Finding #: 2022-001 Funding Year(s): 7/1/2021 ? 6/30/2022 Federal Direct Student Loan (FAL #84.268) Award Numbers: Various Federal Agency: U.S. Department of Education Type of Finding: Special Test ? Enrollment Reporting ? Compliance and Internal Control (Significant Deficiency) Criteria: Institutions are required to report enrollment information under the Pell grant and Direct and FFEL loan programs via the NSLDS (OMB No. 1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access website. Institutions must complete and return within 15 days the Enrollment Reporting Roster File, within a minimum of every 60 days. If errors are identified by NSLDS in the submitted roster, an Error/Acknowledgement file is provided to the institution and the institution has 10 days to correct the errors and resubmit to NSLDS. Condition/Context: From a non-statistical sample of forty (40) students for which enrollment changes were reported to NSLDS, we identified one (1) instance where the student information was rejected, and for which a correction was not made within the required 10 days. Cause/Effect: Based on discussions with personnel, the above occurred due to significant turnover at the University within the Financial Aid department, including the individual with primary responsibility for NSLDS reporting. Without proper transfer of knowledge to the new Financial Aid personnel, previous processed and controls were not followed to ensure timely updated of rejected student information. Questioned Costs: None noted. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the University?s management update the internal control procedures in place surrounding enrollment reporting, including the correction of data rejected by NSLDS. Views of Responsible Official: Management agrees with the finding.
Finding #: 2022-002 Funding Year(s): 7/1/2021 ? 6/30/2022 Education Stabilization Fund (ESF) (FAL #84.425L, 84,425F, 84,825E) Award Numbers: P425L200075-20C; P425F201063-20B; P425E200786-20B Federal Agency: U.S. Department of Education Type of Finding: Procurement - Internal Control (Material Weakness) Criteria: In accordance with 2 CFR section 200.318, the entity must establish policies for procurement of equipment, real property and other services funded by federal funds. The procurement records and files for purchases in excess of the micro purchase threshold shall include at the minimum the following items: the basis for contractor selection, justification for lack of competition when competitive bids are not obtained, and basis for award cost or price. In addition, award recipients must not utilize any vendor which is suspended or debarred or is otherwise excluded from the central contractor registry. To ensure this is done, recipients should utilize the Excluded Parties List System website. Condition/Context: From a non-statistical sample of two (2) vendors subjected to testing, we determined that rate quotations and rationale for limited competition were not retained for either vendor. It was also determined that there was no documentation retained regarding verification of vendor suspension or debarment for either vendor. Cause/Effect: Per discussion with Management, the entity has the processes designed via the Policies and Procedures provided, however, there is not a formal process established to document the performance of such controls. We note that inadequate controls could result in a reasonable possibility that the entity would not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None noted. Identification as a Repeat Finding: Repeat finding. See prior year finding 2021-002. Recommendation: We recommend implementing a system of review and approval controls to complement the design of processes over the procurement, suspension, and debarment compliance requirements. In addition, we recommend that the University retain documentation regarding procurement decisions including rate quotations and verification of vendor suspension and debarment checks. Views of Responsible Official: Management agrees with finding.
Finding #: 2022-003 Funding Year(s): 7/1/2021 ? 6/30/2022 Education Stabilization Fund (ESF) (FAL #84.425L, 84,425F, 84,825E) Award Numbers: P425L200075-20C; P425F201063-20B; P425E200786-20B Federal Agency: U.S. Department of Education Type of Finding: Reporting - Internal Control (Material Weakness) Criteria: In accordance with 2 CFR sections 200.328 and 200.329, there are three components to reporting for HEERF: 1) public reporting on the Student Aid Portion; 2) public reporting on the Institutional Portion and subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. A complete system of internal controls requires all expenditures be properly approved and supported by appropriate documentation. Condition/Context: From a non-statistical sample of two (2) reports subject to testing, we identified two (2) instances where the report tested lacked evidence of review in accordance with the University?s control policies. Cause/Effect: Based on discussions with Management, the above occurred due to efforts made to abide by the 10-day time period between quarter-end and the reporting deadline. Due to the short time period, the review and approval process is rushed, and the necessary review took place during tele-conference and the CFO provided approval over the phone to get the report posted accordingly. Questioned Costs: None noted. Identification as a Repeat Finding: Repeat finding. See prior year finding 2021-003. Recommendation: We recommend the University?s Management routinely review and consider modifications that would strengthen the internal controls surrounding reporting specifically as it relates to documenting approval of reports. Views of Responsible Official: Management agrees with finding.
