Criteria: Awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of thestudent?s financial need (34 CFR ? 668.42 FWS and 34 CFR ? 682.301). Per 34 CFR ? 685.200, a Direct Subsidized Loan borrower must demonstrate financial need in accordance with Title IV, Part F of the Higher Education Act of 1965. Upon packaging a student's aid, schools are required to calculate the student's need based on the expected family contribution, estimated financial assistance, and estimated cost of attendance.Condition/context: A sample of 40 students out of a population of 735 students who received disbursements of student financial assistance federal awards was selected. The financial need was calculated for each student, with the student?s estimated financial assistance also deducted. One student was identified as being overawarded by $134.Our sample was not, and was not intended to be, statistically valid.Questioned costs: Less than the questioned cost threshold of $25,000.Cause/Effect: This occurred because of a lack of proper understanding of estimated financial assistance as defined by the Federal regulations. Because of the lack of understanding, the system controls in place, while operating as designed, were established using the same lack of understanding. One student was overawarded by $134.Repeat finding: NoRecommendation: We recommend the University further educate and train those involved in the Financial Aid department regarding the Eligibility rules surrounding Federal awards, specifically regardingtypes of and scenarios using estimated financial assistance. We also recommend the University revise the inputs within the PowerFAIDS system so that the control established to prevent (and subsequently detect) overawards is appropriately considering all scholarships and institutional grants as estimated financial assistance, regardless of need-based or not. Lastly, as a monitoring control, we recommend an overaward report showing both Federal and non-Federal overawards be developed and be run and reviewed at a set frequency by the Director. Views of responsible officials and planned corrective actions: Heritage University is to give individuals working in the financial aid office more information and training about the eligibility requirements for federal awards, particularly with regard to the several forms and potential uses of anticipated financial aid. Additionally, the University is to update the PowerFAIDS system's inputs so that all institutional grants and scholarships, regardless of whether they are need-based or not, are adequately taken into account by the control mechanism created to avoid (and consequently detect) overawards. As a monitoring measure, the Director of Financial Aid will create an overaward report that lists both Federal and non-Federal overawards and runs it on a regular basis.
Criteria: The National Student Loan Data System (NSLDS) is the Department of Education?s (ED) centralized database for students? enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs. Uniform guidance requires institutions to have internal controls in place to ensure attendance changes for students are reported to NSLDS within at least 60 days of when the student attendance change occurs. It is the University?s responsibility to update students' enrollment information timely and accurately as outlined in 34 CFR ? 685.309. Institutions are responsible for accurately reporting certain significant data elements under the Campus- Level Record and Program-Level Record that ED considers high risk, which includes the student's program as per the Classification of Instructional Programs (CIP) code, and the student's status change Effective Date.Condition/context: We selected a sample of 28 students out of a population of 266 who had received Federal aid and had withdrawn or graduated from the University during the 2021-2022 fiscal year. We compared the significant data elements under the Campus-Level and Program-Level Records that ED considers high risk as reported to NSLDS to the data included in the student's academic records, other institutional records, and the withdrawal or graduation date per the University?s records. We noted exceptions with nine out of the 28 students tested. For two students their status change was not properly reported at the campus-level record. One student?s campus-level and program-level record was not correct. Six students were not reported to NSLDS within the 60-day requirement.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: This occurred because of lack of controls and oversight of the process. This resulted in late and inaccurate reporting of the information to NSLDS. The enrollment information reported to NSLDS is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status.Repeat finding: NoRecommendation: We recommend the University follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. We also recommend the University establish a formal internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot checks the status updates on NSLDS so to internally audit the National Student Clearinghouse submissions.Views of responsible officials and planned corrective actions: Heritage University will adhere to and improve the current standards to guarantee that all student status changes are promptly identified and submitted accurately within the appropriate time period. In order to internally audit the National Student Clearinghouse submissions, the University will set up a formal internal monitoring system whereby a designated person with access to NSLDS periodically monitors the status updates on NSLDS.
Criteria: Awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of thestudent?s financial need (34 CFR ? 668.42 FWS and 34 CFR ? 682.301). Per 34 CFR ? 685.200, a Direct Subsidized Loan borrower must demonstrate financial need in accordance with Title IV, Part F of the Higher Education Act of 1965. Upon packaging a student's aid, schools are required to calculate the student's need based on the expected family contribution, estimated financial assistance, and estimated cost of attendance.Condition/context: A sample of 40 students out of a population of 735 students who received disbursements of student financial assistance federal awards was selected. The financial need was calculated for each student, with the student?s estimated financial assistance also deducted. One student was identified as being overawarded by $134.Our sample was not, and was not intended to be, statistically valid.Questioned costs: Less than the questioned cost threshold of $25,000.Cause/Effect: This occurred because of a lack of proper understanding of estimated financial assistance as defined by the Federal regulations. Because of the lack of understanding, the system controls in place, while operating as designed, were established using the same lack of understanding. One student was overawarded by $134.Repeat finding: NoRecommendation: We recommend the University further educate and train those involved in the Financial Aid department regarding the Eligibility rules surrounding Federal awards, specifically regardingtypes of and scenarios using estimated financial assistance. We also recommend the University revise the inputs within the PowerFAIDS system so that the control established to prevent (and subsequently detect) overawards is appropriately considering all scholarships and institutional grants as estimated financial assistance, regardless of need-based or not. Lastly, as a monitoring control, we recommend an overaward report showing both Federal and non-Federal overawards be developed and be run and reviewed at a set frequency by the Director. Views of responsible officials and planned corrective actions: Heritage University is to give individuals working in the financial aid office more information and training about the eligibility requirements for federal awards, particularly with regard to the several forms and potential uses of anticipated financial aid. Additionally, the University is to update the PowerFAIDS system's inputs so that all institutional grants and scholarships, regardless of whether they are need-based or not, are adequately taken into account by the control mechanism created to avoid (and consequently detect) overawards. As a monitoring measure, the Director of Financial Aid will create an overaward report that lists both Federal and non-Federal overawards and runs it on a regular basis.
Criteria: The National Student Loan Data System (NSLDS) is the Department of Education?s (ED) centralized database for students? enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs. Uniform guidance requires institutions to have internal controls in place to ensure attendance changes for students are reported to NSLDS within at least 60 days of when the student attendance change occurs. It is the University?s responsibility to update students' enrollment information timely and accurately as outlined in 34 CFR ? 685.309. Institutions are responsible for accurately reporting certain significant data elements under the Campus- Level Record and Program-Level Record that ED considers high risk, which includes the student's program as per the Classification of Instructional Programs (CIP) code, and the student's status change Effective Date.Condition/context: We selected a sample of 28 students out of a population of 266 who had received Federal aid and had withdrawn or graduated from the University during the 2021-2022 fiscal year. We compared the significant data elements under the Campus-Level and Program-Level Records that ED considers high risk as reported to NSLDS to the data included in the student's academic records, other institutional records, and the withdrawal or graduation date per the University?s records. We noted exceptions with nine out of the 28 students tested. For two students their status change was not properly reported at the campus-level record. One student?s campus-level and program-level record was not correct. Six students were not reported to NSLDS within the 60-day requirement.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: This occurred because of lack of controls and oversight of the process. This resulted in late and inaccurate reporting of the information to NSLDS. The enrollment information reported to NSLDS is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status.Repeat finding: NoRecommendation: We recommend the University follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. We also recommend the University establish a formal internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot checks the status updates on NSLDS so to internally audit the National Student Clearinghouse submissions.Views of responsible officials and planned corrective actions: Heritage University will adhere to and improve the current standards to guarantee that all student status changes are promptly identified and submitted accurately within the appropriate time period. In order to internally audit the National Student Clearinghouse submissions, the University will set up a formal internal monitoring system whereby a designated person with access to NSLDS periodically monitors the status updates on NSLDS.
