of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is
within 60 days.
Context: During our testing of 60 students, we identified 5 students had the incorrect effective date, 44
students were reported past the 60-day reporting timeframe, 7 students did not have matching status change
for Campus and Program enrollment, 2 students did not have campus enrollment updated for withdrawal
status change, 2 students with the incorrect effective date on program enrollment and 1 student where
graduate status was not properly updated. Additionally, there is no evidence of review documented.
Questioned costs: N/A
Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched
the institutions records in a timely manner.
Effect: The University was not in compliance with the requirements to properly report student enrollment
data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the
repayment and interest of outstanding Title IV student loans.
Repeat finding: Yes, 2022-012
Recommendation: We recommend the University review current processes for reporting to NSLDS and
implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly report student enrollment changes for students who received
federal student aid to the National Student Loan Data System (NSLDS).
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Additionally, 34 CFR 682.610, states that
institutions must report accurately the enrollment status of all students regardless of if they receive aid from
the institution or not. Changes to said status are required to be reported within 30 days of becoming aware
of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is
within 60 days.
Context: During our testing of 60 students, we identified 5 students had the incorrect effective date, 44
students were reported past the 60-day reporting timeframe, 7 students did not have matching status change
for Campus and Program enrollment, 2 students did not have campus enrollment updated for withdrawal
status change, 2 students with the incorrect effective date on program enrollment and 1 student where
graduate status was not properly updated. Additionally, there is no evidence of review documented.
Questioned costs: N/A
Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched
the institutions records in a timely manner.
Effect: The University was not in compliance with the requirements to properly report student enrollment
data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the
repayment and interest of outstanding Title IV student loans.
Repeat finding: Yes, 2022-012
Recommendation: We recommend the University review current processes for reporting to NSLDS and
implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly report student enrollment changes for students who received
federal student aid to the National Student Loan Data System (NSLDS).
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Additionally, 34 CFR 682.610, states that
institutions must report accurately the enrollment status of all students regardless of if they receive aid from
the institution or not. Changes to said status are required to be reported within 30 days of becoming aware
of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is
within 60 days.
Context: During our testing of 60 students, we identified 5 students had the incorrect effective date, 44
students were reported past the 60-day reporting timeframe, 7 students did not have matching status change
for Campus and Program enrollment, 2 students did not have campus enrollment updated for withdrawal
status change, 2 students with the incorrect effective date on program enrollment and 1 student where
graduate status was not properly updated. Additionally, there is no evidence of review documented.
Questioned costs: N/A
Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched
the institutions records in a timely manner.
Effect: The University was not in compliance with the requirements to properly report student enrollment
data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the
repayment and interest of outstanding Title IV student loans.
Repeat finding: Yes, 2022-012
Recommendation: We recommend the University review current processes for reporting to NSLDS and
implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not properly have documentation of exit counseling notification.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school
must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or
professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive
electronic means. In each case, the school must ensure that this counseling is conducted shortly before the
student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities
receiving federal awards are required to establish and maintain internal controls designed to reasonably
ensure compliance with federal laws, regulations, and program compliance requirements.
Context: During our testing of 40 students, we identified 3 students that did not have documentation of exit
counseling notification.
Questioned costs: N/A
Cause: The University did not have proper procedures in place to ensure that notification of required exit
counseling was sent to applicable students.
Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and
reviews deferment and repayment plans options. If students are not notified of exit counseling, they could
be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat finding: No
Recommendation: We recommend the University review reporting processes to ensure all students that
require exit counseling receive it in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not properly have documentation of exit counseling notification.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school
must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or
professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive
electronic means. In each case, the school must ensure that this counseling is conducted shortly before the
student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities
receiving federal awards are required to establish and maintain internal controls designed to reasonably
ensure compliance with federal laws, regulations, and program compliance requirements.
Context: During our testing of 40 students, we identified 3 students that did not have documentation of exit
counseling notification.
Questioned costs: N/A
Cause: The University did not have proper procedures in place to ensure that notification of required exit
counseling was sent to applicable students.
Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and
reviews deferment and repayment plans options. If students are not notified of exit counseling, they could
be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat finding: No
Recommendation: We recommend the University review reporting processes to ensure all students that
require exit counseling receive it in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not properly have documentation of exit counseling notification.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school
must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or
professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive
electronic means. In each case, the school must ensure that this counseling is conducted shortly before the
student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities
receiving federal awards are required to establish and maintain internal controls designed to reasonably
ensure compliance with federal laws, regulations, and program compliance requirements.
Context: During our testing of 40 students, we identified 3 students that did not have documentation of exit
counseling notification.
Questioned costs: N/A
Cause: The University did not have proper procedures in place to ensure that notification of required exit
counseling was sent to applicable students.
Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and
reviews deferment and repayment plans options. If students are not notified of exit counseling, they could
be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat finding: No
Recommendation: We recommend the University review reporting processes to ensure all students that
require exit counseling receive it in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not properly have documentation of exit counseling notification.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school
must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or
professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive
electronic means. In each case, the school must ensure that this counseling is conducted shortly before the
student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities
receiving federal awards are required to establish and maintain internal controls designed to reasonably
ensure compliance with federal laws, regulations, and program compliance requirements.
Context: During our testing of 40 students, we identified 3 students that did not have documentation of exit
counseling notification.
Questioned costs: N/A
Cause: The University did not have proper procedures in place to ensure that notification of required exit
counseling was sent to applicable students.
Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and
reviews deferment and repayment plans options. If students are not notified of exit counseling, they could
be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat finding: No
Recommendation: We recommend the University review reporting processes to ensure all students that
require exit counseling receive it in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not properly have documentation of exit counseling notification.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school
must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or
professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive
electronic means. In each case, the school must ensure that this counseling is conducted shortly before the
student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities
receiving federal awards are required to establish and maintain internal controls designed to reasonably
ensure compliance with federal laws, regulations, and program compliance requirements.
Context: During our testing of 40 students, we identified 3 students that did not have documentation of exit
counseling notification.
Questioned costs: N/A
Cause: The University did not have proper procedures in place to ensure that notification of required exit
counseling was sent to applicable students.
Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and
reviews deferment and repayment plans options. If students are not notified of exit counseling, they could
be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat finding: No
Recommendation: We recommend the University review reporting processes to ensure all students that
require exit counseling receive it in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not properly have documentation of exit counseling notification.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school
must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or
professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive
electronic means. In each case, the school must ensure that this counseling is conducted shortly before the
student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities
receiving federal awards are required to establish and maintain internal controls designed to reasonably
ensure compliance with federal laws, regulations, and program compliance requirements.
Context: During our testing of 40 students, we identified 3 students that did not have documentation of exit
counseling notification.
Questioned costs: N/A
Cause: The University did not have proper procedures in place to ensure that notification of required exit
counseling was sent to applicable students.
Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and
reviews deferment and repayment plans options. If students are not notified of exit counseling, they could
be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat finding: No
Recommendation: We recommend the University review reporting processes to ensure all students that
require exit counseling receive it in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not properly have documentation of exit counseling notification.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school
must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or
professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive
electronic means. In each case, the school must ensure that this counseling is conducted shortly before the
student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities
receiving federal awards are required to establish and maintain internal controls designed to reasonably
ensure compliance with federal laws, regulations, and program compliance requirements.
Context: During our testing of 40 students, we identified 3 students that did not have documentation of exit
counseling notification.