Finding #: 2022-002 Funding Year(s): 7/1/2021 ? 6/30/2022 Education Stabilization Fund (ESF) (FAL #84.425L, 84,425F, 84,825E) Award Numbers: P425L200075-20C; P425F201063-20B; P425E200786-20B Federal Agency: U.S. Department of Education Type of Finding: Procurement - Internal Control (Material Weakness) Criteria: In accordance with 2 CFR section 200.318, the entity must establish policies for procurement of equipment, real property and other services funded by federal funds. The procurement records and files for purchases in excess of the micro purchase threshold shall include at the minimum the following items: the basis for contractor selection, justification for lack of competition when competitive bids are not obtained, and basis for award cost or price. In addition, award recipients must not utilize any vendor which is suspended or debarred or is otherwise excluded from the central contractor registry. To ensure this is done, recipients should utilize the Excluded Parties List System website. Condition/Context: From a non-statistical sample of two (2) vendors subjected to testing, we determined that rate quotations and rationale for limited competition were not retained for either vendor. It was also determined that there was no documentation retained regarding verification of vendor suspension or debarment for either vendor. Cause/Effect: Per discussion with Management, the entity has the processes designed via the Policies and Procedures provided, however, there is not a formal process established to document the performance of such controls. We note that inadequate controls could result in a reasonable possibility that the entity would not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None noted. Identification as a Repeat Finding: Repeat finding. See prior year finding 2021-002. Recommendation: We recommend implementing a system of review and approval controls to complement the design of processes over the procurement, suspension, and debarment compliance requirements. In addition, we recommend that the University retain documentation regarding procurement decisions including rate quotations and verification of vendor suspension and debarment checks. Views of Responsible Official: Management agrees with finding.
Finding #: 2022-003 Funding Year(s): 7/1/2021 ? 6/30/2022 Education Stabilization Fund (ESF) (FAL #84.425L, 84,425F, 84,825E) Award Numbers: P425L200075-20C; P425F201063-20B; P425E200786-20B Federal Agency: U.S. Department of Education Type of Finding: Reporting - Internal Control (Material Weakness) Criteria: In accordance with 2 CFR sections 200.328 and 200.329, there are three components to reporting for HEERF: 1) public reporting on the Student Aid Portion; 2) public reporting on the Institutional Portion and subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. A complete system of internal controls requires all expenditures be properly approved and supported by appropriate documentation. Condition/Context: From a non-statistical sample of two (2) reports subject to testing, we identified two (2) instances where the report tested lacked evidence of review in accordance with the University?s control policies. Cause/Effect: Based on discussions with Management, the above occurred due to efforts made to abide by the 10-day time period between quarter-end and the reporting deadline. Due to the short time period, the review and approval process is rushed, and the necessary review took place during tele-conference and the CFO provided approval over the phone to get the report posted accordingly. Questioned Costs: None noted. Identification as a Repeat Finding: Repeat finding. See prior year finding 2021-003. Recommendation: We recommend the University?s Management routinely review and consider modifications that would strengthen the internal controls surrounding reporting specifically as it relates to documenting approval of reports. Views of Responsible Official: Management agrees with finding.
Finding #: 2022-002 Funding Year(s): 7/1/2021 ? 6/30/2022 Education Stabilization Fund (ESF) (FAL #84.425L, 84,425F, 84,825E) Award Numbers: P425L200075-20C; P425F201063-20B; P425E200786-20B Federal Agency: U.S. Department of Education Type of Finding: Procurement - Internal Control (Material Weakness) Criteria: In accordance with 2 CFR section 200.318, the entity must establish policies for procurement of equipment, real property and other services funded by federal funds. The procurement records and files for purchases in excess of the micro purchase threshold shall include at the minimum the following items: the basis for contractor selection, justification for lack of competition when competitive bids are not obtained, and basis for award cost or price. In addition, award recipients must not utilize any vendor which is suspended or debarred or is otherwise excluded from the central contractor registry. To ensure this is done, recipients should utilize the Excluded Parties List System website. Condition/Context: From a non-statistical sample of two (2) vendors subjected to testing, we determined that rate quotations and rationale for limited competition were not retained for either vendor. It was also determined that there was no documentation retained regarding verification of vendor suspension or debarment for either vendor. Cause/Effect: Per discussion with Management, the entity has the processes designed via the Policies and Procedures provided, however, there is not a formal process established to document the performance of such controls. We note that inadequate controls could result in a reasonable possibility that the entity would not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None noted. Identification as a Repeat Finding: Repeat finding. See prior year finding 2021-002. Recommendation: We recommend implementing a system of review and approval controls to complement the design of processes over the procurement, suspension, and debarment compliance requirements. In addition, we recommend that the University retain documentation regarding procurement decisions including rate quotations and verification of vendor suspension and debarment checks. Views of Responsible Official: Management agrees with finding.
