FAC Explorer

Audit 334393

FY End
2022-06-30
Total Expended
$17.39M
Findings
28
Programs
9
Organization: Atlantic University College, Inc. (PR)
Year: 2022 Accepted: 2024-12-20
Auditor: De Angel & Compañia CPA LLC

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
516483 2022-004 Significant Deficiency - L
516484 2022-005 Significant Deficiency - L
516485 2022-004 Significant Deficiency - L
516486 2022-005 Significant Deficiency - L
516487 2022-004 Significant Deficiency - L
516488 2022-005 Significant Deficiency - L
516489 2022-004 Significant Deficiency - L
516490 2022-005 Significant Deficiency - L
516491 2022-002 Significant Deficiency - C
516492 2022-003 Material Weakness - I
516493 2022-004 Significant Deficiency - L
516494 2022-002 Significant Deficiency - C
516495 2022-003 Material Weakness - I
516496 2022-004 Significant Deficiency - L
1092925 2022-004 Significant Deficiency - L
1092926 2022-005 Significant Deficiency - L
1092927 2022-004 Significant Deficiency - L
1092928 2022-005 Significant Deficiency - L
1092929 2022-004 Significant Deficiency - L
1092930 2022-005 Significant Deficiency - L
1092931 2022-004 Significant Deficiency - L
1092932 2022-005 Significant Deficiency - L
1092933 2022-002 Significant Deficiency - C
1092934 2022-003 Material Weakness - I
1092935 2022-004 Significant Deficiency - L
1092936 2022-002 Significant Deficiency - C
1092937 2022-003 Material Weakness - I
1092938 2022-004 Significant Deficiency - L

Programs

ALN Program Spent Major Findings
84.063 Federal Pell Grant Program $6.39M Yes 2
84.425 Covid-19 - Higher Education Emergency Relief Fund (heerf) Student Aid Portion $4.82M Yes 0
84.425 Covid-19 - Higher Education Emergency Relief Fund (heerf) Institutional Portion $3.66M Yes 3
84.268 Federal Direct Student Loan Program $656,550 Yes 2
84.031 Developing Hispanic-Serving Institutions Program (title V) $570,482 - 0
84.425 Covid-19 - Heerf Minority Serving Institutions (msis) $536,855 Yes 3
84.031 Promoting Postbaccalaureate Opportunities for Hispanic Americans Program (ppoha) $518,504 - 0
84.007 Federal Supplemental Educational Opportunity Grant Program $186,729 Yes 2
84.033 Federal Work-Study Program $53,387 Yes 2

Contacts

Name Title Type
QMUFKL83DM29 Viviana Santiago Auditee
7877201022 CPA Carlos De Angel Ramirez Auditor
No contacts on file

Notes to SEFA

Title: SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Accounting Policies: The accompanying schedule of expenditures of federal award (the “Schedule”) includes the federal awards activity of Atlantic University College, Inc., (hereinafter “Organization”), under programs of the federal government for the year ended June 30, 2022. The information in this schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used, in the preparation of the Organization’s financial statements. Because the Schedule presents only a selected portion of the activities of the University, it is not intended to, and does not, present the financial position, changes in net assets, and cash flows of the University. Funds received for students’ financial assistance (principally, Pell Grant and Direct Loans) that are awarded directly to students for educational purposes are excluded from revenues and expenses. These grants are applied to the students’ tuition and fees, and any excess is paid to the students. De Minimis Rate Used: N Rate Explanation: The Organization has elected not to use the 10% minimis indirect cost rate allowed under the Uniform Guidance Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, Cost Principles for Non-profit Organizations, wherein certain types of expenditures are not allowable or are limited to reimbursement.
Title: SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Accounting Policies: The accompanying schedule of expenditures of federal award (the “Schedule”) includes the federal awards activity of Atlantic University College, Inc., (hereinafter “Organization”), under programs of the federal government for the year ended June 30, 2022. The information in this schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used, in the preparation of the Organization’s financial statements. Because the Schedule presents only a selected portion of the activities of the University, it is not intended to, and does not, present the financial position, changes in net assets, and cash flows of the University. Funds received for students’ financial assistance (principally, Pell Grant and Direct Loans) that are awarded directly to students for educational purposes are excluded from revenues and expenses. These grants are applied to the students’ tuition and fees, and any excess is paid to the students. De Minimis Rate Used: N Rate Explanation: The Organization has elected not to use the 10% minimis indirect cost rate allowed under the Uniform Guidance a. The Schedule is prepared from the University’s accounting records and is not intended to present its financial position or the results of its operations.