Criteria: Awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of thestudent?s financial need (34 CFR ? 668.42 FWS and 34 CFR ? 682.301). Per 34 CFR ? 685.200, a Direct Subsidized Loan borrower must demonstrate financial need in accordance with Title IV, Part F of the Higher Education Act of 1965. Upon packaging a student's aid, schools are required to calculate the student's need based on the expected family contribution, estimated financial assistance, and estimated cost of attendance.Condition/context: A sample of 40 students out of a population of 735 students who received disbursements of student financial assistance federal awards was selected. The financial need was calculated for each student, with the student?s estimated financial assistance also deducted. One student was identified as being overawarded by $134.Our sample was not, and was not intended to be, statistically valid.Questioned costs: Less than the questioned cost threshold of $25,000.Cause/Effect: This occurred because of a lack of proper understanding of estimated financial assistance as defined by the Federal regulations. Because of the lack of understanding, the system controls in place, while operating as designed, were established using the same lack of understanding. One student was overawarded by $134.Repeat finding: NoRecommendation: We recommend the University further educate and train those involved in the Financial Aid department regarding the Eligibility rules surrounding Federal awards, specifically regardingtypes of and scenarios using estimated financial assistance. We also recommend the University revise the inputs within the PowerFAIDS system so that the control established to prevent (and subsequently detect) overawards is appropriately considering all scholarships and institutional grants as estimated financial assistance, regardless of need-based or not. Lastly, as a monitoring control, we recommend an overaward report showing both Federal and non-Federal overawards be developed and be run and reviewed at a set frequency by the Director. Views of responsible officials and planned corrective actions: Heritage University is to give individuals working in the financial aid office more information and training about the eligibility requirements for federal awards, particularly with regard to the several forms and potential uses of anticipated financial aid. Additionally, the University is to update the PowerFAIDS system's inputs so that all institutional grants and scholarships, regardless of whether they are need-based or not, are adequately taken into account by the control mechanism created to avoid (and consequently detect) overawards. As a monitoring measure, the Director of Financial Aid will create an overaward report that lists both Federal and non-Federal overawards and runs it on a regular basis.
Criteria: Compensation costs are allowable to the extent they satisfy requirements of Title 2 Code of Federal Regulations (CFR) section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awardsfor salaries and wages be based on records that accurately reflect the work performed.Condition/Context: A sample of 9 employees out of a population of 26 employees whose compensation was charged to the awards was selected. For each of the 9 employees selected there were no records to support the actual allocation of time that was charged to each award. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. We noted time was allocated to the award in accordance with the personnel action form that is completed upon hire for all 9 employees. Two of the employees selected had no documentation to support that their time should have been charged to the award.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None notedCause/Effect: The University does not have the proper controls in place to ensure time and effort reporting is completed. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award.Repeat finding: Yes Recommendation: We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time.Views of responsible officials and planned corrective actions: Heritage University agrees with the finding. Heritage University implemented a new internal control policy that requires employees whosecompensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each time an employee must fill out the time and effort to show actual hours worked, signed by the employee and supervisor before turning it into the payroll department. Email sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.
Criteria: Non-federal entities, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicablestate and local laws and regulations, provided the policies and procedures conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.Condition/context: A sample of 2 expenditures greater than the micropurchase threshold of $10,000 but less than the simplified acquisition threshold of $250,000 were selected from the three transactions that exceeded the micropurchase threshold of $10,000. For one of the expenditures the University did not obtain the required rate quotations; per the University?s documented policy two quotes should have been obtained. In addition, we noted the University does not have a documented standard of conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: The personnel completing purchases on behalf of the University were unaware of the internal procurement policies that are in conformance with federal statutes and 2 CFR Part 200. The lack of obtaining the required rate quotations increases the risk that the price paid was not competitive when compared to the market and that the transaction may not have been in a manner providing full and opencompetition. The lack of a documented standard of conduct that covers conflict of interest increases the risk that an actual or perceived conflict could occur.Repeat finding: NoRecommendation: We recommend the University implement controls to ensure all employees making federal purchases on behalf of the University are aware of the University?s documented procurement policy that is in accordance with 2 CFR Part 200. In addition, we recommend the University document its standard of conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts.Views of responsible officials and planned corrective actions: Heritage University agrees to put procedures in place to make certain that every employee making federal purchases on the University's behalf is aware of the University's written procurement policy, which complies with 2 CFR Part 200. Additionally, the University is to formalize its code of conduct, which addresses conflicts of interest and establishes expectations for staff members involved in contract administration, selection, and award.
Criteria: Under 2 CFR section 200.329 non-Federal entities are required to submit performance reports at the interval required by the Federal awarding agency. Reports submitted annually by the non-Federalentity are due no later than 90 calendar days after the reporting period. The reports must be supported to ensure the accuracy and completeness of the reports.Condition/context: The University was unable to provide documentation from the awarding agency indicating when reports were required to be submitted. The University submitted two performance reports covering the period under audit as such both were selected for testing. The two reports were not filed within 90 calendar days after the reporting period. In addition, we were not able to test the underlying datato ensure the data in the reports were complete and accurate.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: The University does not have a centralized process for tracking report due dates nor do they maintain the documentation for the data in the reports. The lack of support for required due dates, and data reported results in a material noncompliance with the reporting compliance requirement.Repeat finding: NoRecommendation: We recommend the University create an internal control to obtain reporting requirements for each award received by the University. We recommend a standard process be implemented for each award to track the due dates to ensure they are completed timely. Lastly, we recommend the data in the reports be supported to ensure the data is complete and accurate.Views of responsible officials and planned corrective actions: Heritage University agrees to ensure that it meets the reporting requirements for each award it receives, and the university will establish internal controls. For each award, Heritage University will place a regular procedure to keep track of the deadlines and make sure everything is finished on time. Finally, to guarantee the data is complete and reliable, Heritage University will add support to the reports' data.
Criteria: Compensation costs are allowable to the extent they satisfy requirements of Title 2 Code of Federal Regulations (CFR) section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awardsfor salaries and wages be based on records that accurately reflect the work performed.Condition/Context: A sample of 9 employees out of a population of 26 employees whose compensation was charged to the awards was selected. For each of the 9 employees selected there were no records to support the actual allocation of time that was charged to each award. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. We noted time was allocated to the award in accordance with the personnel action form that is completed upon hire for all 9 employees. Two of the employees selected had no documentation to support that their time should have been charged to the award.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None notedCause/Effect: The University does not have the proper controls in place to ensure time and effort reporting is completed. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award.Repeat finding: Yes Recommendation: We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time.Views of responsible officials and planned corrective actions: Heritage University agrees with the finding. Heritage University implemented a new internal control policy that requires employees whosecompensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each time an employee must fill out the time and effort to show actual hours worked, signed by the employee and supervisor before turning it into the payroll department. Email sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.
Criteria: Compensation costs are allowable to the extent they satisfy requirements of Title 2 Code of Federal Regulations (CFR) section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awardsfor salaries and wages be based on records that accurately reflect the work performed.Condition/Context: A sample of 9 employees out of a population of 26 employees whose compensation was charged to the awards was selected. For each of the 9 employees selected there were no records to support the actual allocation of time that was charged to each award. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. We noted time was allocated to the award in accordance with the personnel action form that is completed upon hire for all 9 employees. Two of the employees selected had no documentation to support that their time should have been charged to the award.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None notedCause/Effect: The University does not have the proper controls in place to ensure time and effort reporting is completed. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award.Repeat finding: Yes Recommendation: We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time.Views of responsible officials and planned corrective actions: Heritage University agrees with the finding. Heritage University implemented a new internal control policy that requires employees whosecompensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each time an employee must fill out the time and effort to show actual hours worked, signed by the employee and supervisor before turning it into the payroll department. Email sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.
Criteria: In accordance with 2 CFR 200.332 (b) pass-thru entities must evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring and (d) pass-thru entities must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring must include: reviewing financial and performance reports, following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award, issuing a management decision for applicable audit findings pertaining to the Federal award provided to the subrecipient and resolving audit findings specifically related to the subaward. Condition/context: We selected the one subrecipient that the University passed federal funding to during the year ended June 30, 2022. We requested support that the University performed a risk assessment and was monitoring the subrecipient, noting the University did not perform a risk assessment and was not monitoring the subrecipient in accordance with 2 CFR 200.332 (b) or (d).Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: The University does not have a clear understanding of the compliance requirements for subrecipient monitoring. The lack of subrecipient monitoring increases the risk that the subrecipient is not using the subaward for authorized purposes, in compliance with Federal statutes, regulations, or the terms and conditions of the subaward.Repeat finding: YesRecommendation: We recommend the University implement internal controls to assess the risk of the subrecipient and properly monitor any subrecipients of the University, such as reviewing single audits, financial and performance reports, or other necessary documentation of the subrecipient entity to help ensure the subrecipient is in compliance.Views of responsible officials and planned corrective actions: In agreement with the auditor?s recommendation of internal controls to properly monitor any subrecipients of the University, such as reviewing financial and performance reports of the subreceipient entity including any single audit reports. Heritage University has finalized the new ?Grant Management Policy & Procedures? manual. The grant management manual section on subrecipient is explicit about the University?s policies and procedures to ensure documentation is maintained.