Questioned costs: N/A
Cause: The University did not have proper procedures in place to ensure that notification of required exit
counseling was sent to applicable students.
Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and
reviews deferment and repayment plans options. If students are not notified of exit counseling, they could
be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat finding: No
Recommendation: We recommend the University review reporting processes to ensure all students that
require exit counseling receive it in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not properly have documentation of exit counseling notification.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school
must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or
professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive
electronic means. In each case, the school must ensure that this counseling is conducted shortly before the
student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities
receiving federal awards are required to establish and maintain internal controls designed to reasonably
ensure compliance with federal laws, regulations, and program compliance requirements.
Context: During our testing of 40 students, we identified 3 students that did not have documentation of exit
counseling notification.
Questioned costs: N/A
Cause: The University did not have proper procedures in place to ensure that notification of required exit
counseling was sent to applicable students.
Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and
reviews deferment and repayment plans options. If students are not notified of exit counseling, they could
be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat finding: No
Recommendation: We recommend the University review reporting processes to ensure all students that
require exit counseling receive it in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 43.008 and 93.433
Federal Award Identification Number: NNX15AP43A-2023, 90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement
method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar
days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably
believes the request to be improper. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: During our testing of 28 subrecipient payments, from a statistically valid sample, we identified 2
payments were not submitted within 30 days after receiving invoice from the subrecipients. One payment
was 39 days beyond the required 30 days and the second payment was 565 days beyond the required 30
days.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient payments were paid
timely.
Effect: The University was not in compliance with the regulation to make payments to subrecipients within
the required timeframe.
Repeat finding: No
Recommendation: We recommend that the University review and update current procedures to ensure
subrecipient payments are paid timely.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 43.008 and 93.433
Federal Award Identification Number: NNX15AP43A-2023, 90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement
method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar
days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably
believes the request to be improper. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: During our testing of 28 subrecipient payments, from a statistically valid sample, we identified 2
payments were not submitted within 30 days after receiving invoice from the subrecipients. One payment
was 39 days beyond the required 30 days and the second payment was 565 days beyond the required 30
days.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient payments were paid
timely.
Effect: The University was not in compliance with the regulation to make payments to subrecipients within
the required timeframe.
Repeat finding: No
Recommendation: We recommend that the University review and update current procedures to ensure
subrecipient payments are paid timely.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 43.008 and 93.433
Federal Award Identification Number: NNX15AP43A-2023, 90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement
method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar
days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably
believes the request to be improper. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: During our testing of 28 subrecipient payments, from a statistically valid sample, we identified 2
payments were not submitted within 30 days after receiving invoice from the subrecipients. One payment
was 39 days beyond the required 30 days and the second payment was 565 days beyond the required 30
days.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient payments were paid
timely.
Effect: The University was not in compliance with the regulation to make payments to subrecipients within
the required timeframe.
Repeat finding: No
Recommendation: We recommend that the University review and update current procedures to ensure
subrecipient payments are paid timely.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 43.008 and 93.433
Federal Award Identification Number: NNX15AP43A-2023, 90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement
method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar
days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably
believes the request to be improper. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: During our testing of 28 subrecipient payments, from a statistically valid sample, we identified 2
payments were not submitted within 30 days after receiving invoice from the subrecipients. One payment
was 39 days beyond the required 30 days and the second payment was 565 days beyond the required 30
days.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient payments were paid
timely.
Effect: The University was not in compliance with the regulation to make payments to subrecipients within
the required timeframe.
Repeat finding: No
Recommendation: We recommend that the University review and update current procedures to ensure
subrecipient payments are paid timely.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 43.008 and 93.433
Federal Award Identification Number: NNX15AP43A-2023, 90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement
method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar
days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably
believes the request to be improper. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: During our testing of 28 subrecipient payments, from a statistically valid sample, we identified 2
payments were not submitted within 30 days after receiving invoice from the subrecipients. One payment
was 39 days beyond the required 30 days and the second payment was 565 days beyond the required 30
days.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient payments were paid
timely.
Effect: The University was not in compliance with the regulation to make payments to subrecipients within
the required timeframe.
Repeat finding: No
Recommendation: We recommend that the University review and update current procedures to ensure
subrecipient payments are paid timely.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 43.008 and 93.433
Federal Award Identification Number: NNX15AP43A-2023, 90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement
method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar
days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably
believes the request to be improper. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: During our testing of 28 subrecipient payments, from a statistically valid sample, we identified 2
payments were not submitted within 30 days after receiving invoice from the subrecipients. One payment
was 39 days beyond the required 30 days and the second payment was 565 days beyond the required 30
days.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient payments were paid
timely.
Effect: The University was not in compliance with the regulation to make payments to subrecipients within
the required timeframe.
Repeat finding: No
Recommendation: We recommend that the University review and update current procedures to ensure
subrecipient payments are paid timely.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.512, 10.443, 10.215
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019,
NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019-
38640-29878
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure that USDA federal funds
were not spent on disallowed costs.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. As required by 2 CFR
200.403 expenditures of federal awards should be necessary and reasonable for the performance of the
Federal award and be allocable thereto under these principles.
Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded
to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791
in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40
payroll we identified 1 transaction that was improperly coded to the incorrect account code.
Questioned costs: $256,940
Cause: The University does not have an effective control in place to ensure payroll transactions are properly
coded between federal and nonfederal funds.
Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of
disallowed costs on the Schedule of Expenditures of Federal Awards.
Repeat finding: No
Recommendation: We recommend the University review its current procedures to ensure non-federal
costs are not being allocated to federal fund codes. Also, the University should process retro-active cost
transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Agriculture
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.215
Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University does not have adequate procedures in place to ensure federal awards are closed
in a timely manner.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b),
unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity
must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days
after the end date of the period of performance as specified in the terms and conditions of the Federal
award.
Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of
performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over
120 days after the period of performance had ended.
Questioned costs: N/A
Cause: The University does not have an effective control in place to ensure costs are properly incurred prior
to the end of the federal awards period of performance.
Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result
in inaccurate periodic financial reports and unallowable costs.
Repeat finding: No
Recommendation: We recommend the University review its current close out procedures and implement
additional procedures to monitor the timeliness of federal account close outs.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Various
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.205, 10.216, 12.630, 93.859
Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093,
5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not have documentation of physical inventory of the equipment purchased
with Federal funds.
Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing
equipment (including replacement equipment), whether acquired in whole or in part under a Federal award,
until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the
property must be taken and the results reconciled with the property records at least once every two years.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish
and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and
program compliance requirements.
Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling
$1,058,721 did not have documentation of a physical inventory completed.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure physical inventory over equipment
was completed every two years.
Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and
maintaining equipment.
Repeat finding: No
Recommendation: We recommend the University ensure that a physical inventory over equipment is
completed at least every two years.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs eligibility verification procedures.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: The University uses a third party to perform their verification procedures to assess Title IV student
eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other
documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-018
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs eligibility verification procedures.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: The University uses a third party to perform their verification procedures to assess Title IV student
eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other
documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-018
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs eligibility verification procedures.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: The University uses a third party to perform their verification procedures to assess Title IV student
eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other
documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-018
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs eligibility verification procedures.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: The University uses a third party to perform their verification procedures to assess Title IV student
eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other
documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-018
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs eligibility verification procedures.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: The University uses a third party to perform their verification procedures to assess Title IV student
eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other
documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-018
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs eligibility verification procedures.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: The University uses a third party to perform their verification procedures to assess Title IV student
eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other
documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-018
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs eligibility verification procedures.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: The University uses a third party to perform their verification procedures to assess Title IV student
eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other
documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-018
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs eligibility verification procedures.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: The University uses a third party to perform their verification procedures to assess Title IV student
eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other
documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-018
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly notify students when loans were credited to the student's ledger
account.