Title: SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Accounting Policies: The accompanying schedule of expenditures of federal award (the “Schedule”) includes the federal awards activity of Atlantic University College, Inc., (hereinafter “Organization”), under programs of the federal government for the year ended June 30, 2022. The information in this schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used, in the preparation of the Organization’s financial statements. Because the Schedule presents only a selected portion of the activities of the University, it is not intended to, and does not, present the financial position, changes in net assets, and cash flows of the University. Funds received for students’ financial assistance (principally, Pell Grant and Direct Loans) that are awarded directly to students for educational purposes are excluded from revenues and expenses. These grants are applied to the students’ tuition and fees, and any excess is paid to the students. De Minimis Rate Used: N Rate Explanation: The Organization has elected not to use the 10% minimis indirect cost rate allowed under the Uniform Guidance b. The financial transactions are recorded by the University in accordance with the terms and conditions of the grants, which are consistent with accounting principles generally accepted in the United States of America.
Title: SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Accounting Policies: The accompanying schedule of expenditures of federal award (the “Schedule”) includes the federal awards activity of Atlantic University College, Inc., (hereinafter “Organization”), under programs of the federal government for the year ended June 30, 2022. The information in this schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used, in the preparation of the Organization’s financial statements. Because the Schedule presents only a selected portion of the activities of the University, it is not intended to, and does not, present the financial position, changes in net assets, and cash flows of the University. Funds received for students’ financial assistance (principally, Pell Grant and Direct Loans) that are awarded directly to students for educational purposes are excluded from revenues and expenses. These grants are applied to the students’ tuition and fees, and any excess is paid to the students. De Minimis Rate Used: N Rate Explanation: The Organization has elected not to use the 10% minimis indirect cost rate allowed under the Uniform Guidance c. Expenditures are recognized in the accounting period in which the liability is incurred, if measurable or when actually paid, whichever occurs first.
Title: SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Accounting Policies: The accompanying schedule of expenditures of federal award (the “Schedule”) includes the federal awards activity of Atlantic University College, Inc., (hereinafter “Organization”), under programs of the federal government for the year ended June 30, 2022. The information in this schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used, in the preparation of the Organization’s financial statements. Because the Schedule presents only a selected portion of the activities of the University, it is not intended to, and does not, present the financial position, changes in net assets, and cash flows of the University. Funds received for students’ financial assistance (principally, Pell Grant and Direct Loans) that are awarded directly to students for educational purposes are excluded from revenues and expenses. These grants are applied to the students’ tuition and fees, and any excess is paid to the students. De Minimis Rate Used: N Rate Explanation: The Organization has elected not to use the 10% minimis indirect cost rate allowed under the Uniform Guidance d. Expenditures are reported on the Schedule following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures may or may not be allowable or may be limited as to reimbursement.
Title: SCHEDULE NOT IN AGREEMENT WITH OTHER FEDERAL AWARDS REPORTING Accounting Policies: The accompanying schedule of expenditures of federal award (the “Schedule”) includes the federal awards activity of Atlantic University College, Inc., (hereinafter “Organization”), under programs of the federal government for the year ended June 30, 2022. The information in this schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used, in the preparation of the Organization’s financial statements. Because the Schedule presents only a selected portion of the activities of the University, it is not intended to, and does not, present the financial position, changes in net assets, and cash flows of the University. Funds received for students’ financial assistance (principally, Pell Grant and Direct Loans) that are awarded directly to students for educational purposes are excluded from revenues and expenses. These grants are applied to the students’ tuition and fees, and any excess is paid to the students. De Minimis Rate Used: N Rate Explanation: The Organization has elected not to use the 10% minimis indirect cost rate allowed under the Uniform Guidance The information included in the Schedule may not fully agree with other federal awards reports, submitted directly to federal grantor agencies because, among other reasons, the award report may (a) be prepared for a different fiscal period and (b) include cumulative data (from prior years) rather than data from the current year only.