Criteria: Non-federal entities, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicablestate and local laws and regulations, provided the policies and procedures conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.Condition/context: A sample of 2 expenditures greater than the micropurchase threshold of $10,000 but less than the simplified acquisition threshold of $250,000 were selected from the three transactions that exceeded the micropurchase threshold of $10,000. For one of the expenditures the University did not obtain the required rate quotations; per the University?s documented policy two quotes should have been obtained. In addition, we noted the University does not have a documented standard of conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: The personnel completing purchases on behalf of the University were unaware of the internal procurement policies that are in conformance with federal statutes and 2 CFR Part 200. The lack of obtaining the required rate quotations increases the risk that the price paid was not competitive when compared to the market and that the transaction may not have been in a manner providing full and opencompetition. The lack of a documented standard of conduct that covers conflict of interest increases the risk that an actual or perceived conflict could occur.Repeat finding: NoRecommendation: We recommend the University implement controls to ensure all employees making federal purchases on behalf of the University are aware of the University?s documented procurement policy that is in accordance with 2 CFR Part 200. In addition, we recommend the University document its standard of conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts.Views of responsible officials and planned corrective actions: Heritage University agrees to put procedures in place to make certain that every employee making federal purchases on the University's behalf is aware of the University's written procurement policy, which complies with 2 CFR Part 200. Additionally, the University is to formalize its code of conduct, which addresses conflicts of interest and establishes expectations for staff members involved in contract administration, selection, and award.
Criteria: Non-federal entities, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicablestate and local laws and regulations, provided the policies and procedures conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.Condition/context: A sample of 2 expenditures greater than the micropurchase threshold of $10,000 but less than the simplified acquisition threshold of $250,000 were selected from the three transactions that exceeded the micropurchase threshold of $10,000. For one of the expenditures the University did not obtain the required rate quotations; per the University?s documented policy two quotes should have been obtained. In addition, we noted the University does not have a documented standard of conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: The personnel completing purchases on behalf of the University were unaware of the internal procurement policies that are in conformance with federal statutes and 2 CFR Part 200. The lack of obtaining the required rate quotations increases the risk that the price paid was not competitive when compared to the market and that the transaction may not have been in a manner providing full and opencompetition. The lack of a documented standard of conduct that covers conflict of interest increases the risk that an actual or perceived conflict could occur.Repeat finding: NoRecommendation: We recommend the University implement controls to ensure all employees making federal purchases on behalf of the University are aware of the University?s documented procurement policy that is in accordance with 2 CFR Part 200. In addition, we recommend the University document its standard of conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts.Views of responsible officials and planned corrective actions: Heritage University agrees to put procedures in place to make certain that every employee making federal purchases on the University's behalf is aware of the University's written procurement policy, which complies with 2 CFR Part 200. Additionally, the University is to formalize its code of conduct, which addresses conflicts of interest and establishes expectations for staff members involved in contract administration, selection, and award.
Criteria: Under 2 CFR section 200.329 non-Federal entities are required to submit performance reports at the interval required by the Federal awarding agency. Reports submitted annually by the non-Federalentity are due no later than 90 calendar days after the reporting period. The reports must be supported to ensure the accuracy and completeness of the reports.Condition/context: The University was unable to provide documentation from the awarding agency indicating when reports were required to be submitted. The University submitted two performance reports covering the period under audit as such both were selected for testing. The two reports were not filed within 90 calendar days after the reporting period. In addition, we were not able to test the underlying datato ensure the data in the reports were complete and accurate.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: The University does not have a centralized process for tracking report due dates nor do they maintain the documentation for the data in the reports. The lack of support for required due dates, and data reported results in a material noncompliance with the reporting compliance requirement.Repeat finding: NoRecommendation: We recommend the University create an internal control to obtain reporting requirements for each award received by the University. We recommend a standard process be implemented for each award to track the due dates to ensure they are completed timely. Lastly, we recommend the data in the reports be supported to ensure the data is complete and accurate.Views of responsible officials and planned corrective actions: Heritage University agrees to ensure that it meets the reporting requirements for each award it receives, and the university will establish internal controls. For each award, Heritage University will place a regular procedure to keep track of the deadlines and make sure everything is finished on time. Finally, to guarantee the data is complete and reliable, Heritage University will add support to the reports' data.
Criteria: Under 2 CFR section 200.329 non-Federal entities are required to submit performance reports at the interval required by the Federal awarding agency. Reports submitted annually by the non-Federalentity are due no later than 90 calendar days after the reporting period. The reports must be supported to ensure the accuracy and completeness of the reports.Condition/context: The University was unable to provide documentation from the awarding agency indicating when reports were required to be submitted. The University submitted two performance reports covering the period under audit as such both were selected for testing. The two reports were not filed within 90 calendar days after the reporting period. In addition, we were not able to test the underlying datato ensure the data in the reports were complete and accurate.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: The University does not have a centralized process for tracking report due dates nor do they maintain the documentation for the data in the reports. The lack of support for required due dates, and data reported results in a material noncompliance with the reporting compliance requirement.Repeat finding: NoRecommendation: We recommend the University create an internal control to obtain reporting requirements for each award received by the University. We recommend a standard process be implemented for each award to track the due dates to ensure they are completed timely. Lastly, we recommend the data in the reports be supported to ensure the data is complete and accurate.Views of responsible officials and planned corrective actions: Heritage University agrees to ensure that it meets the reporting requirements for each award it receives, and the university will establish internal controls. For each award, Heritage University will place a regular procedure to keep track of the deadlines and make sure everything is finished on time. Finally, to guarantee the data is complete and reliable, Heritage University will add support to the reports' data.
Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act, recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System. The intent is to empower every American with the ability to hold the government accountable for each spending decision. The end result is to reduce wasteful spending in the government.Condition/context: We selected the University?s only subrecipient for testing and found the University did not report its first-tier subaward of $57,653 to the Federal Funding Accountability and Transparency Act Subaward Reporting System.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: Due to the turnover in the business office, the University did not know there was a requirement to report subrecipients to the Federal Funding Accountability and Transparency Act Subaward Reporting System. The required information is not included in the Federal Funding Accountability and Transparency Act Subaward Reporting System and as such limits the public?s ability to search for this federal award via the single, searchable website.Repeat finding: NoRecommendation: We recommend the University create an internal control to ensure all first-tier subawards of $30,000 or more are properly reported to the Federal Funding Accountability andTransparency Act Subaward Reporting System.Views of responsible officials and planned corrective actions: Heritage University will ensure that all first-tier subawards of $30,000 or more are appropriately reported to the Federal Funding Accountability and Transparency Act Subaward Reporting System, with establishing internal control.
Criteria: In accordance with the Funding Certification and Agreement for the Emergency Financial Aid Grants to Students institutions must have a documented plan to distribute funds to students. Condition/context: A sample of 25 disbursements to students out of a population of 995 disbursements to students was selected. A documented plan for distribution of funds to students was requested, however the University did not have a documented plan.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: The University did not have the controls in place to formerly approve a plan for distributions of funds that was documented and circulated to the University. The lack of a documented plan for distribution of funds to students increases the risk that funds were inappropriately disbursed to students at the wrong amounts. In addition, it increases the risk that the disbursements were not equitable across the student population.Repeat finding: YesRecommendation: We recommend the University adopt a policy that is formally approved and retained indicating how HEERF student aid portion funds are to be distributed to students.Views of responsible officials and planned corrective actions: Heritage University has implemented a new policy to formally have documentation of requesting, approving, and disbursing of the HEERF student aid portion.
Criteria: Under the Coronavirus Aid, Relief, and Economic Security Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act 314(e) institutions that received funds underHEERF I and HEERF II are required to submit a report to the secretary on how the school used its HEERF funds. While the American Rescue Plan did not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the U.S. Department of Education exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329.Condition/context: A sample of 8 special reports from the population of 8 special reports was selected. For each report, the University was unable to provide support for submission or publication dates. In addition, the University could not provide consistent institutional records for the data included in the reports nor could they provide support that the reports were reviewed prior to posting.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: Due to the turnover in the business office, the University was unable to locate support for the submission or publication dates, consistent institutional records for the data included in the reports or documented review of the reports prior to posting. The lack of support for submission or publication dates, data reported and documented review results in a material noncompliance with the reporting compliancerequirement.Repeat finding: YesRecommendation: We recommend the University update previously posted reports to accurately reflect the actual expenditures during the time period covered by the report. We recommend each report beposted to the University?s website on separate documents by quarter and should not be cumulative. We also recommend the University implement a process to ensure the submission dates and publication dates are maintained to ensure compliance with the reporting due dates and that the data submitted in the reports is properly supported by institutional records. Lastly, we recommend each report be properly reviewed by someone other than the preparer and that the review be documented with a signature anddate.Views of responsible officials and planned corrective actions: Heritage University will update the previously posted reports to accurately reflect the actual expenditures during FY20 & FY21 on the University?s website by quarter. Going further it will be the Grant accountant?s practice that the submission dates and publication dates are maintained and documented with reporting due dates. All documents will be reviewed and approved by the VP of Administration/CFO with dated signatures.