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or
parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to
cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder
of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the
student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or
TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are
disbursed by EFT payment or master check. Additionally per 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: During our Eligibility testing of 60 students, we noted that there were 43 students that received
loan disbursements however, all 43 students did not receive the required notification for each loan
disbursement.
Questioned costs: N/A
Cause: The University did not send loan disbursement notifications.
Effect: Students were not made aware of the anticipated date and amount of loan disbursement for the right
to cancel all or a portion of the loan in the required amount of time.
Repeat finding: Yes, 2022-013
Recommendation: We recommend the University evaluate its procedures around disbursements of loans
and ensure that notifications of disbursements are sent and contain all the required elements outlined in the
FSA handbook.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly notify students when loans were credited to the student's ledger
account.
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or
parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to
cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder
of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the
student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or
TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are
disbursed by EFT payment or master check. Additionally per 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: During our Eligibility testing of 60 students, we noted that there were 43 students that received
loan disbursements however, all 43 students did not receive the required notification for each loan
disbursement.
Questioned costs: N/A
Cause: The University did not send loan disbursement notifications.
Effect: Students were not made aware of the anticipated date and amount of loan disbursement for the right
to cancel all or a portion of the loan in the required amount of time.
Repeat finding: Yes, 2022-013
Recommendation: We recommend the University evaluate its procedures around disbursements of loans
and ensure that notifications of disbursements are sent and contain all the required elements outlined in the
FSA handbook.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly notify students when loans were credited to the student's ledger
account.
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or
parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to
cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder
of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the
student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or
TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are
disbursed by EFT payment or master check. Additionally per 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: During our Eligibility testing of 60 students, we noted that there were 43 students that received
loan disbursements however, all 43 students did not receive the required notification for each loan
disbursement.
Questioned costs: N/A
Cause: The University did not send loan disbursement notifications.
Effect: Students were not made aware of the anticipated date and amount of loan disbursement for the right
to cancel all or a portion of the loan in the required amount of time.
Repeat finding: Yes, 2022-013
Recommendation: We recommend the University evaluate its procedures around disbursements of loans
and ensure that notifications of disbursements are sent and contain all the required elements outlined in the
FSA handbook.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly notify students when loans were credited to the student's ledger
account.
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or
parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to
cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder
of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the
student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or
TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are
disbursed by EFT payment or master check. Additionally per 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: During our Eligibility testing of 60 students, we noted that there were 43 students that received
loan disbursements however, all 43 students did not receive the required notification for each loan
disbursement.
Questioned costs: N/A
Cause: The University did not send loan disbursement notifications.
Effect: Students were not made aware of the anticipated date and amount of loan disbursement for the right
to cancel all or a portion of the loan in the required amount of time.
Repeat finding: Yes, 2022-013
Recommendation: We recommend the University evaluate its procedures around disbursements of loans
and ensure that notifications of disbursements are sent and contain all the required elements outlined in the
FSA handbook.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly notify students when loans were credited to the student's ledger
account.
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or
parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to
cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder
of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the
student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or
TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are
disbursed by EFT payment or master check. Additionally per 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: During our Eligibility testing of 60 students, we noted that there were 43 students that received
loan disbursements however, all 43 students did not receive the required notification for each loan
disbursement.
Questioned costs: N/A
Cause: The University did not send loan disbursement notifications.
Effect: Students were not made aware of the anticipated date and amount of loan disbursement for the right
to cancel all or a portion of the loan in the required amount of time.
Repeat finding: Yes, 2022-013
Recommendation: We recommend the University evaluate its procedures around disbursements of loans
and ensure that notifications of disbursements are sent and contain all the required elements outlined in the
FSA handbook.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly notify students when loans were credited to the student's ledger
account.
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or
parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to
cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder
of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the
student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or
TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are
disbursed by EFT payment or master check. Additionally per 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: During our Eligibility testing of 60 students, we noted that there were 43 students that received
loan disbursements however, all 43 students did not receive the required notification for each loan
disbursement.
Questioned costs: N/A
Cause: The University did not send loan disbursement notifications.
Effect: Students were not made aware of the anticipated date and amount of loan disbursement for the right
to cancel all or a portion of the loan in the required amount of time.
Repeat finding: Yes, 2022-013
Recommendation: We recommend the University evaluate its procedures around disbursements of loans
and ensure that notifications of disbursements are sent and contain all the required elements outlined in the
FSA handbook.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly notify students when loans were credited to the student's ledger
account.
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or
parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to
cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder
of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the
student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or
TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are
disbursed by EFT payment or master check. Additionally per 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: During our Eligibility testing of 60 students, we noted that there were 43 students that received
loan disbursements however, all 43 students did not receive the required notification for each loan
disbursement.
Questioned costs: N/A
Cause: The University did not send loan disbursement notifications.
Effect: Students were not made aware of the anticipated date and amount of loan disbursement for the right
to cancel all or a portion of the loan in the required amount of time.
Repeat finding: Yes, 2022-013
Recommendation: We recommend the University evaluate its procedures around disbursements of loans
and ensure that notifications of disbursements are sent and contain all the required elements outlined in the
FSA handbook.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly notify students when loans were credited to the student's ledger
account.
Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or
parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to
cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder
of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the
student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or
TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are
disbursed by EFT payment or master check. Additionally per 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements.
Context: During our Eligibility testing of 60 students, we noted that there were 43 students that received
loan disbursements however, all 43 students did not receive the required notification for each loan
disbursement.
Questioned costs: N/A
Cause: The University did not send loan disbursement notifications.
Effect: Students were not made aware of the anticipated date and amount of loan disbursement for the right
to cancel all or a portion of the loan in the required amount of time.
Repeat finding: Yes, 2022-013
Recommendation: We recommend the University evaluate its procedures around disbursements of loans
and ensure that notifications of disbursements are sent and contain all the required elements outlined in the
FSA handbook.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University has a Written information Security Program; however, the University did not meet
the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not
designate a qualified individual responsible for overseeing and implementing the information and security
program.
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to
explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314).
The regulation states that the college must designate a qualified individual responsible for overseeing and
implementing your information security program and enforcing your information security program. (16 CFR
314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and
implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s
written information security program must address the implementation of the minimum safeguards identified
in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written
security program provides for the institution to regularly test or otherwise monitor the effectiveness of the
safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal
awards are required to establish and maintain internal controls designed to reasonably ensure compliance
with federal laws, regulations, and program compliance requirements.
Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were seven
elements missing from their Written Information Security Program.
Questioned costs: N/A
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure
compliance.
Effect: The University was not in compliance with Gramm-Leach-Bliley compliance standards.
Repeat finding: Yes, 2022-017
Recommendation: We recommend that the University review the updated GLBA requirements and ensure
their WISP includes all required elements.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University has a Written information Security Program; however, the University did not meet
the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not
designate a qualified individual responsible for overseeing and implementing the information and security
program.
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to
explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314).