Title: MAJOR FEDERAL PROGRAMS Accounting Policies: The accompanying schedule of expenditures of federal award (the “Schedule”) includes the federal awards activity of Atlantic University College, Inc., (hereinafter “Organization”), under programs of the federal government for the year ended June 30, 2022. The information in this schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used, in the preparation of the Organization’s financial statements. Because the Schedule presents only a selected portion of the activities of the University, it is not intended to, and does not, present the financial position, changes in net assets, and cash flows of the University. Funds received for students’ financial assistance (principally, Pell Grant and Direct Loans) that are awarded directly to students for educational purposes are excluded from revenues and expenses. These grants are applied to the students’ tuition and fees, and any excess is paid to the students. De Minimis Rate Used: N Rate Explanation: The Organization has elected not to use the 10% minimis indirect cost rate allowed under the Uniform Guidance Major programs are identified in the Summary of Auditors’ Results Section in the Schedule of Findings and Questioned Costs. Federal programs are presented by federal agency.
Title: ASSISTANCE LISTING NUMBER (ALN) Accounting Policies: The accompanying schedule of expenditures of federal award (the “Schedule”) includes the federal awards activity of Atlantic University College, Inc., (hereinafter “Organization”), under programs of the federal government for the year ended June 30, 2022. The information in this schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used, in the preparation of the Organization’s financial statements. Because the Schedule presents only a selected portion of the activities of the University, it is not intended to, and does not, present the financial position, changes in net assets, and cash flows of the University. Funds received for students’ financial assistance (principally, Pell Grant and Direct Loans) that are awarded directly to students for educational purposes are excluded from revenues and expenses. These grants are applied to the students’ tuition and fees, and any excess is paid to the students. De Minimis Rate Used: N Rate Explanation: The Organization has elected not to use the 10% minimis indirect cost rate allowed under the Uniform Guidance Assistance Listing Number ("ALN") numbers are presented for those programs for which such numbers are available. Federal programs are presented as appropriate, by the Federal Department. The first two digits identify the federal department or agency that administers the program, and the last three numbers are assigned by numerical sequence.
Title: ACCOUNTING POLICIES FOR LOANS AND LOAN GUARANTEES Accounting Policies: The accompanying schedule of expenditures of federal award (the “Schedule”) includes the federal awards activity of Atlantic University College, Inc., (hereinafter “Organization”), under programs of the federal government for the year ended June 30, 2022. The information in this schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used, in the preparation of the Organization’s financial statements. Because the Schedule presents only a selected portion of the activities of the University, it is not intended to, and does not, present the financial position, changes in net assets, and cash flows of the University. Funds received for students’ financial assistance (principally, Pell Grant and Direct Loans) that are awarded directly to students for educational purposes are excluded from revenues and expenses. These grants are applied to the students’ tuition and fees, and any excess is paid to the students. De Minimis Rate Used: N Rate Explanation: The Organization has elected not to use the 10% minimis indirect cost rate allowed under the Uniform Guidance The Organization participates in the Federal Direct Student Loans (Direct Loans) Program (ALN 84.268) of the U.S. Department of Education (USDE). Under the Direct Loans program, the University is responsible only for certain administrative duties, accordingly, the disbursements under the program and the outstanding loan balances are excluded from the financial statements of the Organization. However, Direct Loans are considered a component of the student financial assistance programs of the Organization, as such, new loans processed during the year ended June 30, 2022 amounting to $686,065 were included in the Schedule. Federal expenditures for Direct Loans are determined when loans are made to the students, accordingly, the balance of Direct Loans from previous years is not considered federal expenditures of the current year.
Title: PASS-THROUGH Accounting Policies: The accompanying schedule of expenditures of federal award (the “Schedule”) includes the federal awards activity of Atlantic University College, Inc., (hereinafter “Organization”), under programs of the federal government for the year ended June 30, 2022. The information in this schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used, in the preparation of the Organization’s financial statements. Because the Schedule presents only a selected portion of the activities of the University, it is not intended to, and does not, present the financial position, changes in net assets, and cash flows of the University. Funds received for students’ financial assistance (principally, Pell Grant and Direct Loans) that are awarded directly to students for educational purposes are excluded from revenues and expenses. These grants are applied to the students’ tuition and fees, and any excess is paid to the students. De Minimis Rate Used: N Rate Explanation: The Organization has elected not to use the 10% minimis indirect cost rate allowed under the Uniform Guidance No federal grant dollar has been passed through to sub-recipient.