Finding #: 2022-003 Funding Year(s): 7/1/2021 ? 6/30/2022 Education Stabilization Fund (ESF) (FAL #84.425L, 84,425F, 84,825E) Award Numbers: P425L200075-20C; P425F201063-20B; P425E200786-20B Federal Agency: U.S. Department of Education Type of Finding: Reporting - Internal Control (Material Weakness) Criteria: In accordance with 2 CFR sections 200.328 and 200.329, there are three components to reporting for HEERF: 1) public reporting on the Student Aid Portion; 2) public reporting on the Institutional Portion and subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. A complete system of internal controls requires all expenditures be properly approved and supported by appropriate documentation. Condition/Context: From a non-statistical sample of two (2) reports subject to testing, we identified two (2) instances where the report tested lacked evidence of review in accordance with the University?s control policies. Cause/Effect: Based on discussions with Management, the above occurred due to efforts made to abide by the 10-day time period between quarter-end and the reporting deadline. Due to the short time period, the review and approval process is rushed, and the necessary review took place during tele-conference and the CFO provided approval over the phone to get the report posted accordingly. Questioned Costs: None noted. Identification as a Repeat Finding: Repeat finding. See prior year finding 2021-003. Recommendation: We recommend the University?s Management routinely review and consider modifications that would strengthen the internal controls surrounding reporting specifically as it relates to documenting approval of reports. Views of Responsible Official: Management agrees with finding.
Finding #: 2022-001 Funding Year(s): 7/1/2021 ? 6/30/2022 Federal Direct Student Loan (FAL #84.268) Award Numbers: Various Federal Agency: U.S. Department of Education Type of Finding: Special Test ? Enrollment Reporting ? Compliance and Internal Control (Significant Deficiency) Criteria: Institutions are required to report enrollment information under the Pell grant and Direct and FFEL loan programs via the NSLDS (OMB No. 1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access website. Institutions must complete and return within 15 days the Enrollment Reporting Roster File, within a minimum of every 60 days. If errors are identified by NSLDS in the submitted roster, an Error/Acknowledgement file is provided to the institution and the institution has 10 days to correct the errors and resubmit to NSLDS. Condition/Context: From a non-statistical sample of forty (40) students for which enrollment changes were reported to NSLDS, we identified one (1) instance where the student information was rejected, and for which a correction was not made within the required 10 days. Cause/Effect: Based on discussions with personnel, the above occurred due to significant turnover at the University within the Financial Aid department, including the individual with primary responsibility for NSLDS reporting. Without proper transfer of knowledge to the new Financial Aid personnel, previous processed and controls were not followed to ensure timely updated of rejected student information. Questioned Costs: None noted. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the University?s management update the internal control procedures in place surrounding enrollment reporting, including the correction of data rejected by NSLDS. Views of Responsible Official: Management agrees with the finding.