The regulation states that the college must designate a qualified individual responsible for overseeing and
implementing your information security program and enforcing your information security program. (16 CFR
314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and
implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s
written information security program must address the implementation of the minimum safeguards identified
in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written
security program provides for the institution to regularly test or otherwise monitor the effectiveness of the
safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal
awards are required to establish and maintain internal controls designed to reasonably ensure compliance
with federal laws, regulations, and program compliance requirements.
Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were seven
elements missing from their Written Information Security Program.
Questioned costs: N/A
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure
compliance.
Effect: The University was not in compliance with Gramm-Leach-Bliley compliance standards.
Repeat finding: Yes, 2022-017
Recommendation: We recommend that the University review the updated GLBA requirements and ensure
their WISP includes all required elements.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University has a Written information Security Program; however, the University did not meet
the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not
designate a qualified individual responsible for overseeing and implementing the information and security
program.
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to
explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314).
The regulation states that the college must designate a qualified individual responsible for overseeing and
implementing your information security program and enforcing your information security program. (16 CFR
314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and
implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s
written information security program must address the implementation of the minimum safeguards identified
in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written
security program provides for the institution to regularly test or otherwise monitor the effectiveness of the
safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal
awards are required to establish and maintain internal controls designed to reasonably ensure compliance
with federal laws, regulations, and program compliance requirements.
Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were seven
elements missing from their Written Information Security Program.
Questioned costs: N/A
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure
compliance.
Effect: The University was not in compliance with Gramm-Leach-Bliley compliance standards.
Repeat finding: Yes, 2022-017
Recommendation: We recommend that the University review the updated GLBA requirements and ensure
their WISP includes all required elements.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University has a Written information Security Program; however, the University did not meet
the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not
designate a qualified individual responsible for overseeing and implementing the information and security
program.
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to
explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314).
The regulation states that the college must designate a qualified individual responsible for overseeing and
implementing your information security program and enforcing your information security program. (16 CFR
314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and
implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s
written information security program must address the implementation of the minimum safeguards identified
in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written
security program provides for the institution to regularly test or otherwise monitor the effectiveness of the
safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal
awards are required to establish and maintain internal controls designed to reasonably ensure compliance
with federal laws, regulations, and program compliance requirements.
Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were seven
elements missing from their Written Information Security Program.
Questioned costs: N/A
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure
compliance.
Effect: The University was not in compliance with Gramm-Leach-Bliley compliance standards.
Repeat finding: Yes, 2022-017
Recommendation: We recommend that the University review the updated GLBA requirements and ensure
their WISP includes all required elements.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University has a Written information Security Program; however, the University did not meet
the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not
designate a qualified individual responsible for overseeing and implementing the information and security
program.
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to
explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314).
The regulation states that the college must designate a qualified individual responsible for overseeing and
implementing your information security program and enforcing your information security program. (16 CFR
314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and
implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s
written information security program must address the implementation of the minimum safeguards identified
in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written
security program provides for the institution to regularly test or otherwise monitor the effectiveness of the
safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal
awards are required to establish and maintain internal controls designed to reasonably ensure compliance
with federal laws, regulations, and program compliance requirements.
Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were seven
elements missing from their Written Information Security Program.
Questioned costs: N/A
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure
compliance.
Effect: The University was not in compliance with Gramm-Leach-Bliley compliance standards.
Repeat finding: Yes, 2022-017
Recommendation: We recommend that the University review the updated GLBA requirements and ensure
their WISP includes all required elements.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University has a Written information Security Program; however, the University did not meet
the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not
designate a qualified individual responsible for overseeing and implementing the information and security
program.
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to
explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314).
The regulation states that the college must designate a qualified individual responsible for overseeing and
implementing your information security program and enforcing your information security program. (16 CFR
314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and
implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s
written information security program must address the implementation of the minimum safeguards identified
in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written
security program provides for the institution to regularly test or otherwise monitor the effectiveness of the
safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal
awards are required to establish and maintain internal controls designed to reasonably ensure compliance
with federal laws, regulations, and program compliance requirements.
Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were seven
elements missing from their Written Information Security Program.
Questioned costs: N/A
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure
compliance.
Effect: The University was not in compliance with Gramm-Leach-Bliley compliance standards.
Repeat finding: Yes, 2022-017
Recommendation: We recommend that the University review the updated GLBA requirements and ensure
their WISP includes all required elements.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University has a Written information Security Program; however, the University did not meet
the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not
designate a qualified individual responsible for overseeing and implementing the information and security
program.
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to
explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314).
The regulation states that the college must designate a qualified individual responsible for overseeing and
implementing your information security program and enforcing your information security program. (16 CFR
314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and
implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s
written information security program must address the implementation of the minimum safeguards identified
in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written
security program provides for the institution to regularly test or otherwise monitor the effectiveness of the
safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal
awards are required to establish and maintain internal controls designed to reasonably ensure compliance
with federal laws, regulations, and program compliance requirements.
Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were seven
elements missing from their Written Information Security Program.
Questioned costs: N/A
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure
compliance.
Effect: The University was not in compliance with Gramm-Leach-Bliley compliance standards.
Repeat finding: Yes, 2022-017
Recommendation: We recommend that the University review the updated GLBA requirements and ensure
their WISP includes all required elements.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University has a Written information Security Program; however, the University did not meet
the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not
designate a qualified individual responsible for overseeing and implementing the information and security
program.
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to
explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314).
The regulation states that the college must designate a qualified individual responsible for overseeing and
implementing your information security program and enforcing your information security program. (16 CFR
314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and
implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s
written information security program must address the implementation of the minimum safeguards identified
in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written
security program provides for the institution to regularly test or otherwise monitor the effectiveness of the
safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal
awards are required to establish and maintain internal controls designed to reasonably ensure compliance
with federal laws, regulations, and program compliance requirements.
Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were seven
elements missing from their Written Information Security Program.
Questioned costs: N/A
Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure
compliance.
Effect: The University was not in compliance with Gramm-Leach-Bliley compliance standards.
Repeat finding: Yes, 2022-017
Recommendation: We recommend that the University review the updated GLBA requirements and ensure
their WISP includes all required elements.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: Langston University had 2 instance of Title IV refund checks to students that were outstanding
longer than 240 days as of June 30, 2023.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an
institution that attempts to disburse funds by check and the check is not cashed, the institution must return
the funds to the Secretary no later than 240 days after the date it issued that check. The Code of Federal
Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award.
Context: During the testing of the outstanding Title IV student check listing CLA observed two instances of
stale checks at Langston that were aged greater than 240 days.
Questioned costs: N/A
Cause: The University did not return checks that were not cashed within 240 days.
Effect: Funds are not returned to the Department of Education in a timely manner.
Repeat finding: No
Recommendation: We recommend that the University establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award and that stale federal aid checks are returned
to the Department of Education with 240 days after the date of issuance if not cashed.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: Langston University had 2 instance of Title IV refund checks to students that were outstanding
longer than 240 days as of June 30, 2023.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an
institution that attempts to disburse funds by check and the check is not cashed, the institution must return
the funds to the Secretary no later than 240 days after the date it issued that check. The Code of Federal
Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award.
Context: During the testing of the outstanding Title IV student check listing CLA observed two instances of
stale checks at Langston that were aged greater than 240 days.
Questioned costs: N/A
Cause: The University did not return checks that were not cashed within 240 days.
Effect: Funds are not returned to the Department of Education in a timely manner.