Finding Details

Finding 2022-004
Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
Finding 2022-005
Enrollment Reporting Federal Program Name Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR 685.309 (b)(2)(ii) states that unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that; a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition As part of our testing of twenty five (25) students who graduated and/or withdrew during 2022, we noted the following instances of non-compliance: 1. Two (2) students for which the Institution did not report to the National Student Loan Data System (NSLDS) the student status changes within the required 60 days’ period. Cause Late submissions were mainly caused due to lack of verification of information submitted to the National Student Clearinghouse (NSC) and they submitted it to NSLDS as is. The ordinary process was that the programmer created the file and sent it directly through the third-party clearinghouse. Errors in the file were not addressed. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of the Direct Loan Program and for USDE budgetary policy analysis. Questioned Cost None Context Of the two hundred and thirty-five (235) status changes for 2023, we selected twenty (25) students for testing and noted two (2) instances in which the Institution did not comply with the enrollment reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the timeframe in which the Institution submits the information to the NSC and reinforce its monitoring of NSC to ensure they comply with the agreed upon reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure enrollment status changes are timely and accurately reported to NSDLS.
Finding 2022-004
Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
Finding 2022-005
Enrollment Reporting Federal Program Name Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR 685.309 (b)(2)(ii) states that unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that; a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition As part of our testing of twenty five (25) students who graduated and/or withdrew during 2022, we noted the following instances of non-compliance: 1. Two (2) students for which the Institution did not report to the National Student Loan Data System (NSLDS) the student status changes within the required 60 days’ period. Cause Late submissions were mainly caused due to lack of verification of information submitted to the National Student Clearinghouse (NSC) and they submitted it to NSLDS as is. The ordinary process was that the programmer created the file and sent it directly through the third-party clearinghouse. Errors in the file were not addressed. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of the Direct Loan Program and for USDE budgetary policy analysis. Questioned Cost None Context Of the two hundred and thirty-five (235) status changes for 2023, we selected twenty (25) students for testing and noted two (2) instances in which the Institution did not comply with the enrollment reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the timeframe in which the Institution submits the information to the NSC and reinforce its monitoring of NSC to ensure they comply with the agreed upon reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure enrollment status changes are timely and accurately reported to NSDLS.
Finding 2022-004
Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
Finding 2022-005
Enrollment Reporting Federal Program Name Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR 685.309 (b)(2)(ii) states that unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that; a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition As part of our testing of twenty five (25) students who graduated and/or withdrew during 2022, we noted the following instances of non-compliance: 1. Two (2) students for which the Institution did not report to the National Student Loan Data System (NSLDS) the student status changes within the required 60 days’ period. Cause Late submissions were mainly caused due to lack of verification of information submitted to the National Student Clearinghouse (NSC) and they submitted it to NSLDS as is. The ordinary process was that the programmer created the file and sent it directly through the third-party clearinghouse. Errors in the file were not addressed. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of the Direct Loan Program and for USDE budgetary policy analysis. Questioned Cost None Context Of the two hundred and thirty-five (235) status changes for 2023, we selected twenty (25) students for testing and noted two (2) instances in which the Institution did not comply with the enrollment reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the timeframe in which the Institution submits the information to the NSC and reinforce its monitoring of NSC to ensure they comply with the agreed upon reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure enrollment status changes are timely and accurately reported to NSDLS.
Finding 2022-004
Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
Finding 2022-005
Enrollment Reporting Federal Program Name Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR 685.309 (b)(2)(ii) states that unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that; a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition As part of our testing of twenty five (25) students who graduated and/or withdrew during 2022, we noted the following instances of non-compliance: 1. Two (2) students for which the Institution did not report to the National Student Loan Data System (NSLDS) the student status changes within the required 60 days’ period. Cause Late submissions were mainly caused due to lack of verification of information submitted to the National Student Clearinghouse (NSC) and they submitted it to NSLDS as is. The ordinary process was that the programmer created the file and sent it directly through the third-party clearinghouse. Errors in the file were not addressed. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of the Direct Loan Program and for USDE budgetary policy analysis. Questioned Cost None Context Of the two hundred and thirty-five (235) status changes for 2023, we selected twenty (25) students for testing and noted two (2) instances in which the Institution did not comply with the enrollment reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the timeframe in which the Institution submits the information to the NSC and reinforce its monitoring of NSC to ensure they comply with the agreed upon reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure enrollment status changes are timely and accurately reported to NSDLS.