Criteria: Under the Coronavirus Aid, Relief, and Economic Security Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act 314(e) institutions that received funds underHEERF I and HEERF II are required to submit a report to the secretary on how the school used its HEERF funds. While the American Rescue Plan did not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the U.S. Department of Education exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329.Condition/context: A sample of 8 special reports from the population of 8 special reports was selected. For each report, the University was unable to provide support for submission or publication dates. In addition, the University could not provide consistent institutional records for the data included in the reports nor could they provide support that the reports were reviewed prior to posting.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: Due to the turnover in the business office, the University was unable to locate support for the submission or publication dates, consistent institutional records for the data included in the reports or documented review of the reports prior to posting. The lack of support for submission or publication dates, data reported and documented review results in a material noncompliance with the reporting compliancerequirement.Repeat finding: YesRecommendation: We recommend the University update previously posted reports to accurately reflect the actual expenditures during the time period covered by the report. We recommend each report beposted to the University?s website on separate documents by quarter and should not be cumulative. We also recommend the University implement a process to ensure the submission dates and publication dates are maintained to ensure compliance with the reporting due dates and that the data submitted in the reports is properly supported by institutional records. Lastly, we recommend each report be properly reviewed by someone other than the preparer and that the review be documented with a signature anddate.Views of responsible officials and planned corrective actions: Heritage University will update the previously posted reports to accurately reflect the actual expenditures during FY20 & FY21 on the University?s website by quarter. Going further it will be the Grant accountant?s practice that the submission dates and publication dates are maintained and documented with reporting due dates. All documents will be reviewed and approved by the VP of Administration/CFO with dated signatures.
Criteria: Compensation costs are allowable to the extent they satisfy requirements of Title 2 Code of Federal Regulations (CFR) section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awardsfor salaries and wages be based on records that accurately reflect the work performed.Condition/Context: A sample of 9 employees out of a population of 26 employees whose compensation was charged to the awards was selected. For each of the 9 employees selected there were no records to support the actual allocation of time that was charged to each award. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. We noted time was allocated to the award in accordance with the personnel action form that is completed upon hire for all 9 employees. Two of the employees selected had no documentation to support that their time should have been charged to the award.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None notedCause/Effect: The University does not have the proper controls in place to ensure time and effort reporting is completed. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award.Repeat finding: Yes Recommendation: We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time.Views of responsible officials and planned corrective actions: Heritage University agrees with the finding. Heritage University implemented a new internal control policy that requires employees whosecompensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each time an employee must fill out the time and effort to show actual hours worked, signed by the employee and supervisor before turning it into the payroll department. Email sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.
Criteria: Compensation costs are allowable to the extent they satisfy requirements of Title 2 Code of Federal Regulations (CFR) section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awardsfor salaries and wages be based on records that accurately reflect the work performed.Condition/Context: A sample of 9 employees out of a population of 26 employees whose compensation was charged to the awards was selected. For each of the 9 employees selected there were no records to support the actual allocation of time that was charged to each award. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. We noted time was allocated to the award in accordance with the personnel action form that is completed upon hire for all 9 employees. Two of the employees selected had no documentation to support that their time should have been charged to the award.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None notedCause/Effect: The University does not have the proper controls in place to ensure time and effort reporting is completed. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award.Repeat finding: Yes Recommendation: We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time.Views of responsible officials and planned corrective actions: Heritage University agrees with the finding. Heritage University implemented a new internal control policy that requires employees whosecompensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each time an employee must fill out the time and effort to show actual hours worked, signed by the employee and supervisor before turning it into the payroll department. Email sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.
Criteria: Compensation costs are allowable to the extent they satisfy requirements of Title 2 Code of Federal Regulations (CFR) section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awardsfor salaries and wages be based on records that accurately reflect the work performed.Condition/Context: A sample of 9 employees out of a population of 26 employees whose compensation was charged to the awards was selected. For each of the 9 employees selected there were no records to support the actual allocation of time that was charged to each award. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. We noted time was allocated to the award in accordance with the personnel action form that is completed upon hire for all 9 employees. Two of the employees selected had no documentation to support that their time should have been charged to the award.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None notedCause/Effect: The University does not have the proper controls in place to ensure time and effort reporting is completed. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award.Repeat finding: Yes Recommendation: We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time.Views of responsible officials and planned corrective actions: Heritage University agrees with the finding. Heritage University implemented a new internal control policy that requires employees whosecompensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each time an employee must fill out the time and effort to show actual hours worked, signed by the employee and supervisor before turning it into the payroll department. Email sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.
Criteria: Compensation costs are allowable to the extent they satisfy requirements of Title 2 Code of Federal Regulations (CFR) section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awardsfor salaries and wages be based on records that accurately reflect the work performed.Condition/Context: A sample of 9 employees out of a population of 26 employees whose compensation was charged to the awards was selected. For each of the 9 employees selected there were no records to support the actual allocation of time that was charged to each award. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. We noted time was allocated to the award in accordance with the personnel action form that is completed upon hire for all 9 employees. Two of the employees selected had no documentation to support that their time should have been charged to the award.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None notedCause/Effect: The University does not have the proper controls in place to ensure time and effort reporting is completed. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award.Repeat finding: Yes Recommendation: We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time.Views of responsible officials and planned corrective actions: Heritage University agrees with the finding. Heritage University implemented a new internal control policy that requires employees whosecompensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each time an employee must fill out the time and effort to show actual hours worked, signed by the employee and supervisor before turning it into the payroll department. Email sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.
Criteria: In accordance with 2 CFR 200.332 (b) pass-thru entities must evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring and (d) pass-thru entities must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring must include: reviewing financial and performance reports, following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award, issuing a management decision for applicable audit findings pertaining to the Federal award provided to the subrecipient and resolving audit findings specifically related to the subaward. Condition/context: We selected the one subrecipient that the University passed federal funding to during the year ended June 30, 2022. We requested support that the University performed a risk assessment and was monitoring the subrecipient, noting the University did not perform a risk assessment and was not monitoring the subrecipient in accordance with 2 CFR 200.332 (b) or (d).Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: The University does not have a clear understanding of the compliance requirements for subrecipient monitoring. The lack of subrecipient monitoring increases the risk that the subrecipient is not using the subaward for authorized purposes, in compliance with Federal statutes, regulations, or the terms and conditions of the subaward.Repeat finding: YesRecommendation: We recommend the University implement internal controls to assess the risk of the subrecipient and properly monitor any subrecipients of the University, such as reviewing single audits, financial and performance reports, or other necessary documentation of the subrecipient entity to help ensure the subrecipient is in compliance.Views of responsible officials and planned corrective actions: In agreement with the auditor?s recommendation of internal controls to properly monitor any subrecipients of the University, such as reviewing financial and performance reports of the subreceipient entity including any single audit reports. Heritage University has finalized the new ?Grant Management Policy & Procedures? manual. The grant management manual section on subrecipient is explicit about the University?s policies and procedures to ensure documentation is maintained.
Criteria: Compensation costs are allowable to the extent they satisfy requirements of Title 2 Code of Federal Regulations (CFR) section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awardsfor salaries and wages be based on records that accurately reflect the work performed.Condition/Context: A sample of 9 employees out of a population of 26 employees whose compensation was charged to the awards was selected. For each of the 9 employees selected there were no records to support the actual allocation of time that was charged to each award. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. We noted time was allocated to the award in accordance with the personnel action form that is completed upon hire for all 9 employees. Two of the employees selected had no documentation to support that their time should have been charged to the award.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None notedCause/Effect: The University does not have the proper controls in place to ensure time and effort reporting is completed. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award.Repeat finding: Yes Recommendation: We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time.Views of responsible officials and planned corrective actions: Heritage University agrees with the finding. Heritage University implemented a new internal control policy that requires employees whosecompensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each time an employee must fill out the time and effort to show actual hours worked, signed by the employee and supervisor before turning it into the payroll department. Email sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.
Criteria: Compensation costs are allowable to the extent they satisfy requirements of Title 2 Code of Federal Regulations (CFR) section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awardsfor salaries and wages be based on records that accurately reflect the work performed.Condition/Context: A sample of 9 employees out of a population of 26 employees whose compensation was charged to the awards was selected. For each of the 9 employees selected there were no records to support the actual allocation of time that was charged to each award. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. We noted time was allocated to the award in accordance with the personnel action form that is completed upon hire for all 9 employees. Two of the employees selected had no documentation to support that their time should have been charged to the award.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None notedCause/Effect: The University does not have the proper controls in place to ensure time and effort reporting is completed. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award.Repeat finding: Yes Recommendation: We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time.Views of responsible officials and planned corrective actions: Heritage University agrees with the finding. Heritage University implemented a new internal control policy that requires employees whosecompensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each time an employee must fill out the time and effort to show actual hours worked, signed by the employee and supervisor before turning it into the payroll department. Email sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.