Repeat finding: No
Recommendation: We recommend that the University establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award and that stale federal aid checks are returned
to the Department of Education with 240 days after the date of issuance if not cashed.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: Langston University had 2 instance of Title IV refund checks to students that were outstanding
longer than 240 days as of June 30, 2023.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an
institution that attempts to disburse funds by check and the check is not cashed, the institution must return
the funds to the Secretary no later than 240 days after the date it issued that check. The Code of Federal
Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award.
Context: During the testing of the outstanding Title IV student check listing CLA observed two instances of
stale checks at Langston that were aged greater than 240 days.
Questioned costs: N/A
Cause: The University did not return checks that were not cashed within 240 days.
Effect: Funds are not returned to the Department of Education in a timely manner.
Repeat finding: No
Recommendation: We recommend that the University establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award and that stale federal aid checks are returned
to the Department of Education with 240 days after the date of issuance if not cashed.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: Langston University had 2 instance of Title IV refund checks to students that were outstanding
longer than 240 days as of June 30, 2023.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an
institution that attempts to disburse funds by check and the check is not cashed, the institution must return
the funds to the Secretary no later than 240 days after the date it issued that check. The Code of Federal
Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award.
Context: During the testing of the outstanding Title IV student check listing CLA observed two instances of
stale checks at Langston that were aged greater than 240 days.
Questioned costs: N/A
Cause: The University did not return checks that were not cashed within 240 days.
Effect: Funds are not returned to the Department of Education in a timely manner.
Repeat finding: No
Recommendation: We recommend that the University establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award and that stale federal aid checks are returned
to the Department of Education with 240 days after the date of issuance if not cashed.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: Langston University had 2 instance of Title IV refund checks to students that were outstanding
longer than 240 days as of June 30, 2023.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an
institution that attempts to disburse funds by check and the check is not cashed, the institution must return
the funds to the Secretary no later than 240 days after the date it issued that check. The Code of Federal
Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award.
Context: During the testing of the outstanding Title IV student check listing CLA observed two instances of
stale checks at Langston that were aged greater than 240 days.
Questioned costs: N/A
Cause: The University did not return checks that were not cashed within 240 days.
Effect: Funds are not returned to the Department of Education in a timely manner.
Repeat finding: No
Recommendation: We recommend that the University establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award and that stale federal aid checks are returned
to the Department of Education with 240 days after the date of issuance if not cashed.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: Langston University had 2 instance of Title IV refund checks to students that were outstanding
longer than 240 days as of June 30, 2023.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an
institution that attempts to disburse funds by check and the check is not cashed, the institution must return
the funds to the Secretary no later than 240 days after the date it issued that check. The Code of Federal
Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award.
Context: During the testing of the outstanding Title IV student check listing CLA observed two instances of
stale checks at Langston that were aged greater than 240 days.
Questioned costs: N/A
Cause: The University did not return checks that were not cashed within 240 days.
Effect: Funds are not returned to the Department of Education in a timely manner.
Repeat finding: No
Recommendation: We recommend that the University establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award and that stale federal aid checks are returned
to the Department of Education with 240 days after the date of issuance if not cashed.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: Langston University had 2 instance of Title IV refund checks to students that were outstanding
longer than 240 days as of June 30, 2023.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an
institution that attempts to disburse funds by check and the check is not cashed, the institution must return
the funds to the Secretary no later than 240 days after the date it issued that check. The Code of Federal
Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award.
Context: During the testing of the outstanding Title IV student check listing CLA observed two instances of
stale checks at Langston that were aged greater than 240 days.
Questioned costs: N/A
Cause: The University did not return checks that were not cashed within 240 days.
Effect: Funds are not returned to the Department of Education in a timely manner.
Repeat finding: No
Recommendation: We recommend that the University establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award and that stale federal aid checks are returned
to the Department of Education with 240 days after the date of issuance if not cashed.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: Langston University had 2 instance of Title IV refund checks to students that were outstanding
longer than 240 days as of June 30, 2023.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an
institution that attempts to disburse funds by check and the check is not cashed, the institution must return
the funds to the Secretary no later than 240 days after the date it issued that check. The Code of Federal
Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award.
Context: During the testing of the outstanding Title IV student check listing CLA observed two instances of
stale checks at Langston that were aged greater than 240 days.
Questioned costs: N/A
Cause: The University did not return checks that were not cashed within 240 days.
Effect: Funds are not returned to the Department of Education in a timely manner.
Repeat finding: No
Recommendation: We recommend that the University establish and maintain internal controls which
provide reasonable assurance that federal award expenditures are in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal Award and that stale federal aid checks are returned
to the Department of Education with 240 days after the date of issuance if not cashed.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University incorrectly calculated Return to Title IV (R2T4) calculations, did not have
documentation of withdrawal and did not have formal procedures in place to review the R2T4 calculations.
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Per 34 CFR 668.22(f)(2)(i), the total number of
calendar days in a payment period or period of enrollment includes all days within the period that the student
was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded
from the total number of calendar days in a payment period or period of enrollment and the number of
calendar days completed in that period.
Context: During our testing of 13 R2T4 calculations, we identified that 7 had mechanically incorrect
calculations by using the incorrect number of scheduled break days in the Spring term. Also, during our
testing, we identified 2 instances of no documentation to support withdrawal date used for the R2T4
calculation. Furthermore, we were unable to identify a formal control procedure related to Return to Title IV
transactions.
Questioned costs: $1,363
Cause: The University was using the incorrect number of scheduled break days for Spring Term.
Effect: The University could return incorrect amounts based off of their calculations, which could affect
student repayment amounts based off of amount earned.
Repeat finding: Yes, 2022-015
Recommendation: We recommend that the University review policies and procedures related to R2T4
calculations to ensure calculations are performed correctly and timely. We also recommend the University
implement formal review procedures to document the Return of Title IV calculations are being performed to
minimize the likelihood that errors may go undetected and not be corrected in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University incorrectly calculated Return to Title IV (R2T4) calculations, did not have
documentation of withdrawal and did not have formal procedures in place to review the R2T4 calculations.
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Per 34 CFR 668.22(f)(2)(i), the total number of
calendar days in a payment period or period of enrollment includes all days within the period that the student
was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded
from the total number of calendar days in a payment period or period of enrollment and the number of
calendar days completed in that period.
Context: During our testing of 13 R2T4 calculations, we identified that 7 had mechanically incorrect
calculations by using the incorrect number of scheduled break days in the Spring term. Also, during our
testing, we identified 2 instances of no documentation to support withdrawal date used for the R2T4
calculation. Furthermore, we were unable to identify a formal control procedure related to Return to Title IV
transactions.
Questioned costs: $1,363
Cause: The University was using the incorrect number of scheduled break days for Spring Term.
Effect: The University could return incorrect amounts based off of their calculations, which could affect
student repayment amounts based off of amount earned.
Repeat finding: Yes, 2022-015
Recommendation: We recommend that the University review policies and procedures related to R2T4
calculations to ensure calculations are performed correctly and timely. We also recommend the University
implement formal review procedures to document the Return of Title IV calculations are being performed to
minimize the likelihood that errors may go undetected and not be corrected in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University incorrectly calculated Return to Title IV (R2T4) calculations, did not have
documentation of withdrawal and did not have formal procedures in place to review the R2T4 calculations.
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Per 34 CFR 668.22(f)(2)(i), the total number of
calendar days in a payment period or period of enrollment includes all days within the period that the student
was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded
from the total number of calendar days in a payment period or period of enrollment and the number of
calendar days completed in that period.