Finding 2022-002
Cash Management Federal Program Name Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria According to the 2 CFR 200.305(b) non-federal entities must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Also, CRRSAA HEERF II and ARP HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Institutional Aid Portion, (a)(2), and (a)(3) funds should be disbursed within 3 calendar days of the drawdown from G5. Condition During our examination, we found the following instances on which the Institution did not disbursed funds in an expedite matter: Fund Instances Average of days late 84.425F 106 7 84.425L 5 31 Cause The delay in disbursements responds to several situations: remote work, lack of banking or information from suppliers, multiplicity of tasks under the responsibility of the Administration and Operations Director, which affected the dates of sending the payments. Effect As a result of this condition, the USDE may issue warnings and/or impose penalties to the Institution. Questioned Cost None Context During our examination, we noted one hundred six (106) instances from one hundred thirty-six (136) of the HEERF Institutional portion and five (5) instances from five (5) from Minority, on which the Institution did not disbursed funds within 3 calendar days of the drawdown from G5. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation The management of the Institution should reinforce its cash management procedures and internal controls to ensure the disbursement of funds in the required time frame after the drawdowns from G5. Views of Responsible Officials of the Auditee and Planned Corrective Actions The management of the Institution agrees with this finding. Please refer to the corrective action plan on pages 22-26.
Finding 2022-003
Procurement and Suspension and Debarment Federal Program Name Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria According to 2 CFR Section 200.319, all procurement transactions must be conducted in a manner providing full and open competition. According to 2 CFR Section 200.320 there are three types of procurement methods described in this section: informal procurement methods (for micro-purchases and simplified acquisitions); formal procurement methods (through sealed bids or proposals); and noncompetitive procurement methods. For any of these methods, the recipient or subrecipient must maintain and use documented procurement procedures. 2 CFR section 180.220(b)(1) non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000. Condition As part of our testing of fifteen (15) disbursements from institutional funds, we noted the following instances of non-compliance: 1. Six (6) transactions weren’t conducted in a manner providing full and open competition, no quotes nor quote analysis were available for examination. 2. Six (6) transactions Suspension and Debarment verification weren’t performed. Cause The exceptions mentioned above are the result of the failure to implement adequate internal control procedures, such as thorough managerial review, which should detect and correct, on a timely basis, instances where controls are not being followed. Effect The institution COVID-19 policies and procedures were not followed, did not provide for full and open competition and suspension and debarment verification were not performed, as a result of that the USDE could be required to reimburse federal funds to the grantor for the expenditures incurred. Questioned Cost $201,543 Context Of the 142 disbursements, we selected 15 transactions for testing and noted the following instances of noncompliance: 1. Transactions were not conducted in a manner providing full and open competition 6 2. Suspension and Debarment verification were not performed 6 Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation We recommend the Institution to establish adequate procedures and controls, which shall consider, among others, the following: • Shall improve its internal controls over the filing and safeguarding of documents in order to easily identify and retrieve payment vouchers and all related supporting documentation. • Establish and implement written policies and procedures for all aspects of the Purchase administration, including controls for proper review and authorization during the processing and payment of program expenditures. Payment documents and related supporting documentation shall be thoroughly reviewed before they are recorded and processed for payment. All payment vouchers shall be properly authorized by the respective Institution’s representatives and shall be supported with all the required documentation. • Provide adequate training to employees regarding each program requirements and proper procurement and disbursement processing procedures, and as to the importance of safeguarding procedures and the proper coordination and communication for the retrieval of documents when needed.
Finding 2022-004
Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
Finding 2022-002
Cash Management Federal Program Name Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria According to the 2 CFR 200.305(b) non-federal entities must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Also, CRRSAA HEERF II and ARP HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Institutional Aid Portion, (a)(2), and (a)(3) funds should be disbursed within 3 calendar days of the drawdown from G5. Condition During our examination, we found the following instances on which the Institution did not disbursed funds in an expedite matter: Fund Instances Average of days late 84.425F 106 7 84.425L 5 31 Cause The delay in disbursements responds to several situations: remote work, lack of banking or information from suppliers, multiplicity of tasks under the responsibility of the Administration and Operations Director, which affected the dates of sending the payments. Effect As a result of this condition, the USDE may issue warnings and/or impose penalties to the Institution. Questioned Cost None Context During our examination, we noted one hundred six (106) instances from one hundred thirty-six (136) of the HEERF Institutional portion and five (5) instances from five (5) from Minority, on which the Institution did not disbursed funds within 3 calendar days of the drawdown from G5. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation The management of the Institution should reinforce its cash management procedures and internal controls to ensure the disbursement of funds in the required time frame after the drawdowns from G5. Views of Responsible Officials of the Auditee and Planned Corrective Actions The management of the Institution agrees with this finding. Please refer to the corrective action plan on pages 22-26.