Criteria: Awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of thestudent?s financial need (34 CFR ? 668.42 FWS and 34 CFR ? 682.301). Per 34 CFR ? 685.200, a Direct Subsidized Loan borrower must demonstrate financial need in accordance with Title IV, Part F of the Higher Education Act of 1965. Upon packaging a student's aid, schools are required to calculate the student's need based on the expected family contribution, estimated financial assistance, and estimated cost of attendance.Condition/context: A sample of 40 students out of a population of 735 students who received disbursements of student financial assistance federal awards was selected. The financial need was calculated for each student, with the student?s estimated financial assistance also deducted. One student was identified as being overawarded by $134.Our sample was not, and was not intended to be, statistically valid.Questioned costs: Less than the questioned cost threshold of $25,000.Cause/Effect: This occurred because of a lack of proper understanding of estimated financial assistance as defined by the Federal regulations. Because of the lack of understanding, the system controls in place, while operating as designed, were established using the same lack of understanding. One student was overawarded by $134.Repeat finding: NoRecommendation: We recommend the University further educate and train those involved in the Financial Aid department regarding the Eligibility rules surrounding Federal awards, specifically regardingtypes of and scenarios using estimated financial assistance. We also recommend the University revise the inputs within the PowerFAIDS system so that the control established to prevent (and subsequently detect) overawards is appropriately considering all scholarships and institutional grants as estimated financial assistance, regardless of need-based or not. Lastly, as a monitoring control, we recommend an overaward report showing both Federal and non-Federal overawards be developed and be run and reviewed at a set frequency by the Director. Views of responsible officials and planned corrective actions: Heritage University is to give individuals working in the financial aid office more information and training about the eligibility requirements for federal awards, particularly with regard to the several forms and potential uses of anticipated financial aid. Additionally, the University is to update the PowerFAIDS system's inputs so that all institutional grants and scholarships, regardless of whether they are need-based or not, are adequately taken into account by the control mechanism created to avoid (and consequently detect) overawards. As a monitoring measure, the Director of Financial Aid will create an overaward report that lists both Federal and non-Federal overawards and runs it on a regular basis.
Criteria: The National Student Loan Data System (NSLDS) is the Department of Education?s (ED) centralized database for students? enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs. Uniform guidance requires institutions to have internal controls in place to ensure attendance changes for students are reported to NSLDS within at least 60 days of when the student attendance change occurs. It is the University?s responsibility to update students' enrollment information timely and accurately as outlined in 34 CFR ? 685.309. Institutions are responsible for accurately reporting certain significant data elements under the Campus- Level Record and Program-Level Record that ED considers high risk, which includes the student's program as per the Classification of Instructional Programs (CIP) code, and the student's status change Effective Date.Condition/context: We selected a sample of 28 students out of a population of 266 who had received Federal aid and had withdrawn or graduated from the University during the 2021-2022 fiscal year. We compared the significant data elements under the Campus-Level and Program-Level Records that ED considers high risk as reported to NSLDS to the data included in the student's academic records, other institutional records, and the withdrawal or graduation date per the University?s records. We noted exceptions with nine out of the 28 students tested. For two students their status change was not properly reported at the campus-level record. One student?s campus-level and program-level record was not correct. Six students were not reported to NSLDS within the 60-day requirement.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: This occurred because of lack of controls and oversight of the process. This resulted in late and inaccurate reporting of the information to NSLDS. The enrollment information reported to NSLDS is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status.Repeat finding: NoRecommendation: We recommend the University follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. We also recommend the University establish a formal internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot checks the status updates on NSLDS so to internally audit the National Student Clearinghouse submissions.Views of responsible officials and planned corrective actions: Heritage University will adhere to and improve the current standards to guarantee that all student status changes are promptly identified and submitted accurately within the appropriate time period. In order to internally audit the National Student Clearinghouse submissions, the University will set up a formal internal monitoring system whereby a designated person with access to NSLDS periodically monitors the status updates on NSLDS.
Criteria: Awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of thestudent?s financial need (34 CFR ? 668.42 FWS and 34 CFR ? 682.301). Per 34 CFR ? 685.200, a Direct Subsidized Loan borrower must demonstrate financial need in accordance with Title IV, Part F of the Higher Education Act of 1965. Upon packaging a student's aid, schools are required to calculate the student's need based on the expected family contribution, estimated financial assistance, and estimated cost of attendance.Condition/context: A sample of 40 students out of a population of 735 students who received disbursements of student financial assistance federal awards was selected. The financial need was calculated for each student, with the student?s estimated financial assistance also deducted. One student was identified as being overawarded by $134.Our sample was not, and was not intended to be, statistically valid.Questioned costs: Less than the questioned cost threshold of $25,000.Cause/Effect: This occurred because of a lack of proper understanding of estimated financial assistance as defined by the Federal regulations. Because of the lack of understanding, the system controls in place, while operating as designed, were established using the same lack of understanding. One student was overawarded by $134.Repeat finding: NoRecommendation: We recommend the University further educate and train those involved in the Financial Aid department regarding the Eligibility rules surrounding Federal awards, specifically regardingtypes of and scenarios using estimated financial assistance. We also recommend the University revise the inputs within the PowerFAIDS system so that the control established to prevent (and subsequently detect) overawards is appropriately considering all scholarships and institutional grants as estimated financial assistance, regardless of need-based or not. Lastly, as a monitoring control, we recommend an overaward report showing both Federal and non-Federal overawards be developed and be run and reviewed at a set frequency by the Director. Views of responsible officials and planned corrective actions: Heritage University is to give individuals working in the financial aid office more information and training about the eligibility requirements for federal awards, particularly with regard to the several forms and potential uses of anticipated financial aid. Additionally, the University is to update the PowerFAIDS system's inputs so that all institutional grants and scholarships, regardless of whether they are need-based or not, are adequately taken into account by the control mechanism created to avoid (and consequently detect) overawards. As a monitoring measure, the Director of Financial Aid will create an overaward report that lists both Federal and non-Federal overawards and runs it on a regular basis.
Criteria: The National Student Loan Data System (NSLDS) is the Department of Education?s (ED) centralized database for students? enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs. Uniform guidance requires institutions to have internal controls in place to ensure attendance changes for students are reported to NSLDS within at least 60 days of when the student attendance change occurs. It is the University?s responsibility to update students' enrollment information timely and accurately as outlined in 34 CFR ? 685.309. Institutions are responsible for accurately reporting certain significant data elements under the Campus- Level Record and Program-Level Record that ED considers high risk, which includes the student's program as per the Classification of Instructional Programs (CIP) code, and the student's status change Effective Date.Condition/context: We selected a sample of 28 students out of a population of 266 who had received Federal aid and had withdrawn or graduated from the University during the 2021-2022 fiscal year. We compared the significant data elements under the Campus-Level and Program-Level Records that ED considers high risk as reported to NSLDS to the data included in the student's academic records, other institutional records, and the withdrawal or graduation date per the University?s records. We noted exceptions with nine out of the 28 students tested. For two students their status change was not properly reported at the campus-level record. One student?s campus-level and program-level record was not correct. Six students were not reported to NSLDS within the 60-day requirement.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: This occurred because of lack of controls and oversight of the process. This resulted in late and inaccurate reporting of the information to NSLDS. The enrollment information reported to NSLDS is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status.Repeat finding: NoRecommendation: We recommend the University follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. We also recommend the University establish a formal internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot checks the status updates on NSLDS so to internally audit the National Student Clearinghouse submissions.Views of responsible officials and planned corrective actions: Heritage University will adhere to and improve the current standards to guarantee that all student status changes are promptly identified and submitted accurately within the appropriate time period. In order to internally audit the National Student Clearinghouse submissions, the University will set up a formal internal monitoring system whereby a designated person with access to NSLDS periodically monitors the status updates on NSLDS.