Context: During our testing of 13 R2T4 calculations, we identified that 7 had mechanically incorrect
calculations by using the incorrect number of scheduled break days in the Spring term. Also, during our
testing, we identified 2 instances of no documentation to support withdrawal date used for the R2T4
calculation. Furthermore, we were unable to identify a formal control procedure related to Return to Title IV
transactions.
Questioned costs: $1,363
Cause: The University was using the incorrect number of scheduled break days for Spring Term.
Effect: The University could return incorrect amounts based off of their calculations, which could affect
student repayment amounts based off of amount earned.
Repeat finding: Yes, 2022-015
Recommendation: We recommend that the University review policies and procedures related to R2T4
calculations to ensure calculations are performed correctly and timely. We also recommend the University
implement formal review procedures to document the Return of Title IV calculations are being performed to
minimize the likelihood that errors may go undetected and not be corrected in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University incorrectly calculated Return to Title IV (R2T4) calculations, did not have
documentation of withdrawal and did not have formal procedures in place to review the R2T4 calculations.
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Per 34 CFR 668.22(f)(2)(i), the total number of
calendar days in a payment period or period of enrollment includes all days within the period that the student
was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded
from the total number of calendar days in a payment period or period of enrollment and the number of
calendar days completed in that period.
Context: During our testing of 13 R2T4 calculations, we identified that 7 had mechanically incorrect
calculations by using the incorrect number of scheduled break days in the Spring term. Also, during our
testing, we identified 2 instances of no documentation to support withdrawal date used for the R2T4
calculation. Furthermore, we were unable to identify a formal control procedure related to Return to Title IV
transactions.
Questioned costs: $1,363
Cause: The University was using the incorrect number of scheduled break days for Spring Term.
Effect: The University could return incorrect amounts based off of their calculations, which could affect
student repayment amounts based off of amount earned.
Repeat finding: Yes, 2022-015
Recommendation: We recommend that the University review policies and procedures related to R2T4
calculations to ensure calculations are performed correctly and timely. We also recommend the University
implement formal review procedures to document the Return of Title IV calculations are being performed to
minimize the likelihood that errors may go undetected and not be corrected in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University incorrectly calculated Return to Title IV (R2T4) calculations, did not have
documentation of withdrawal and did not have formal procedures in place to review the R2T4 calculations.
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Per 34 CFR 668.22(f)(2)(i), the total number of
calendar days in a payment period or period of enrollment includes all days within the period that the student
was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded
from the total number of calendar days in a payment period or period of enrollment and the number of
calendar days completed in that period.
Context: During our testing of 13 R2T4 calculations, we identified that 7 had mechanically incorrect
calculations by using the incorrect number of scheduled break days in the Spring term. Also, during our
testing, we identified 2 instances of no documentation to support withdrawal date used for the R2T4
calculation. Furthermore, we were unable to identify a formal control procedure related to Return to Title IV
transactions.
Questioned costs: $1,363
Cause: The University was using the incorrect number of scheduled break days for Spring Term.
Effect: The University could return incorrect amounts based off of their calculations, which could affect
student repayment amounts based off of amount earned.
Repeat finding: Yes, 2022-015
Recommendation: We recommend that the University review policies and procedures related to R2T4
calculations to ensure calculations are performed correctly and timely. We also recommend the University
implement formal review procedures to document the Return of Title IV calculations are being performed to
minimize the likelihood that errors may go undetected and not be corrected in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University incorrectly calculated Return to Title IV (R2T4) calculations, did not have
documentation of withdrawal and did not have formal procedures in place to review the R2T4 calculations.
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Per 34 CFR 668.22(f)(2)(i), the total number of
calendar days in a payment period or period of enrollment includes all days within the period that the student
was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded
from the total number of calendar days in a payment period or period of enrollment and the number of
calendar days completed in that period.
Context: During our testing of 13 R2T4 calculations, we identified that 7 had mechanically incorrect
calculations by using the incorrect number of scheduled break days in the Spring term. Also, during our
testing, we identified 2 instances of no documentation to support withdrawal date used for the R2T4
calculation. Furthermore, we were unable to identify a formal control procedure related to Return to Title IV
transactions.
Questioned costs: $1,363
Cause: The University was using the incorrect number of scheduled break days for Spring Term.
Effect: The University could return incorrect amounts based off of their calculations, which could affect
student repayment amounts based off of amount earned.
Repeat finding: Yes, 2022-015
Recommendation: We recommend that the University review policies and procedures related to R2T4
calculations to ensure calculations are performed correctly and timely. We also recommend the University
implement formal review procedures to document the Return of Title IV calculations are being performed to
minimize the likelihood that errors may go undetected and not be corrected in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University incorrectly calculated Return to Title IV (R2T4) calculations, did not have
documentation of withdrawal and did not have formal procedures in place to review the R2T4 calculations.
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Per 34 CFR 668.22(f)(2)(i), the total number of
calendar days in a payment period or period of enrollment includes all days within the period that the student
was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded
from the total number of calendar days in a payment period or period of enrollment and the number of
calendar days completed in that period.
Context: During our testing of 13 R2T4 calculations, we identified that 7 had mechanically incorrect
calculations by using the incorrect number of scheduled break days in the Spring term. Also, during our
testing, we identified 2 instances of no documentation to support withdrawal date used for the R2T4
calculation. Furthermore, we were unable to identify a formal control procedure related to Return to Title IV
transactions.
Questioned costs: $1,363
Cause: The University was using the incorrect number of scheduled break days for Spring Term.
Effect: The University could return incorrect amounts based off of their calculations, which could affect
student repayment amounts based off of amount earned.
Repeat finding: Yes, 2022-015
Recommendation: We recommend that the University review policies and procedures related to R2T4
calculations to ensure calculations are performed correctly and timely. We also recommend the University
implement formal review procedures to document the Return of Title IV calculations are being performed to
minimize the likelihood that errors may go undetected and not be corrected in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University incorrectly calculated Return to Title IV (R2T4) calculations, did not have
documentation of withdrawal and did not have formal procedures in place to review the R2T4 calculations.
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Per 34 CFR 668.22(f)(2)(i), the total number of
calendar days in a payment period or period of enrollment includes all days within the period that the student
was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded
from the total number of calendar days in a payment period or period of enrollment and the number of
calendar days completed in that period.
Context: During our testing of 13 R2T4 calculations, we identified that 7 had mechanically incorrect
calculations by using the incorrect number of scheduled break days in the Spring term. Also, during our
testing, we identified 2 instances of no documentation to support withdrawal date used for the R2T4
calculation. Furthermore, we were unable to identify a formal control procedure related to Return to Title IV
transactions.
Questioned costs: $1,363
Cause: The University was using the incorrect number of scheduled break days for Spring Term.
Effect: The University could return incorrect amounts based off of their calculations, which could affect
student repayment amounts based off of amount earned.
Repeat finding: Yes, 2022-015
Recommendation: We recommend that the University review policies and procedures related to R2T4
calculations to ensure calculations are performed correctly and timely. We also recommend the University
implement formal review procedures to document the Return of Title IV calculations are being performed to
minimize the likelihood that errors may go undetected and not be corrected in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly report student enrollment changes for students who received
federal student aid to the National Student Loan Data System (NSLDS).
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Additionally, 34 CFR 682.610, states that
institutions must report accurately the enrollment status of all students regardless of if they receive aid from
the institution or not. Changes to said status are required to be reported within 30 days of becoming aware
of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is
within 60 days.