Finding 2022-003
Procurement and Suspension and Debarment Federal Program Name Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria According to 2 CFR Section 200.319, all procurement transactions must be conducted in a manner providing full and open competition. According to 2 CFR Section 200.320 there are three types of procurement methods described in this section: informal procurement methods (for micro-purchases and simplified acquisitions); formal procurement methods (through sealed bids or proposals); and noncompetitive procurement methods. For any of these methods, the recipient or subrecipient must maintain and use documented procurement procedures. 2 CFR section 180.220(b)(1) non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000. Condition As part of our testing of fifteen (15) disbursements from institutional funds, we noted the following instances of non-compliance: 1. Six (6) transactions weren’t conducted in a manner providing full and open competition, no quotes nor quote analysis were available for examination. 2. Six (6) transactions Suspension and Debarment verification weren’t performed. Cause The exceptions mentioned above are the result of the failure to implement adequate internal control procedures, such as thorough managerial review, which should detect and correct, on a timely basis, instances where controls are not being followed. Effect The institution COVID-19 policies and procedures were not followed, did not provide for full and open competition and suspension and debarment verification were not performed, as a result of that the USDE could be required to reimburse federal funds to the grantor for the expenditures incurred. Questioned Cost $201,543 Context Of the 142 disbursements, we selected 15 transactions for testing and noted the following instances of noncompliance: 1. Transactions were not conducted in a manner providing full and open competition 6 2. Suspension and Debarment verification were not performed 6 Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation We recommend the Institution to establish adequate procedures and controls, which shall consider, among others, the following: • Shall improve its internal controls over the filing and safeguarding of documents in order to easily identify and retrieve payment vouchers and all related supporting documentation. • Establish and implement written policies and procedures for all aspects of the Purchase administration, including controls for proper review and authorization during the processing and payment of program expenditures. Payment documents and related supporting documentation shall be thoroughly reviewed before they are recorded and processed for payment. All payment vouchers shall be properly authorized by the respective Institution’s representatives and shall be supported with all the required documentation. • Provide adequate training to employees regarding each program requirements and proper procurement and disbursement processing procedures, and as to the importance of safeguarding procedures and the proper coordination and communication for the retrieval of documents when needed.
Finding 2022-004
Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
Finding 2022-004
Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
Finding 2022-005
Enrollment Reporting Federal Program Name Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR 685.309 (b)(2)(ii) states that unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that; a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition As part of our testing of twenty five (25) students who graduated and/or withdrew during 2022, we noted the following instances of non-compliance: 1. Two (2) students for which the Institution did not report to the National Student Loan Data System (NSLDS) the student status changes within the required 60 days’ period. Cause Late submissions were mainly caused due to lack of verification of information submitted to the National Student Clearinghouse (NSC) and they submitted it to NSLDS as is. The ordinary process was that the programmer created the file and sent it directly through the third-party clearinghouse. Errors in the file were not addressed. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of the Direct Loan Program and for USDE budgetary policy analysis. Questioned Cost None Context Of the two hundred and thirty-five (235) status changes for 2023, we selected twenty (25) students for testing and noted two (2) instances in which the Institution did not comply with the enrollment reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the timeframe in which the Institution submits the information to the NSC and reinforce its monitoring of NSC to ensure they comply with the agreed upon reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure enrollment status changes are timely and accurately reported to NSDLS.
Finding 2022-004
Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
Finding 2022-005
Enrollment Reporting Federal Program Name Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR 685.309 (b)(2)(ii) states that unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that; a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition As part of our testing of twenty five (25) students who graduated and/or withdrew during 2022, we noted the following instances of non-compliance: 1. Two (2) students for which the Institution did not report to the National Student Loan Data System (NSLDS) the student status changes within the required 60 days’ period. Cause Late submissions were mainly caused due to lack of verification of information submitted to the National Student Clearinghouse (NSC) and they submitted it to NSLDS as is. The ordinary process was that the programmer created the file and sent it directly through the third-party clearinghouse. Errors in the file were not addressed. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of the Direct Loan Program and for USDE budgetary policy analysis. Questioned Cost None Context Of the two hundred and thirty-five (235) status changes for 2023, we selected twenty (25) students for testing and noted two (2) instances in which the Institution did not comply with the enrollment reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the timeframe in which the Institution submits the information to the NSC and reinforce its monitoring of NSC to ensure they comply with the agreed upon reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure enrollment status changes are timely and accurately reported to NSDLS.