Criteria: Awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of thestudent?s financial need (34 CFR ? 668.42 FWS and 34 CFR ? 682.301). Per 34 CFR ? 685.200, a Direct Subsidized Loan borrower must demonstrate financial need in accordance with Title IV, Part F of the Higher Education Act of 1965. Upon packaging a student's aid, schools are required to calculate the student's need based on the expected family contribution, estimated financial assistance, and estimated cost of attendance.Condition/context: A sample of 40 students out of a population of 735 students who received disbursements of student financial assistance federal awards was selected. The financial need was calculated for each student, with the student?s estimated financial assistance also deducted. One student was identified as being overawarded by $134.Our sample was not, and was not intended to be, statistically valid.Questioned costs: Less than the questioned cost threshold of $25,000.Cause/Effect: This occurred because of a lack of proper understanding of estimated financial assistance as defined by the Federal regulations. Because of the lack of understanding, the system controls in place, while operating as designed, were established using the same lack of understanding. One student was overawarded by $134.Repeat finding: NoRecommendation: We recommend the University further educate and train those involved in the Financial Aid department regarding the Eligibility rules surrounding Federal awards, specifically regardingtypes of and scenarios using estimated financial assistance. We also recommend the University revise the inputs within the PowerFAIDS system so that the control established to prevent (and subsequently detect) overawards is appropriately considering all scholarships and institutional grants as estimated financial assistance, regardless of need-based or not. Lastly, as a monitoring control, we recommend an overaward report showing both Federal and non-Federal overawards be developed and be run and reviewed at a set frequency by the Director. Views of responsible officials and planned corrective actions: Heritage University is to give individuals working in the financial aid office more information and training about the eligibility requirements for federal awards, particularly with regard to the several forms and potential uses of anticipated financial aid. Additionally, the University is to update the PowerFAIDS system's inputs so that all institutional grants and scholarships, regardless of whether they are need-based or not, are adequately taken into account by the control mechanism created to avoid (and consequently detect) overawards. As a monitoring measure, the Director of Financial Aid will create an overaward report that lists both Federal and non-Federal overawards and runs it on a regular basis.
Criteria: Compensation costs are allowable to the extent they satisfy requirements of Title 2 Code of Federal Regulations (CFR) section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awardsfor salaries and wages be based on records that accurately reflect the work performed.Condition/Context: A sample of 9 employees out of a population of 26 employees whose compensation was charged to the awards was selected. For each of the 9 employees selected there were no records to support the actual allocation of time that was charged to each award. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. We noted time was allocated to the award in accordance with the personnel action form that is completed upon hire for all 9 employees. Two of the employees selected had no documentation to support that their time should have been charged to the award.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None notedCause/Effect: The University does not have the proper controls in place to ensure time and effort reporting is completed. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award.Repeat finding: Yes Recommendation: We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time.Views of responsible officials and planned corrective actions: Heritage University agrees with the finding. Heritage University implemented a new internal control policy that requires employees whosecompensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each time an employee must fill out the time and effort to show actual hours worked, signed by the employee and supervisor before turning it into the payroll department. Email sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.
Criteria: Non-federal entities, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicablestate and local laws and regulations, provided the policies and procedures conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.Condition/context: A sample of 2 expenditures greater than the micropurchase threshold of $10,000 but less than the simplified acquisition threshold of $250,000 were selected from the three transactions that exceeded the micropurchase threshold of $10,000. For one of the expenditures the University did not obtain the required rate quotations; per the University?s documented policy two quotes should have been obtained. In addition, we noted the University does not have a documented standard of conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: The personnel completing purchases on behalf of the University were unaware of the internal procurement policies that are in conformance with federal statutes and 2 CFR Part 200. The lack of obtaining the required rate quotations increases the risk that the price paid was not competitive when compared to the market and that the transaction may not have been in a manner providing full and opencompetition. The lack of a documented standard of conduct that covers conflict of interest increases the risk that an actual or perceived conflict could occur.Repeat finding: NoRecommendation: We recommend the University implement controls to ensure all employees making federal purchases on behalf of the University are aware of the University?s documented procurement policy that is in accordance with 2 CFR Part 200. In addition, we recommend the University document its standard of conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts.Views of responsible officials and planned corrective actions: Heritage University agrees to put procedures in place to make certain that every employee making federal purchases on the University's behalf is aware of the University's written procurement policy, which complies with 2 CFR Part 200. Additionally, the University is to formalize its code of conduct, which addresses conflicts of interest and establishes expectations for staff members involved in contract administration, selection, and award.
Criteria: Under 2 CFR section 200.329 non-Federal entities are required to submit performance reports at the interval required by the Federal awarding agency. Reports submitted annually by the non-Federalentity are due no later than 90 calendar days after the reporting period. The reports must be supported to ensure the accuracy and completeness of the reports.Condition/context: The University was unable to provide documentation from the awarding agency indicating when reports were required to be submitted. The University submitted two performance reports covering the period under audit as such both were selected for testing. The two reports were not filed within 90 calendar days after the reporting period. In addition, we were not able to test the underlying datato ensure the data in the reports were complete and accurate.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: The University does not have a centralized process for tracking report due dates nor do they maintain the documentation for the data in the reports. The lack of support for required due dates, and data reported results in a material noncompliance with the reporting compliance requirement.Repeat finding: NoRecommendation: We recommend the University create an internal control to obtain reporting requirements for each award received by the University. We recommend a standard process be implemented for each award to track the due dates to ensure they are completed timely. Lastly, we recommend the data in the reports be supported to ensure the data is complete and accurate.Views of responsible officials and planned corrective actions: Heritage University agrees to ensure that it meets the reporting requirements for each award it receives, and the university will establish internal controls. For each award, Heritage University will place a regular procedure to keep track of the deadlines and make sure everything is finished on time. Finally, to guarantee the data is complete and reliable, Heritage University will add support to the reports' data.
Criteria: Compensation costs are allowable to the extent they satisfy requirements of Title 2 Code of Federal Regulations (CFR) section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awardsfor salaries and wages be based on records that accurately reflect the work performed.Condition/Context: A sample of 9 employees out of a population of 26 employees whose compensation was charged to the awards was selected. For each of the 9 employees selected there were no records to support the actual allocation of time that was charged to each award. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. We noted time was allocated to the award in accordance with the personnel action form that is completed upon hire for all 9 employees. Two of the employees selected had no documentation to support that their time should have been charged to the award.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None notedCause/Effect: The University does not have the proper controls in place to ensure time and effort reporting is completed. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award.Repeat finding: Yes Recommendation: We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time.Views of responsible officials and planned corrective actions: Heritage University agrees with the finding. Heritage University implemented a new internal control policy that requires employees whosecompensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each time an employee must fill out the time and effort to show actual hours worked, signed by the employee and supervisor before turning it into the payroll department. Email sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.
Criteria: Compensation costs are allowable to the extent they satisfy requirements of Title 2 Code of Federal Regulations (CFR) section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awardsfor salaries and wages be based on records that accurately reflect the work performed.Condition/Context: A sample of 9 employees out of a population of 26 employees whose compensation was charged to the awards was selected. For each of the 9 employees selected there were no records to support the actual allocation of time that was charged to each award. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. We noted time was allocated to the award in accordance with the personnel action form that is completed upon hire for all 9 employees. Two of the employees selected had no documentation to support that their time should have been charged to the award.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None notedCause/Effect: The University does not have the proper controls in place to ensure time and effort reporting is completed. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award.Repeat finding: Yes Recommendation: We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time.Views of responsible officials and planned corrective actions: Heritage University agrees with the finding. Heritage University implemented a new internal control policy that requires employees whosecompensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each time an employee must fill out the time and effort to show actual hours worked, signed by the employee and supervisor before turning it into the payroll department. Email sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.
Criteria: In accordance with 2 CFR 200.332 (b) pass-thru entities must evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring and (d) pass-thru entities must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring must include: reviewing financial and performance reports, following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award, issuing a management decision for applicable audit findings pertaining to the Federal award provided to the subrecipient and resolving audit findings specifically related to the subaward. Condition/context: We selected the one subrecipient that the University passed federal funding to during the year ended June 30, 2022. We requested support that the University performed a risk assessment and was monitoring the subrecipient, noting the University did not perform a risk assessment and was not monitoring the subrecipient in accordance with 2 CFR 200.332 (b) or (d).Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: The University does not have a clear understanding of the compliance requirements for subrecipient monitoring. The lack of subrecipient monitoring increases the risk that the subrecipient is not using the subaward for authorized purposes, in compliance with Federal statutes, regulations, or the terms and conditions of the subaward.Repeat finding: YesRecommendation: We recommend the University implement internal controls to assess the risk of the subrecipient and properly monitor any subrecipients of the University, such as reviewing single audits, financial and performance reports, or other necessary documentation of the subrecipient entity to help ensure the subrecipient is in compliance.Views of responsible officials and planned corrective actions: In agreement with the auditor?s recommendation of internal controls to properly monitor any subrecipients of the University, such as reviewing financial and performance reports of the subreceipient entity including any single audit reports. Heritage University has finalized the new ?Grant Management Policy & Procedures? manual. The grant management manual section on subrecipient is explicit about the University?s policies and procedures to ensure documentation is maintained.