Finding #: 2022-002 Funding Year(s): 7/1/2021 ? 6/30/2022 Education Stabilization Fund (ESF) (FAL #84.425L, 84,425F, 84,825E) Award Numbers: P425L200075-20C; P425F201063-20B; P425E200786-20B Federal Agency: U.S. Department of Education Type of Finding: Procurement - Internal Control (Material Weakness) Criteria: In accordance with 2 CFR section 200.318, the entity must establish policies for procurement of equipment, real property and other services funded by federal funds. The procurement records and files for purchases in excess of the micro purchase threshold shall include at the minimum the following items: the basis for contractor selection, justification for lack of competition when competitive bids are not obtained, and basis for award cost or price. In addition, award recipients must not utilize any vendor which is suspended or debarred or is otherwise excluded from the central contractor registry. To ensure this is done, recipients should utilize the Excluded Parties List System website. Condition/Context: From a non-statistical sample of two (2) vendors subjected to testing, we determined that rate quotations and rationale for limited competition were not retained for either vendor. It was also determined that there was no documentation retained regarding verification of vendor suspension or debarment for either vendor. Cause/Effect: Per discussion with Management, the entity has the processes designed via the Policies and Procedures provided, however, there is not a formal process established to document the performance of such controls. We note that inadequate controls could result in a reasonable possibility that the entity would not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None noted. Identification as a Repeat Finding: Repeat finding. See prior year finding 2021-002. Recommendation: We recommend implementing a system of review and approval controls to complement the design of processes over the procurement, suspension, and debarment compliance requirements. In addition, we recommend that the University retain documentation regarding procurement decisions including rate quotations and verification of vendor suspension and debarment checks. Views of Responsible Official: Management agrees with finding.
Finding #: 2022-003 Funding Year(s): 7/1/2021 ? 6/30/2022 Education Stabilization Fund (ESF) (FAL #84.425L, 84,425F, 84,825E) Award Numbers: P425L200075-20C; P425F201063-20B; P425E200786-20B Federal Agency: U.S. Department of Education Type of Finding: Reporting - Internal Control (Material Weakness) Criteria: In accordance with 2 CFR sections 200.328 and 200.329, there are three components to reporting for HEERF: 1) public reporting on the Student Aid Portion; 2) public reporting on the Institutional Portion and subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. A complete system of internal controls requires all expenditures be properly approved and supported by appropriate documentation. Condition/Context: From a non-statistical sample of two (2) reports subject to testing, we identified two (2) instances where the report tested lacked evidence of review in accordance with the University?s control policies. Cause/Effect: Based on discussions with Management, the above occurred due to efforts made to abide by the 10-day time period between quarter-end and the reporting deadline. Due to the short time period, the review and approval process is rushed, and the necessary review took place during tele-conference and the CFO provided approval over the phone to get the report posted accordingly. Questioned Costs: None noted. Identification as a Repeat Finding: Repeat finding. See prior year finding 2021-003. Recommendation: We recommend the University?s Management routinely review and consider modifications that would strengthen the internal controls surrounding reporting specifically as it relates to documenting approval of reports. Views of Responsible Official: Management agrees with finding.
Finding #: 2022-002 Funding Year(s): 7/1/2021 ? 6/30/2022 Education Stabilization Fund (ESF) (FAL #84.425L, 84,425F, 84,825E) Award Numbers: P425L200075-20C; P425F201063-20B; P425E200786-20B Federal Agency: U.S. Department of Education Type of Finding: Procurement - Internal Control (Material Weakness) Criteria: In accordance with 2 CFR section 200.318, the entity must establish policies for procurement of equipment, real property and other services funded by federal funds. The procurement records and files for purchases in excess of the micro purchase threshold shall include at the minimum the following items: the basis for contractor selection, justification for lack of competition when competitive bids are not obtained, and basis for award cost or price. In addition, award recipients must not utilize any vendor which is suspended or debarred or is otherwise excluded from the central contractor registry. To ensure this is done, recipients should utilize the Excluded Parties List System website. Condition/Context: From a non-statistical sample of two (2) vendors subjected to testing, we determined that rate quotations and rationale for limited competition were not retained for either vendor. It was also determined that there was no documentation retained regarding verification of vendor suspension or debarment for either vendor. Cause/Effect: Per discussion with Management, the entity has the processes designed via the Policies and Procedures provided, however, there is not a formal process established to document the performance of such controls. We note that inadequate controls could result in a reasonable possibility that the entity would not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None noted. Identification as a Repeat Finding: Repeat finding. See prior year finding 2021-002. Recommendation: We recommend implementing a system of review and approval controls to complement the design of processes over the procurement, suspension, and debarment compliance requirements. In addition, we recommend that the University retain documentation regarding procurement decisions including rate quotations and verification of vendor suspension and debarment checks. Views of Responsible Official: Management agrees with finding.