Finding 2022-004
Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
Finding 2022-005
Enrollment Reporting Federal Program Name Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR 685.309 (b)(2)(ii) states that unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that; a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition As part of our testing of twenty five (25) students who graduated and/or withdrew during 2022, we noted the following instances of non-compliance: 1. Two (2) students for which the Institution did not report to the National Student Loan Data System (NSLDS) the student status changes within the required 60 days’ period. Cause Late submissions were mainly caused due to lack of verification of information submitted to the National Student Clearinghouse (NSC) and they submitted it to NSLDS as is. The ordinary process was that the programmer created the file and sent it directly through the third-party clearinghouse. Errors in the file were not addressed. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of the Direct Loan Program and for USDE budgetary policy analysis. Questioned Cost None Context Of the two hundred and thirty-five (235) status changes for 2023, we selected twenty (25) students for testing and noted two (2) instances in which the Institution did not comply with the enrollment reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the timeframe in which the Institution submits the information to the NSC and reinforce its monitoring of NSC to ensure they comply with the agreed upon reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure enrollment status changes are timely and accurately reported to NSDLS.
Finding 2022-004
Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
Finding 2022-005
Enrollment Reporting Federal Program Name Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR 685.309 (b)(2)(ii) states that unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that; a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition As part of our testing of twenty five (25) students who graduated and/or withdrew during 2022, we noted the following instances of non-compliance: 1. Two (2) students for which the Institution did not report to the National Student Loan Data System (NSLDS) the student status changes within the required 60 days’ period. Cause Late submissions were mainly caused due to lack of verification of information submitted to the National Student Clearinghouse (NSC) and they submitted it to NSLDS as is. The ordinary process was that the programmer created the file and sent it directly through the third-party clearinghouse. Errors in the file were not addressed. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of the Direct Loan Program and for USDE budgetary policy analysis. Questioned Cost None Context Of the two hundred and thirty-five (235) status changes for 2023, we selected twenty (25) students for testing and noted two (2) instances in which the Institution did not comply with the enrollment reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the timeframe in which the Institution submits the information to the NSC and reinforce its monitoring of NSC to ensure they comply with the agreed upon reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure enrollment status changes are timely and accurately reported to NSDLS.
Finding 2022-002
Cash Management Federal Program Name Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria According to the 2 CFR 200.305(b) non-federal entities must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Also, CRRSAA HEERF II and ARP HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Institutional Aid Portion, (a)(2), and (a)(3) funds should be disbursed within 3 calendar days of the drawdown from G5. Condition During our examination, we found the following instances on which the Institution did not disbursed funds in an expedite matter: Fund Instances Average of days late 84.425F 106 7 84.425L 5 31 Cause The delay in disbursements responds to several situations: remote work, lack of banking or information from suppliers, multiplicity of tasks under the responsibility of the Administration and Operations Director, which affected the dates of sending the payments. Effect As a result of this condition, the USDE may issue warnings and/or impose penalties to the Institution. Questioned Cost None Context During our examination, we noted one hundred six (106) instances from one hundred thirty-six (136) of the HEERF Institutional portion and five (5) instances from five (5) from Minority, on which the Institution did not disbursed funds within 3 calendar days of the drawdown from G5. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation The management of the Institution should reinforce its cash management procedures and internal controls to ensure the disbursement of funds in the required time frame after the drawdowns from G5. Views of Responsible Officials of the Auditee and Planned Corrective Actions The management of the Institution agrees with this finding. Please refer to the corrective action plan on pages 22-26.
Finding 2022-003
Procurement and Suspension and Debarment Federal Program Name Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria According to 2 CFR Section 200.319, all procurement transactions must be conducted in a manner providing full and open competition. According to 2 CFR Section 200.320 there are three types of procurement methods described in this section: informal procurement methods (for micro-purchases and simplified acquisitions); formal procurement methods (through sealed bids or proposals); and noncompetitive procurement methods. For any of these methods, the recipient or subrecipient must maintain and use documented procurement procedures. 2 CFR section 180.220(b)(1) non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000. Condition As part of our testing of fifteen (15) disbursements from institutional funds, we noted the following instances of non-compliance: 1. Six (6) transactions weren’t conducted in a manner providing full and open competition, no quotes nor quote analysis were available for examination. 2. Six (6) transactions Suspension and Debarment verification weren’t performed. Cause The exceptions mentioned above are the result of the failure to implement adequate internal control procedures, such as thorough managerial review, which should detect and correct, on a timely basis, instances where controls are not being followed. Effect The institution COVID-19 policies and procedures were not followed, did not provide for full and open competition and suspension and debarment verification were not performed, as a result of that the USDE could be required to reimburse federal funds to the grantor for the expenditures incurred. Questioned Cost $201,543 Context Of the 142 disbursements, we selected 15 transactions for testing and noted the following instances of noncompliance: 1. Transactions were not conducted in a manner providing full and open competition 6 2. Suspension and Debarment verification were not performed 6 Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation We recommend the Institution to establish adequate procedures and controls, which shall consider, among others, the following: • Shall improve its internal controls over the filing and safeguarding of documents in order to easily identify and retrieve payment vouchers and all related supporting documentation. • Establish and implement written policies and procedures for all aspects of the Purchase administration, including controls for proper review and authorization during the processing and payment of program expenditures. Payment documents and related supporting documentation shall be thoroughly reviewed before they are recorded and processed for payment. All payment vouchers shall be properly authorized by the respective Institution’s representatives and shall be supported with all the required documentation. • Provide adequate training to employees regarding each program requirements and proper procurement and disbursement processing procedures, and as to the importance of safeguarding procedures and the proper coordination and communication for the retrieval of documents when needed.