Context: During our testing of 60 students, we identified 5 students had the incorrect effective date, 44
students were reported past the 60-day reporting timeframe, 7 students did not have matching status change
for Campus and Program enrollment, 2 students did not have campus enrollment updated for withdrawal
status change, 2 students with the incorrect effective date on program enrollment and 1 student where
graduate status was not properly updated. Additionally, there is no evidence of review documented.
Questioned costs: N/A
Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched
the institutions records in a timely manner.
Effect: The University was not in compliance with the requirements to properly report student enrollment
data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the
repayment and interest of outstanding Title IV student loans.
Repeat finding: Yes, 2022-012
Recommendation: We recommend the University review current processes for reporting to NSLDS and
implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly report student enrollment changes for students who received
federal student aid to the National Student Loan Data System (NSLDS).
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Additionally, 34 CFR 682.610, states that
institutions must report accurately the enrollment status of all students regardless of if they receive aid from
the institution or not. Changes to said status are required to be reported within 30 days of becoming aware
of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is
within 60 days.
Context: During our testing of 60 students, we identified 5 students had the incorrect effective date, 44
students were reported past the 60-day reporting timeframe, 7 students did not have matching status change
for Campus and Program enrollment, 2 students did not have campus enrollment updated for withdrawal
status change, 2 students with the incorrect effective date on program enrollment and 1 student where
graduate status was not properly updated. Additionally, there is no evidence of review documented.
Questioned costs: N/A
Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched
the institutions records in a timely manner.
Effect: The University was not in compliance with the requirements to properly report student enrollment
data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the
repayment and interest of outstanding Title IV student loans.
Repeat finding: Yes, 2022-012
Recommendation: We recommend the University review current processes for reporting to NSLDS and
implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly report student enrollment changes for students who received
federal student aid to the National Student Loan Data System (NSLDS).
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Additionally, 34 CFR 682.610, states that
institutions must report accurately the enrollment status of all students regardless of if they receive aid from
the institution or not. Changes to said status are required to be reported within 30 days of becoming aware
of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is
within 60 days.
Context: During our testing of 60 students, we identified 5 students had the incorrect effective date, 44
students were reported past the 60-day reporting timeframe, 7 students did not have matching status change
for Campus and Program enrollment, 2 students did not have campus enrollment updated for withdrawal
status change, 2 students with the incorrect effective date on program enrollment and 1 student where
graduate status was not properly updated. Additionally, there is no evidence of review documented.
Questioned costs: N/A
Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched
the institutions records in a timely manner.
Effect: The University was not in compliance with the requirements to properly report student enrollment
data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the
repayment and interest of outstanding Title IV student loans.
Repeat finding: Yes, 2022-012
Recommendation: We recommend the University review current processes for reporting to NSLDS and
implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly report student enrollment changes for students who received
federal student aid to the National Student Loan Data System (NSLDS).
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Additionally, 34 CFR 682.610, states that
institutions must report accurately the enrollment status of all students regardless of if they receive aid from
the institution or not. Changes to said status are required to be reported within 30 days of becoming aware
of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is
within 60 days.
Context: During our testing of 60 students, we identified 5 students had the incorrect effective date, 44
students were reported past the 60-day reporting timeframe, 7 students did not have matching status change
for Campus and Program enrollment, 2 students did not have campus enrollment updated for withdrawal
status change, 2 students with the incorrect effective date on program enrollment and 1 student where
graduate status was not properly updated. Additionally, there is no evidence of review documented.
Questioned costs: N/A
Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched
the institutions records in a timely manner.
Effect: The University was not in compliance with the requirements to properly report student enrollment
data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the
repayment and interest of outstanding Title IV student loans.
Repeat finding: Yes, 2022-012
Recommendation: We recommend the University review current processes for reporting to NSLDS and
implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly report student enrollment changes for students who received
federal student aid to the National Student Loan Data System (NSLDS).
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Additionally, 34 CFR 682.610, states that
institutions must report accurately the enrollment status of all students regardless of if they receive aid from
the institution or not. Changes to said status are required to be reported within 30 days of becoming aware
of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is
within 60 days.
Context: During our testing of 60 students, we identified 5 students had the incorrect effective date, 44
students were reported past the 60-day reporting timeframe, 7 students did not have matching status change
for Campus and Program enrollment, 2 students did not have campus enrollment updated for withdrawal
status change, 2 students with the incorrect effective date on program enrollment and 1 student where
graduate status was not properly updated. Additionally, there is no evidence of review documented.
Questioned costs: N/A
Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched
the institutions records in a timely manner.
Effect: The University was not in compliance with the requirements to properly report student enrollment
data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the
repayment and interest of outstanding Title IV student loans.
Repeat finding: Yes, 2022-012
Recommendation: We recommend the University review current processes for reporting to NSLDS and
implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly report student enrollment changes for students who received
federal student aid to the National Student Loan Data System (NSLDS).
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Additionally, 34 CFR 682.610, states that
institutions must report accurately the enrollment status of all students regardless of if they receive aid from
the institution or not. Changes to said status are required to be reported within 30 days of becoming aware
of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is
within 60 days.
Context: During our testing of 60 students, we identified 5 students had the incorrect effective date, 44
students were reported past the 60-day reporting timeframe, 7 students did not have matching status change
for Campus and Program enrollment, 2 students did not have campus enrollment updated for withdrawal
status change, 2 students with the incorrect effective date on program enrollment and 1 student where
graduate status was not properly updated. Additionally, there is no evidence of review documented.
Questioned costs: N/A
Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched
the institutions records in a timely manner.
Effect: The University was not in compliance with the requirements to properly report student enrollment
data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the
repayment and interest of outstanding Title IV student loans.
Repeat finding: Yes, 2022-012
Recommendation: We recommend the University review current processes for reporting to NSLDS and
implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly report student enrollment changes for students who received
federal student aid to the National Student Loan Data System (NSLDS).
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Additionally, 34 CFR 682.610, states that
institutions must report accurately the enrollment status of all students regardless of if they receive aid from
the institution or not. Changes to said status are required to be reported within 30 days of becoming aware
of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is
within 60 days.
Context: During our testing of 60 students, we identified 5 students had the incorrect effective date, 44
students were reported past the 60-day reporting timeframe, 7 students did not have matching status change
for Campus and Program enrollment, 2 students did not have campus enrollment updated for withdrawal
status change, 2 students with the incorrect effective date on program enrollment and 1 student where
graduate status was not properly updated. Additionally, there is no evidence of review documented.
Questioned costs: N/A
Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched
the institutions records in a timely manner.
Effect: The University was not in compliance with the requirements to properly report student enrollment
data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the
repayment and interest of outstanding Title IV student loans.
Repeat finding: Yes, 2022-012
Recommendation: We recommend the University review current processes for reporting to NSLDS and
implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University did not properly report student enrollment changes for students who received
federal student aid to the National Student Loan Data System (NSLDS).
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are
required to establish and maintain internal controls designed to reasonably ensure compliance with federal
laws, regulations, and program compliance requirements. Additionally, 34 CFR 682.610, states that
institutions must report accurately the enrollment status of all students regardless of if they receive aid from
the institution or not. Changes to said status are required to be reported within 30 days of becoming aware
of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is
within 60 days.
Context: During our testing of 60 students, we identified 5 students had the incorrect effective date, 44
students were reported past the 60-day reporting timeframe, 7 students did not have matching status change
for Campus and Program enrollment, 2 students did not have campus enrollment updated for withdrawal
status change, 2 students with the incorrect effective date on program enrollment and 1 student where
graduate status was not properly updated. Additionally, there is no evidence of review documented.