Criteria: Non-federal entities, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicablestate and local laws and regulations, provided the policies and procedures conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.Condition/context: A sample of 2 expenditures greater than the micropurchase threshold of $10,000 but less than the simplified acquisition threshold of $250,000 were selected from the three transactions that exceeded the micropurchase threshold of $10,000. For one of the expenditures the University did not obtain the required rate quotations; per the University?s documented policy two quotes should have been obtained. In addition, we noted the University does not have a documented standard of conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: The personnel completing purchases on behalf of the University were unaware of the internal procurement policies that are in conformance with federal statutes and 2 CFR Part 200. The lack of obtaining the required rate quotations increases the risk that the price paid was not competitive when compared to the market and that the transaction may not have been in a manner providing full and opencompetition. The lack of a documented standard of conduct that covers conflict of interest increases the risk that an actual or perceived conflict could occur.Repeat finding: NoRecommendation: We recommend the University implement controls to ensure all employees making federal purchases on behalf of the University are aware of the University?s documented procurement policy that is in accordance with 2 CFR Part 200. In addition, we recommend the University document its standard of conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts.Views of responsible officials and planned corrective actions: Heritage University agrees to put procedures in place to make certain that every employee making federal purchases on the University's behalf is aware of the University's written procurement policy, which complies with 2 CFR Part 200. Additionally, the University is to formalize its code of conduct, which addresses conflicts of interest and establishes expectations for staff members involved in contract administration, selection, and award.
Criteria: Non-federal entities, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicablestate and local laws and regulations, provided the policies and procedures conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.Condition/context: A sample of 2 expenditures greater than the micropurchase threshold of $10,000 but less than the simplified acquisition threshold of $250,000 were selected from the three transactions that exceeded the micropurchase threshold of $10,000. For one of the expenditures the University did not obtain the required rate quotations; per the University?s documented policy two quotes should have been obtained. In addition, we noted the University does not have a documented standard of conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: The personnel completing purchases on behalf of the University were unaware of the internal procurement policies that are in conformance with federal statutes and 2 CFR Part 200. The lack of obtaining the required rate quotations increases the risk that the price paid was not competitive when compared to the market and that the transaction may not have been in a manner providing full and opencompetition. The lack of a documented standard of conduct that covers conflict of interest increases the risk that an actual or perceived conflict could occur.Repeat finding: NoRecommendation: We recommend the University implement controls to ensure all employees making federal purchases on behalf of the University are aware of the University?s documented procurement policy that is in accordance with 2 CFR Part 200. In addition, we recommend the University document its standard of conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts.Views of responsible officials and planned corrective actions: Heritage University agrees to put procedures in place to make certain that every employee making federal purchases on the University's behalf is aware of the University's written procurement policy, which complies with 2 CFR Part 200. Additionally, the University is to formalize its code of conduct, which addresses conflicts of interest and establishes expectations for staff members involved in contract administration, selection, and award.
Criteria: Under 2 CFR section 200.329 non-Federal entities are required to submit performance reports at the interval required by the Federal awarding agency. Reports submitted annually by the non-Federalentity are due no later than 90 calendar days after the reporting period. The reports must be supported to ensure the accuracy and completeness of the reports.Condition/context: The University was unable to provide documentation from the awarding agency indicating when reports were required to be submitted. The University submitted two performance reports covering the period under audit as such both were selected for testing. The two reports were not filed within 90 calendar days after the reporting period. In addition, we were not able to test the underlying datato ensure the data in the reports were complete and accurate.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: The University does not have a centralized process for tracking report due dates nor do they maintain the documentation for the data in the reports. The lack of support for required due dates, and data reported results in a material noncompliance with the reporting compliance requirement.Repeat finding: NoRecommendation: We recommend the University create an internal control to obtain reporting requirements for each award received by the University. We recommend a standard process be implemented for each award to track the due dates to ensure they are completed timely. Lastly, we recommend the data in the reports be supported to ensure the data is complete and accurate.Views of responsible officials and planned corrective actions: Heritage University agrees to ensure that it meets the reporting requirements for each award it receives, and the university will establish internal controls. For each award, Heritage University will place a regular procedure to keep track of the deadlines and make sure everything is finished on time. Finally, to guarantee the data is complete and reliable, Heritage University will add support to the reports' data.
Criteria: Under 2 CFR section 200.329 non-Federal entities are required to submit performance reports at the interval required by the Federal awarding agency. Reports submitted annually by the non-Federalentity are due no later than 90 calendar days after the reporting period. The reports must be supported to ensure the accuracy and completeness of the reports.Condition/context: The University was unable to provide documentation from the awarding agency indicating when reports were required to be submitted. The University submitted two performance reports covering the period under audit as such both were selected for testing. The two reports were not filed within 90 calendar days after the reporting period. In addition, we were not able to test the underlying datato ensure the data in the reports were complete and accurate.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: The University does not have a centralized process for tracking report due dates nor do they maintain the documentation for the data in the reports. The lack of support for required due dates, and data reported results in a material noncompliance with the reporting compliance requirement.Repeat finding: NoRecommendation: We recommend the University create an internal control to obtain reporting requirements for each award received by the University. We recommend a standard process be implemented for each award to track the due dates to ensure they are completed timely. Lastly, we recommend the data in the reports be supported to ensure the data is complete and accurate.Views of responsible officials and planned corrective actions: Heritage University agrees to ensure that it meets the reporting requirements for each award it receives, and the university will establish internal controls. For each award, Heritage University will place a regular procedure to keep track of the deadlines and make sure everything is finished on time. Finally, to guarantee the data is complete and reliable, Heritage University will add support to the reports' data.
Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act, recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System. The intent is to empower every American with the ability to hold the government accountable for each spending decision. The end result is to reduce wasteful spending in the government.Condition/context: We selected the University?s only subrecipient for testing and found the University did not report its first-tier subaward of $57,653 to the Federal Funding Accountability and Transparency Act Subaward Reporting System.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: Due to the turnover in the business office, the University did not know there was a requirement to report subrecipients to the Federal Funding Accountability and Transparency Act Subaward Reporting System. The required information is not included in the Federal Funding Accountability and Transparency Act Subaward Reporting System and as such limits the public?s ability to search for this federal award via the single, searchable website.Repeat finding: NoRecommendation: We recommend the University create an internal control to ensure all first-tier subawards of $30,000 or more are properly reported to the Federal Funding Accountability andTransparency Act Subaward Reporting System.Views of responsible officials and planned corrective actions: Heritage University will ensure that all first-tier subawards of $30,000 or more are appropriately reported to the Federal Funding Accountability and Transparency Act Subaward Reporting System, with establishing internal control.
Criteria: In accordance with the Funding Certification and Agreement for the Emergency Financial Aid Grants to Students institutions must have a documented plan to distribute funds to students. Condition/context: A sample of 25 disbursements to students out of a population of 995 disbursements to students was selected. A documented plan for distribution of funds to students was requested, however the University did not have a documented plan.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: The University did not have the controls in place to formerly approve a plan for distributions of funds that was documented and circulated to the University. The lack of a documented plan for distribution of funds to students increases the risk that funds were inappropriately disbursed to students at the wrong amounts. In addition, it increases the risk that the disbursements were not equitable across the student population.Repeat finding: YesRecommendation: We recommend the University adopt a policy that is formally approved and retained indicating how HEERF student aid portion funds are to be distributed to students.Views of responsible officials and planned corrective actions: Heritage University has implemented a new policy to formally have documentation of requesting, approving, and disbursing of the HEERF student aid portion.
Criteria: Under the Coronavirus Aid, Relief, and Economic Security Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act 314(e) institutions that received funds underHEERF I and HEERF II are required to submit a report to the secretary on how the school used its HEERF funds. While the American Rescue Plan did not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the U.S. Department of Education exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329.Condition/context: A sample of 8 special reports from the population of 8 special reports was selected. For each report, the University was unable to provide support for submission or publication dates. In addition, the University could not provide consistent institutional records for the data included in the reports nor could they provide support that the reports were reviewed prior to posting.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: Due to the turnover in the business office, the University was unable to locate support for the submission or publication dates, consistent institutional records for the data included in the reports or documented review of the reports prior to posting. The lack of support for submission or publication dates, data reported and documented review results in a material noncompliance with the reporting compliancerequirement.Repeat finding: YesRecommendation: We recommend the University update previously posted reports to accurately reflect the actual expenditures during the time period covered by the report. We recommend each report beposted to the University?s website on separate documents by quarter and should not be cumulative. We also recommend the University implement a process to ensure the submission dates and publication dates are maintained to ensure compliance with the reporting due dates and that the data submitted in the reports is properly supported by institutional records. Lastly, we recommend each report be properly reviewed by someone other than the preparer and that the review be documented with a signature anddate.Views of responsible officials and planned corrective actions: Heritage University will update the previously posted reports to accurately reflect the actual expenditures during FY20 & FY21 on the University?s website by quarter. Going further it will be the Grant accountant?s practice that the submission dates and publication dates are maintained and documented with reporting due dates. All documents will be reviewed and approved by the VP of Administration/CFO with dated signatures.