Finding #: 2022-003 Funding Year(s): 7/1/2021 ? 6/30/2022 Education Stabilization Fund (ESF) (FAL #84.425L, 84,425F, 84,825E) Award Numbers: P425L200075-20C; P425F201063-20B; P425E200786-20B Federal Agency: U.S. Department of Education Type of Finding: Reporting - Internal Control (Material Weakness) Criteria: In accordance with 2 CFR sections 200.328 and 200.329, there are three components to reporting for HEERF: 1) public reporting on the Student Aid Portion; 2) public reporting on the Institutional Portion and subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. A complete system of internal controls requires all expenditures be properly approved and supported by appropriate documentation. Condition/Context: From a non-statistical sample of two (2) reports subject to testing, we identified two (2) instances where the report tested lacked evidence of review in accordance with the University?s control policies. Cause/Effect: Based on discussions with Management, the above occurred due to efforts made to abide by the 10-day time period between quarter-end and the reporting deadline. Due to the short time period, the review and approval process is rushed, and the necessary review took place during tele-conference and the CFO provided approval over the phone to get the report posted accordingly. Questioned Costs: None noted. Identification as a Repeat Finding: Repeat finding. See prior year finding 2021-003. Recommendation: We recommend the University?s Management routinely review and consider modifications that would strengthen the internal controls surrounding reporting specifically as it relates to documenting approval of reports. Views of Responsible Official: Management agrees with finding.
Finding #: 2022-002 Funding Year(s): 7/1/2021 ? 6/30/2022 Education Stabilization Fund (ESF) (FAL #84.425L, 84,425F, 84,825E) Award Numbers: P425L200075-20C; P425F201063-20B; P425E200786-20B Federal Agency: U.S. Department of Education Type of Finding: Procurement - Internal Control (Material Weakness) Criteria: In accordance with 2 CFR section 200.318, the entity must establish policies for procurement of equipment, real property and other services funded by federal funds. The procurement records and files for purchases in excess of the micro purchase threshold shall include at the minimum the following items: the basis for contractor selection, justification for lack of competition when competitive bids are not obtained, and basis for award cost or price. In addition, award recipients must not utilize any vendor which is suspended or debarred or is otherwise excluded from the central contractor registry. To ensure this is done, recipients should utilize the Excluded Parties List System website. Condition/Context: From a non-statistical sample of two (2) vendors subjected to testing, we determined that rate quotations and rationale for limited competition were not retained for either vendor. It was also determined that there was no documentation retained regarding verification of vendor suspension or debarment for either vendor. Cause/Effect: Per discussion with Management, the entity has the processes designed via the Policies and Procedures provided, however, there is not a formal process established to document the performance of such controls. We note that inadequate controls could result in a reasonable possibility that the entity would not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None noted. Identification as a Repeat Finding: Repeat finding. See prior year finding 2021-002. Recommendation: We recommend implementing a system of review and approval controls to complement the design of processes over the procurement, suspension, and debarment compliance requirements. In addition, we recommend that the University retain documentation regarding procurement decisions including rate quotations and verification of vendor suspension and debarment checks. Views of Responsible Official: Management agrees with finding.
Finding #: 2022-003 Funding Year(s): 7/1/2021 ? 6/30/2022 Education Stabilization Fund (ESF) (FAL #84.425L, 84,425F, 84,825E) Award Numbers: P425L200075-20C; P425F201063-20B; P425E200786-20B Federal Agency: U.S. Department of Education Type of Finding: Reporting - Internal Control (Material Weakness) Criteria: In accordance with 2 CFR sections 200.328 and 200.329, there are three components to reporting for HEERF: 1) public reporting on the Student Aid Portion; 2) public reporting on the Institutional Portion and subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. A complete system of internal controls requires all expenditures be properly approved and supported by appropriate documentation. Condition/Context: From a non-statistical sample of two (2) reports subject to testing, we identified two (2) instances where the report tested lacked evidence of review in accordance with the University?s control policies. Cause/Effect: Based on discussions with Management, the above occurred due to efforts made to abide by the 10-day time period between quarter-end and the reporting deadline. Due to the short time period, the review and approval process is rushed, and the necessary review took place during tele-conference and the CFO provided approval over the phone to get the report posted accordingly. Questioned Costs: None noted. Identification as a Repeat Finding: Repeat finding. See prior year finding 2021-003. Recommendation: We recommend the University?s Management routinely review and consider modifications that would strengthen the internal controls surrounding reporting specifically as it relates to documenting approval of reports. Views of Responsible Official: Management agrees with finding.