Finding 2022-004
Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
Finding 2022-002
Cash Management Federal Program Name Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria According to the 2 CFR 200.305(b) non-federal entities must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Also, CRRSAA HEERF II and ARP HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Institutional Aid Portion, (a)(2), and (a)(3) funds should be disbursed within 3 calendar days of the drawdown from G5. Condition During our examination, we found the following instances on which the Institution did not disbursed funds in an expedite matter: Fund Instances Average of days late 84.425F 106 7 84.425L 5 31 Cause The delay in disbursements responds to several situations: remote work, lack of banking or information from suppliers, multiplicity of tasks under the responsibility of the Administration and Operations Director, which affected the dates of sending the payments. Effect As a result of this condition, the USDE may issue warnings and/or impose penalties to the Institution. Questioned Cost None Context During our examination, we noted one hundred six (106) instances from one hundred thirty-six (136) of the HEERF Institutional portion and five (5) instances from five (5) from Minority, on which the Institution did not disbursed funds within 3 calendar days of the drawdown from G5. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation The management of the Institution should reinforce its cash management procedures and internal controls to ensure the disbursement of funds in the required time frame after the drawdowns from G5. Views of Responsible Officials of the Auditee and Planned Corrective Actions The management of the Institution agrees with this finding. Please refer to the corrective action plan on pages 22-26.
Finding 2022-003
Procurement and Suspension and Debarment Federal Program Name Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria According to 2 CFR Section 200.319, all procurement transactions must be conducted in a manner providing full and open competition. According to 2 CFR Section 200.320 there are three types of procurement methods described in this section: informal procurement methods (for micro-purchases and simplified acquisitions); formal procurement methods (through sealed bids or proposals); and noncompetitive procurement methods. For any of these methods, the recipient or subrecipient must maintain and use documented procurement procedures. 2 CFR section 180.220(b)(1) non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000. Condition As part of our testing of fifteen (15) disbursements from institutional funds, we noted the following instances of non-compliance: 1. Six (6) transactions weren’t conducted in a manner providing full and open competition, no quotes nor quote analysis were available for examination. 2. Six (6) transactions Suspension and Debarment verification weren’t performed. Cause The exceptions mentioned above are the result of the failure to implement adequate internal control procedures, such as thorough managerial review, which should detect and correct, on a timely basis, instances where controls are not being followed. Effect The institution COVID-19 policies and procedures were not followed, did not provide for full and open competition and suspension and debarment verification were not performed, as a result of that the USDE could be required to reimburse federal funds to the grantor for the expenditures incurred. Questioned Cost $201,543 Context Of the 142 disbursements, we selected 15 transactions for testing and noted the following instances of noncompliance: 1. Transactions were not conducted in a manner providing full and open competition 6 2. Suspension and Debarment verification were not performed 6 Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation We recommend the Institution to establish adequate procedures and controls, which shall consider, among others, the following: • Shall improve its internal controls over the filing and safeguarding of documents in order to easily identify and retrieve payment vouchers and all related supporting documentation. • Establish and implement written policies and procedures for all aspects of the Purchase administration, including controls for proper review and authorization during the processing and payment of program expenditures. Payment documents and related supporting documentation shall be thoroughly reviewed before they are recorded and processed for payment. All payment vouchers shall be properly authorized by the respective Institution’s representatives and shall be supported with all the required documentation. • Provide adequate training to employees regarding each program requirements and proper procurement and disbursement processing procedures, and as to the importance of safeguarding procedures and the proper coordination and communication for the retrieval of documents when needed.
Finding 2022-004
Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.