Criteria: Under the Coronavirus Aid, Relief, and Economic Security Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act 314(e) institutions that received funds underHEERF I and HEERF II are required to submit a report to the secretary on how the school used its HEERF funds. While the American Rescue Plan did not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the U.S. Department of Education exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329.Condition/context: A sample of 8 special reports from the population of 8 special reports was selected. For each report, the University was unable to provide support for submission or publication dates. In addition, the University could not provide consistent institutional records for the data included in the reports nor could they provide support that the reports were reviewed prior to posting.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: Due to the turnover in the business office, the University was unable to locate support for the submission or publication dates, consistent institutional records for the data included in the reports or documented review of the reports prior to posting. The lack of support for submission or publication dates, data reported and documented review results in a material noncompliance with the reporting compliancerequirement.Repeat finding: YesRecommendation: We recommend the University update previously posted reports to accurately reflect the actual expenditures during the time period covered by the report. We recommend each report beposted to the University?s website on separate documents by quarter and should not be cumulative. We also recommend the University implement a process to ensure the submission dates and publication dates are maintained to ensure compliance with the reporting due dates and that the data submitted in the reports is properly supported by institutional records. Lastly, we recommend each report be properly reviewed by someone other than the preparer and that the review be documented with a signature anddate.Views of responsible officials and planned corrective actions: Heritage University will update the previously posted reports to accurately reflect the actual expenditures during FY20 & FY21 on the University?s website by quarter. Going further it will be the Grant accountant?s practice that the submission dates and publication dates are maintained and documented with reporting due dates. All documents will be reviewed and approved by the VP of Administration/CFO with dated signatures.
Criteria: Compensation costs are allowable to the extent they satisfy requirements of Title 2 Code of Federal Regulations (CFR) section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awardsfor salaries and wages be based on records that accurately reflect the work performed.Condition/Context: A sample of 9 employees out of a population of 26 employees whose compensation was charged to the awards was selected. For each of the 9 employees selected there were no records to support the actual allocation of time that was charged to each award. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. We noted time was allocated to the award in accordance with the personnel action form that is completed upon hire for all 9 employees. Two of the employees selected had no documentation to support that their time should have been charged to the award.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None notedCause/Effect: The University does not have the proper controls in place to ensure time and effort reporting is completed. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award.Repeat finding: Yes Recommendation: We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time.Views of responsible officials and planned corrective actions: Heritage University agrees with the finding. Heritage University implemented a new internal control policy that requires employees whosecompensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each time an employee must fill out the time and effort to show actual hours worked, signed by the employee and supervisor before turning it into the payroll department. Email sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.
Criteria: Compensation costs are allowable to the extent they satisfy requirements of Title 2 Code of Federal Regulations (CFR) section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awardsfor salaries and wages be based on records that accurately reflect the work performed.Condition/Context: A sample of 9 employees out of a population of 26 employees whose compensation was charged to the awards was selected. For each of the 9 employees selected there were no records to support the actual allocation of time that was charged to each award. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. We noted time was allocated to the award in accordance with the personnel action form that is completed upon hire for all 9 employees. Two of the employees selected had no documentation to support that their time should have been charged to the award.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None notedCause/Effect: The University does not have the proper controls in place to ensure time and effort reporting is completed. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award.Repeat finding: Yes Recommendation: We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time.Views of responsible officials and planned corrective actions: Heritage University agrees with the finding. Heritage University implemented a new internal control policy that requires employees whosecompensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each time an employee must fill out the time and effort to show actual hours worked, signed by the employee and supervisor before turning it into the payroll department. Email sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.
Criteria: Compensation costs are allowable to the extent they satisfy requirements of Title 2 Code of Federal Regulations (CFR) section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awardsfor salaries and wages be based on records that accurately reflect the work performed.Condition/Context: A sample of 9 employees out of a population of 26 employees whose compensation was charged to the awards was selected. For each of the 9 employees selected there were no records to support the actual allocation of time that was charged to each award. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. We noted time was allocated to the award in accordance with the personnel action form that is completed upon hire for all 9 employees. Two of the employees selected had no documentation to support that their time should have been charged to the award.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None notedCause/Effect: The University does not have the proper controls in place to ensure time and effort reporting is completed. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award.Repeat finding: Yes Recommendation: We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time.Views of responsible officials and planned corrective actions: Heritage University agrees with the finding. Heritage University implemented a new internal control policy that requires employees whosecompensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each time an employee must fill out the time and effort to show actual hours worked, signed by the employee and supervisor before turning it into the payroll department. Email sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.
Criteria: Compensation costs are allowable to the extent they satisfy requirements of Title 2 Code of Federal Regulations (CFR) section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awardsfor salaries and wages be based on records that accurately reflect the work performed.Condition/Context: A sample of 9 employees out of a population of 26 employees whose compensation was charged to the awards was selected. For each of the 9 employees selected there were no records to support the actual allocation of time that was charged to each award. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. We noted time was allocated to the award in accordance with the personnel action form that is completed upon hire for all 9 employees. Two of the employees selected had no documentation to support that their time should have been charged to the award.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None notedCause/Effect: The University does not have the proper controls in place to ensure time and effort reporting is completed. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award.Repeat finding: Yes Recommendation: We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time.Views of responsible officials and planned corrective actions: Heritage University agrees with the finding. Heritage University implemented a new internal control policy that requires employees whosecompensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each time an employee must fill out the time and effort to show actual hours worked, signed by the employee and supervisor before turning it into the payroll department. Email sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.
Criteria: In accordance with 2 CFR 200.332 (b) pass-thru entities must evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring and (d) pass-thru entities must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring must include: reviewing financial and performance reports, following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award, issuing a management decision for applicable audit findings pertaining to the Federal award provided to the subrecipient and resolving audit findings specifically related to the subaward. Condition/context: We selected the one subrecipient that the University passed federal funding to during the year ended June 30, 2022. We requested support that the University performed a risk assessment and was monitoring the subrecipient, noting the University did not perform a risk assessment and was not monitoring the subrecipient in accordance with 2 CFR 200.332 (b) or (d).Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: The University does not have a clear understanding of the compliance requirements for subrecipient monitoring. The lack of subrecipient monitoring increases the risk that the subrecipient is not using the subaward for authorized purposes, in compliance with Federal statutes, regulations, or the terms and conditions of the subaward.Repeat finding: YesRecommendation: We recommend the University implement internal controls to assess the risk of the subrecipient and properly monitor any subrecipients of the University, such as reviewing single audits, financial and performance reports, or other necessary documentation of the subrecipient entity to help ensure the subrecipient is in compliance.Views of responsible officials and planned corrective actions: In agreement with the auditor?s recommendation of internal controls to properly monitor any subrecipients of the University, such as reviewing financial and performance reports of the subreceipient entity including any single audit reports. Heritage University has finalized the new ?Grant Management Policy & Procedures? manual. The grant management manual section on subrecipient is explicit about the University?s policies and procedures to ensure documentation is maintained.
Criteria: Compensation costs are allowable to the extent they satisfy requirements of Title 2 Code of Federal Regulations (CFR) section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awardsfor salaries and wages be based on records that accurately reflect the work performed.Condition/Context: A sample of 9 employees out of a population of 26 employees whose compensation was charged to the awards was selected. For each of the 9 employees selected there were no records to support the actual allocation of time that was charged to each award. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. We noted time was allocated to the award in accordance with the personnel action form that is completed upon hire for all 9 employees. Two of the employees selected had no documentation to support that their time should have been charged to the award.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None notedCause/Effect: The University does not have the proper controls in place to ensure time and effort reporting is completed. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award.Repeat finding: Yes Recommendation: We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time.Views of responsible officials and planned corrective actions: Heritage University agrees with the finding. Heritage University implemented a new internal control policy that requires employees whosecompensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each time an employee must fill out the time and effort to show actual hours worked, signed by the employee and supervisor before turning it into the payroll department. Email sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.
Criteria: Compensation costs are allowable to the extent they satisfy requirements of Title 2 Code of Federal Regulations (CFR) section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awardsfor salaries and wages be based on records that accurately reflect the work performed.Condition/Context: A sample of 9 employees out of a population of 26 employees whose compensation was charged to the awards was selected. For each of the 9 employees selected there were no records to support the actual allocation of time that was charged to each award. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. We noted time was allocated to the award in accordance with the personnel action form that is completed upon hire for all 9 employees. Two of the employees selected had no documentation to support that their time should have been charged to the award.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None notedCause/Effect: The University does not have the proper controls in place to ensure time and effort reporting is completed. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award.Repeat finding: Yes Recommendation: We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time.Views of responsible officials and planned corrective actions: Heritage University agrees with the finding. Heritage University implemented a new internal control policy that requires employees whosecompensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each time an employee must fill out the time and effort to show actual hours worked, signed by the employee and supervisor before turning it into the payroll department. Email sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.