Questioned costs: N/A
Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched
the institutions records in a timely manner.
Effect: The University was not in compliance with the requirements to properly report student enrollment
data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the
repayment and interest of outstanding Title IV student loans.
Repeat finding: Yes, 2022-012
Recommendation: We recommend the University review current processes for reporting to NSLDS and
implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not properly have documentation of exit counseling notification.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school
must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or
professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive
electronic means. In each case, the school must ensure that this counseling is conducted shortly before the
student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities
receiving federal awards are required to establish and maintain internal controls designed to reasonably
ensure compliance with federal laws, regulations, and program compliance requirements.
Context: During our testing of 40 students, we identified 3 students that did not have documentation of exit
counseling notification.
Questioned costs: N/A
Cause: The University did not have proper procedures in place to ensure that notification of required exit
counseling was sent to applicable students.
Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and
reviews deferment and repayment plans options. If students are not notified of exit counseling, they could
be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat finding: No
Recommendation: We recommend the University review reporting processes to ensure all students that
require exit counseling receive it in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not properly have documentation of exit counseling notification.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school
must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or
professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive
electronic means. In each case, the school must ensure that this counseling is conducted shortly before the
student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities
receiving federal awards are required to establish and maintain internal controls designed to reasonably
ensure compliance with federal laws, regulations, and program compliance requirements.
Context: During our testing of 40 students, we identified 3 students that did not have documentation of exit
counseling notification.
Questioned costs: N/A
Cause: The University did not have proper procedures in place to ensure that notification of required exit
counseling was sent to applicable students.
Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and
reviews deferment and repayment plans options. If students are not notified of exit counseling, they could
be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat finding: No
Recommendation: We recommend the University review reporting processes to ensure all students that
require exit counseling receive it in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not properly have documentation of exit counseling notification.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school
must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or
professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive
electronic means. In each case, the school must ensure that this counseling is conducted shortly before the
student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities
receiving federal awards are required to establish and maintain internal controls designed to reasonably
ensure compliance with federal laws, regulations, and program compliance requirements.
Context: During our testing of 40 students, we identified 3 students that did not have documentation of exit
counseling notification.
Questioned costs: N/A
Cause: The University did not have proper procedures in place to ensure that notification of required exit
counseling was sent to applicable students.
Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and
reviews deferment and repayment plans options. If students are not notified of exit counseling, they could
be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat finding: No
Recommendation: We recommend the University review reporting processes to ensure all students that
require exit counseling receive it in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not properly have documentation of exit counseling notification.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school
must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or
professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive
electronic means. In each case, the school must ensure that this counseling is conducted shortly before the
student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities
receiving federal awards are required to establish and maintain internal controls designed to reasonably
ensure compliance with federal laws, regulations, and program compliance requirements.
Context: During our testing of 40 students, we identified 3 students that did not have documentation of exit
counseling notification.
Questioned costs: N/A
Cause: The University did not have proper procedures in place to ensure that notification of required exit
counseling was sent to applicable students.
Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and
reviews deferment and repayment plans options. If students are not notified of exit counseling, they could
be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat finding: No
Recommendation: We recommend the University review reporting processes to ensure all students that
require exit counseling receive it in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not properly have documentation of exit counseling notification.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school
must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or
professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive
electronic means. In each case, the school must ensure that this counseling is conducted shortly before the
student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities
receiving federal awards are required to establish and maintain internal controls designed to reasonably
ensure compliance with federal laws, regulations, and program compliance requirements.
Context: During our testing of 40 students, we identified 3 students that did not have documentation of exit
counseling notification.
Questioned costs: N/A
Cause: The University did not have proper procedures in place to ensure that notification of required exit
counseling was sent to applicable students.
Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and
reviews deferment and repayment plans options. If students are not notified of exit counseling, they could
be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat finding: No
Recommendation: We recommend the University review reporting processes to ensure all students that
require exit counseling receive it in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not properly have documentation of exit counseling notification.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school
must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or
professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive
electronic means. In each case, the school must ensure that this counseling is conducted shortly before the
student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities
receiving federal awards are required to establish and maintain internal controls designed to reasonably
ensure compliance with federal laws, regulations, and program compliance requirements.
Context: During our testing of 40 students, we identified 3 students that did not have documentation of exit
counseling notification.
Questioned costs: N/A
Cause: The University did not have proper procedures in place to ensure that notification of required exit
counseling was sent to applicable students.
Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and
reviews deferment and repayment plans options. If students are not notified of exit counseling, they could
be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat finding: No
Recommendation: We recommend the University review reporting processes to ensure all students that
require exit counseling receive it in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not properly have documentation of exit counseling notification.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school
must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or
professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive
electronic means. In each case, the school must ensure that this counseling is conducted shortly before the
student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities
receiving federal awards are required to establish and maintain internal controls designed to reasonably
ensure compliance with federal laws, regulations, and program compliance requirements.
Context: During our testing of 40 students, we identified 3 students that did not have documentation of exit
counseling notification.
Questioned costs: N/A
Cause: The University did not have proper procedures in place to ensure that notification of required exit
counseling was sent to applicable students.
Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and
reviews deferment and repayment plans options. If students are not notified of exit counseling, they could
be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat finding: No
Recommendation: We recommend the University review reporting processes to ensure all students that
require exit counseling receive it in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023,
and P268K220352-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not properly have documentation of exit counseling notification.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school
must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or
professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive
electronic means. In each case, the school must ensure that this counseling is conducted shortly before the
student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities
receiving federal awards are required to establish and maintain internal controls designed to reasonably
ensure compliance with federal laws, regulations, and program compliance requirements.
Context: During our testing of 40 students, we identified 3 students that did not have documentation of exit
counseling notification.
Questioned costs: N/A
Cause: The University did not have proper procedures in place to ensure that notification of required exit
counseling was sent to applicable students.
Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and
reviews deferment and repayment plans options. If students are not notified of exit counseling, they could
be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat finding: No
Recommendation: We recommend the University review reporting processes to ensure all students that
require exit counseling receive it in a timely manner.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.
Federal Agency: Department of Education, Department of Agriculture, and Department of Defense
Federal Program Title: Education Stabilization Fund & Research and Development Cluster
Assistance Listing Number: 84.425F, 10.205, and 12.630
Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023,
NI201445XXXXG009-2023, W911NF-22
Award Period: 7/1/22-6/30/23
Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material
Noncompliance
Condition: The University does not review the work or internal control reports of their third-party servicer
who performs suspension and debarment checks against the federal exclusion list.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving
federal awards are required to establish and maintain internal controls designed to reasonably ensure
compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 180.300
nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to
do business with are not excluded or disqualified.
Context: The University uses a third party to perform their suspension and debarment checks for covered
transactions. The University does not review internal control reports, such as SOC1 reports, or perform
other documented reviews of the third-party servicer's work.
Questioned costs: N/A
Cause: The University did not have a control in place to review the controls and accuracy of the third-party
servicer's work.
Effect: The third-party servicer could experience control deficiencies which may impact compliance and the
University would be unaware and unable to make timely reviews of the work provided by the servicer.
Repeat finding: Yes, 2022-019
Recommendation: We recommend the University review internal control reports and implement review
controls for work performed by third party servicers.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct
the finding.