Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. Condition: The physical inventory was not conducted as required. Context: In October 2021, the University conducted a physical inventory of all of its fixed assets which includes property acquired with federal funds. To facilitate the inventory, the University distributed a memo to all department heads detailing the procedures needed to conduct a physical inventory and instructed them to perform a physical inventory in their respective departments by December 1, 2021. During our audit, it was noted that the physical inventory was not completed by all departments. Based on the information provided by management there were 16 property items that were subject to inventory; however, because the inventory documentation provided did not cover all departments, only 1 property item was identified through the physical inventory. Cause: Although the University has procedures in place over the physical inventory of property, there was a lack of diligence in complying with the procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years results in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for the physical inventory of equipment and ensure all departments timely complete the physical inventory. Views of responsible officials: The HPU Fixed Asset Accountant, Federal Grant Project Investigator and Office of Sponsored Projects will work collaboratively to ensure that the physical inventory of all fixed assets which were acquired using federal funds are conducted and completed periodically. This physical inventory monitoring will be done at least, every two years. The team will work on getting all departments covered in the periodic inventory to confirm that the fixed asset listing is complete, updated and maintained.
Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual, corporation, association, unit of government, or legal entity, however organized) they are entering into a covered transaction with is not suspended or debarred by: (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: Verification that an entity was not suspended or debarred was not performed for one entity. Context: The University entered into covered transactions with six entities during the fiscal year. We selected a non-statistical sample of two entities for testing, noting verification that the entity was not suspended or debarred was not performed for one entity. We re-performed the verification and noted the entity did not have any exclusion records, indicating they were not suspended or debarred. Cause: Although the University has established policies and procedures in place over the procurement and suspension and debarment process, there was a lack of diligence in complying with obtaining or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process could result in noncompliance with the procurement and suspension and debarment requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the department to ensure that the required procedure for verification of Suspension and Debarment is consistently conducted and evidence of such procedure is maintained. The OSP Office will strengthen its policies and procedures so that the SAM screenshot for all covered transactions is complete and retained. The Principal Investigator should work collaboratively with the OSP to ensure that the documentation for suspension and debarment for vendors meeting this requirement is obtained and maintained. The Manager for Grants and Contracts will be sure to check the SAM.gov for suspension and debarment and will maintain the documentation. The Assistant VP of the Office of Sponsored Projects will review the documentation.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. Condition: The physical inventory was not conducted as required. Context: In October 2021, the University conducted a physical inventory of all of its fixed assets which includes property acquired with federal funds. To facilitate the inventory, the University distributed a memo to all department heads detailing the procedures needed to conduct a physical inventory and instructed them to perform a physical inventory in their respective departments by December 1, 2021. During our audit, it was noted that the physical inventory was not completed by all departments. Based on the information provided by management there were 16 property items that were subject to inventory; however, because the inventory documentation provided did not cover all departments, only 1 property item was identified through the physical inventory. Cause: Although the University has procedures in place over the physical inventory of property, there was a lack of diligence in complying with the procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years results in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for the physical inventory of equipment and ensure all departments timely complete the physical inventory. Views of responsible officials: The HPU Fixed Asset Accountant, Federal Grant Project Investigator and Office of Sponsored Projects will work collaboratively to ensure that the physical inventory of all fixed assets which were acquired using federal funds are conducted and completed periodically. This physical inventory monitoring will be done at least, every two years. The team will work on getting all departments covered in the periodic inventory to confirm that the fixed asset listing is complete, updated and maintained.
Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual, corporation, association, unit of government, or legal entity, however organized) they are entering into a covered transaction with is not suspended or debarred by: (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: Verification that an entity was not suspended or debarred was not performed for one entity. Context: The University entered into covered transactions with six entities during the fiscal year. We selected a non-statistical sample of two entities for testing, noting verification that the entity was not suspended or debarred was not performed for one entity. We re-performed the verification and noted the entity did not have any exclusion records, indicating they were not suspended or debarred. Cause: Although the University has established policies and procedures in place over the procurement and suspension and debarment process, there was a lack of diligence in complying with obtaining or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process could result in noncompliance with the procurement and suspension and debarment requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the department to ensure that the required procedure for verification of Suspension and Debarment is consistently conducted and evidence of such procedure is maintained. The OSP Office will strengthen its policies and procedures so that the SAM screenshot for all covered transactions is complete and retained. The Principal Investigator should work collaboratively with the OSP to ensure that the documentation for suspension and debarment for vendors meeting this requirement is obtained and maintained. The Manager for Grants and Contracts will be sure to check the SAM.gov for suspension and debarment and will maintain the documentation. The Assistant VP of the Office of Sponsored Projects will review the documentation.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. Condition: The physical inventory was not conducted as required. Context: In October 2021, the University conducted a physical inventory of all of its fixed assets which includes property acquired with federal funds. To facilitate the inventory, the University distributed a memo to all department heads detailing the procedures needed to conduct a physical inventory and instructed them to perform a physical inventory in their respective departments by December 1, 2021. During our audit, it was noted that the physical inventory was not completed by all departments. Based on the information provided by management there were 16 property items that were subject to inventory; however, because the inventory documentation provided did not cover all departments, only 1 property item was identified through the physical inventory. Cause: Although the University has procedures in place over the physical inventory of property, there was a lack of diligence in complying with the procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years results in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for the physical inventory of equipment and ensure all departments timely complete the physical inventory. Views of responsible officials: The HPU Fixed Asset Accountant, Federal Grant Project Investigator and Office of Sponsored Projects will work collaboratively to ensure that the physical inventory of all fixed assets which were acquired using federal funds are conducted and completed periodically. This physical inventory monitoring will be done at least, every two years. The team will work on getting all departments covered in the periodic inventory to confirm that the fixed asset listing is complete, updated and maintained.
Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual, corporation, association, unit of government, or legal entity, however organized) they are entering into a covered transaction with is not suspended or debarred by: (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: Verification that an entity was not suspended or debarred was not performed for one entity. Context: The University entered into covered transactions with six entities during the fiscal year. We selected a non-statistical sample of two entities for testing, noting verification that the entity was not suspended or debarred was not performed for one entity. We re-performed the verification and noted the entity did not have any exclusion records, indicating they were not suspended or debarred. Cause: Although the University has established policies and procedures in place over the procurement and suspension and debarment process, there was a lack of diligence in complying with obtaining or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process could result in noncompliance with the procurement and suspension and debarment requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the department to ensure that the required procedure for verification of Suspension and Debarment is consistently conducted and evidence of such procedure is maintained. The OSP Office will strengthen its policies and procedures so that the SAM screenshot for all covered transactions is complete and retained. The Principal Investigator should work collaboratively with the OSP to ensure that the documentation for suspension and debarment for vendors meeting this requirement is obtained and maintained. The Manager for Grants and Contracts will be sure to check the SAM.gov for suspension and debarment and will maintain the documentation. The Assistant VP of the Office of Sponsored Projects will review the documentation.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. Condition: The physical inventory was not conducted as required. Context: In October 2021, the University conducted a physical inventory of all of its fixed assets which includes property acquired with federal funds. To facilitate the inventory, the University distributed a memo to all department heads detailing the procedures needed to conduct a physical inventory and instructed them to perform a physical inventory in their respective departments by December 1, 2021. During our audit, it was noted that the physical inventory was not completed by all departments. Based on the information provided by management there were 16 property items that were subject to inventory; however, because the inventory documentation provided did not cover all departments, only 1 property item was identified through the physical inventory. Cause: Although the University has procedures in place over the physical inventory of property, there was a lack of diligence in complying with the procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years results in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for the physical inventory of equipment and ensure all departments timely complete the physical inventory. Views of responsible officials: The HPU Fixed Asset Accountant, Federal Grant Project Investigator and Office of Sponsored Projects will work collaboratively to ensure that the physical inventory of all fixed assets which were acquired using federal funds are conducted and completed periodically. This physical inventory monitoring will be done at least, every two years. The team will work on getting all departments covered in the periodic inventory to confirm that the fixed asset listing is complete, updated and maintained.
Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual, corporation, association, unit of government, or legal entity, however organized) they are entering into a covered transaction with is not suspended or debarred by: (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: Verification that an entity was not suspended or debarred was not performed for one entity. Context: The University entered into covered transactions with six entities during the fiscal year. We selected a non-statistical sample of two entities for testing, noting verification that the entity was not suspended or debarred was not performed for one entity. We re-performed the verification and noted the entity did not have any exclusion records, indicating they were not suspended or debarred. Cause: Although the University has established policies and procedures in place over the procurement and suspension and debarment process, there was a lack of diligence in complying with obtaining or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process could result in noncompliance with the procurement and suspension and debarment requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the department to ensure that the required procedure for verification of Suspension and Debarment is consistently conducted and evidence of such procedure is maintained. The OSP Office will strengthen its policies and procedures so that the SAM screenshot for all covered transactions is complete and retained. The Principal Investigator should work collaboratively with the OSP to ensure that the documentation for suspension and debarment for vendors meeting this requirement is obtained and maintained. The Manager for Grants and Contracts will be sure to check the SAM.gov for suspension and debarment and will maintain the documentation. The Assistant VP of the Office of Sponsored Projects will review the documentation.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. Condition: The physical inventory was not conducted as required. Context: In October 2021, the University conducted a physical inventory of all of its fixed assets which includes property acquired with federal funds. To facilitate the inventory, the University distributed a memo to all department heads detailing the procedures needed to conduct a physical inventory and instructed them to perform a physical inventory in their respective departments by December 1, 2021. During our audit, it was noted that the physical inventory was not completed by all departments. Based on the information provided by management there were 16 property items that were subject to inventory; however, because the inventory documentation provided did not cover all departments, only 1 property item was identified through the physical inventory. Cause: Although the University has procedures in place over the physical inventory of property, there was a lack of diligence in complying with the procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years results in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for the physical inventory of equipment and ensure all departments timely complete the physical inventory. Views of responsible officials: The HPU Fixed Asset Accountant, Federal Grant Project Investigator and Office of Sponsored Projects will work collaboratively to ensure that the physical inventory of all fixed assets which were acquired using federal funds are conducted and completed periodically. This physical inventory monitoring will be done at least, every two years. The team will work on getting all departments covered in the periodic inventory to confirm that the fixed asset listing is complete, updated and maintained.
Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual, corporation, association, unit of government, or legal entity, however organized) they are entering into a covered transaction with is not suspended or debarred by: (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: Verification that an entity was not suspended or debarred was not performed for one entity. Context: The University entered into covered transactions with six entities during the fiscal year. We selected a non-statistical sample of two entities for testing, noting verification that the entity was not suspended or debarred was not performed for one entity. We re-performed the verification and noted the entity did not have any exclusion records, indicating they were not suspended or debarred. Cause: Although the University has established policies and procedures in place over the procurement and suspension and debarment process, there was a lack of diligence in complying with obtaining or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process could result in noncompliance with the procurement and suspension and debarment requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the department to ensure that the required procedure for verification of Suspension and Debarment is consistently conducted and evidence of such procedure is maintained. The OSP Office will strengthen its policies and procedures so that the SAM screenshot for all covered transactions is complete and retained. The Principal Investigator should work collaboratively with the OSP to ensure that the documentation for suspension and debarment for vendors meeting this requirement is obtained and maintained. The Manager for Grants and Contracts will be sure to check the SAM.gov for suspension and debarment and will maintain the documentation. The Assistant VP of the Office of Sponsored Projects will review the documentation.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. Condition: The physical inventory was not conducted as required. Context: In October 2021, the University conducted a physical inventory of all of its fixed assets which includes property acquired with federal funds. To facilitate the inventory, the University distributed a memo to all department heads detailing the procedures needed to conduct a physical inventory and instructed them to perform a physical inventory in their respective departments by December 1, 2021. During our audit, it was noted that the physical inventory was not completed by all departments. Based on the information provided by management there were 16 property items that were subject to inventory; however, because the inventory documentation provided did not cover all departments, only 1 property item was identified through the physical inventory. Cause: Although the University has procedures in place over the physical inventory of property, there was a lack of diligence in complying with the procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years results in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for the physical inventory of equipment and ensure all departments timely complete the physical inventory. Views of responsible officials: The HPU Fixed Asset Accountant, Federal Grant Project Investigator and Office of Sponsored Projects will work collaboratively to ensure that the physical inventory of all fixed assets which were acquired using federal funds are conducted and completed periodically. This physical inventory monitoring will be done at least, every two years. The team will work on getting all departments covered in the periodic inventory to confirm that the fixed asset listing is complete, updated and maintained.
Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual, corporation, association, unit of government, or legal entity, however organized) they are entering into a covered transaction with is not suspended or debarred by: (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: Verification that an entity was not suspended or debarred was not performed for one entity. Context: The University entered into covered transactions with six entities during the fiscal year. We selected a non-statistical sample of two entities for testing, noting verification that the entity was not suspended or debarred was not performed for one entity. We re-performed the verification and noted the entity did not have any exclusion records, indicating they were not suspended or debarred. Cause: Although the University has established policies and procedures in place over the procurement and suspension and debarment process, there was a lack of diligence in complying with obtaining or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process could result in noncompliance with the procurement and suspension and debarment requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the department to ensure that the required procedure for verification of Suspension and Debarment is consistently conducted and evidence of such procedure is maintained. The OSP Office will strengthen its policies and procedures so that the SAM screenshot for all covered transactions is complete and retained. The Principal Investigator should work collaboratively with the OSP to ensure that the documentation for suspension and debarment for vendors meeting this requirement is obtained and maintained. The Manager for Grants and Contracts will be sure to check the SAM.gov for suspension and debarment and will maintain the documentation. The Assistant VP of the Office of Sponsored Projects will review the documentation.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. Condition: The physical inventory was not conducted as required. Context: In October 2021, the University conducted a physical inventory of all of its fixed assets which includes property acquired with federal funds. To facilitate the inventory, the University distributed a memo to all department heads detailing the procedures needed to conduct a physical inventory and instructed them to perform a physical inventory in their respective departments by December 1, 2021. During our audit, it was noted that the physical inventory was not completed by all departments. Based on the information provided by management there were 16 property items that were subject to inventory; however, because the inventory documentation provided did not cover all departments, only 1 property item was identified through the physical inventory. Cause: Although the University has procedures in place over the physical inventory of property, there was a lack of diligence in complying with the procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years results in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for the physical inventory of equipment and ensure all departments timely complete the physical inventory. Views of responsible officials: The HPU Fixed Asset Accountant, Federal Grant Project Investigator and Office of Sponsored Projects will work collaboratively to ensure that the physical inventory of all fixed assets which were acquired using federal funds are conducted and completed periodically. This physical inventory monitoring will be done at least, every two years. The team will work on getting all departments covered in the periodic inventory to confirm that the fixed asset listing is complete, updated and maintained.
Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual, corporation, association, unit of government, or legal entity, however organized) they are entering into a covered transaction with is not suspended or debarred by: (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: Verification that an entity was not suspended or debarred was not performed for one entity. Context: The University entered into covered transactions with six entities during the fiscal year. We selected a non-statistical sample of two entities for testing, noting verification that the entity was not suspended or debarred was not performed for one entity. We re-performed the verification and noted the entity did not have any exclusion records, indicating they were not suspended or debarred. Cause: Although the University has established policies and procedures in place over the procurement and suspension and debarment process, there was a lack of diligence in complying with obtaining or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process could result in noncompliance with the procurement and suspension and debarment requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the department to ensure that the required procedure for verification of Suspension and Debarment is consistently conducted and evidence of such procedure is maintained. The OSP Office will strengthen its policies and procedures so that the SAM screenshot for all covered transactions is complete and retained. The Principal Investigator should work collaboratively with the OSP to ensure that the documentation for suspension and debarment for vendors meeting this requirement is obtained and maintained. The Manager for Grants and Contracts will be sure to check the SAM.gov for suspension and debarment and will maintain the documentation. The Assistant VP of the Office of Sponsored Projects will review the documentation.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. Condition: The physical inventory was not conducted as required. Context: In October 2021, the University conducted a physical inventory of all of its fixed assets which includes property acquired with federal funds. To facilitate the inventory, the University distributed a memo to all department heads detailing the procedures needed to conduct a physical inventory and instructed them to perform a physical inventory in their respective departments by December 1, 2021. During our audit, it was noted that the physical inventory was not completed by all departments. Based on the information provided by management there were 16 property items that were subject to inventory; however, because the inventory documentation provided did not cover all departments, only 1 property item was identified through the physical inventory. Cause: Although the University has procedures in place over the physical inventory of property, there was a lack of diligence in complying with the procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years results in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for the physical inventory of equipment and ensure all departments timely complete the physical inventory. Views of responsible officials: The HPU Fixed Asset Accountant, Federal Grant Project Investigator and Office of Sponsored Projects will work collaboratively to ensure that the physical inventory of all fixed assets which were acquired using federal funds are conducted and completed periodically. This physical inventory monitoring will be done at least, every two years. The team will work on getting all departments covered in the periodic inventory to confirm that the fixed asset listing is complete, updated and maintained.
Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual, corporation, association, unit of government, or legal entity, however organized) they are entering into a covered transaction with is not suspended or debarred by: (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: Verification that an entity was not suspended or debarred was not performed for one entity. Context: The University entered into covered transactions with six entities during the fiscal year. We selected a non-statistical sample of two entities for testing, noting verification that the entity was not suspended or debarred was not performed for one entity. We re-performed the verification and noted the entity did not have any exclusion records, indicating they were not suspended or debarred. Cause: Although the University has established policies and procedures in place over the procurement and suspension and debarment process, there was a lack of diligence in complying with obtaining or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process could result in noncompliance with the procurement and suspension and debarment requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the department to ensure that the required procedure for verification of Suspension and Debarment is consistently conducted and evidence of such procedure is maintained. The OSP Office will strengthen its policies and procedures so that the SAM screenshot for all covered transactions is complete and retained. The Principal Investigator should work collaboratively with the OSP to ensure that the documentation for suspension and debarment for vendors meeting this requirement is obtained and maintained. The Manager for Grants and Contracts will be sure to check the SAM.gov for suspension and debarment and will maintain the documentation. The Assistant VP of the Office of Sponsored Projects will review the documentation.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.303(a) requires the non-Federal entity to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing of the HEERF Program, for non-student related payroll and non-payroll expenditures, management did not provide sufficient support for justification for the allocation of these costs to the program. Consequently, we were unable to audit the allowability of these costs. Additionally, for expenditures related to financial aid grants to students, there was no independent review to ensure allowability of costs prior to disbursement. Context: For the non-student payroll-related expenditures, management indicated that department heads and the University?s Office of Sponsored Projects (OSP) held discussions to determine estimates of the time each departments? employees spent on allowable COVID-related activities; however, the discussion related to the rationale, basis and final allocations were not consistently documented. We selected a non-statistical sample of 20 payroll items representing $90,009 of which 17 items representing $75,564 had no documentation of the justification supporting the allocation. Total payroll expenditures for the program were $3,890,213. For non-student non-payroll expenditures, management did not consistently document the justification supporting the allocation of costs to the program. We selected a non-statistical sample of 15 items representing $659,611 of which 5 items representing $76,035 did not have documentation of the justification supporting the allocation. Total non-student non-payroll expenditures for the program were $2,899,106. For the financial aid grants to students, we noted that one person prepares the listing for disbursement with no independent review. Total financial aid grants to students was $4,301,887. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, documented policies and procedures to administer the program were not developed and therefore not all supporting justifications were documented. For financial aid grants to students, management did not design a control to allow to provide for an independent review of allowability prior to disbursement. Effect: Expenditures for non-student related payroll, non-payroll items and financial aid grants to students could be disbursed for unallowable costs. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2021-002. Recommendations: The HEERF Program has ended for the University. We recommend that should similar programs become available in the future, that management develop documented policies and procedures to administer the program and that management maintain documentation to evidence the internal controls. Views of responsible officials: The HPU Financial Aid Office works hard to follow all federal regulations and guidance mandated for the Title IV Federal Student Aid programs. In regards to the distribution of the Federal HEERF fund to HPU students, the HPU Financial Aid Director relied on reports from the SIS (Banner system), Institutional Research, and Accounts Receivable to determine students eligible for HEERF funds. The HPU Financial Aid Office and Office of Sponsored Projects worked hard, and diligently, to award funds to students and expend Institution portion based on the regulations that were provided at the time and not violating the intent of the program, as evidenced by there not being any non-compliance over allowability of costs charged to Federal HEERF fund. For future awards, the Principal Investigator with the assistance of the Office of Sponsored Projects will review diligently the expenditure to be sure the expenditures are within the allowability and terms and conditions of the federal awards. Both offices will work collaboratively so that the internal controls over allowability are strengthened and that the documentation will be strongly implemented and retained. For future programs, the HPU Financial Aid will work to strategically plan, organize, and disburse funds to students and expend Institution funds within the requirements mandated by the United States Department of Education, including strengthening our internal controls over compliance, and increasing the documentation and maintenance of documentation over our existing internal controls for compliance.
Criteria: There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion (Quarterly Student Report); 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Institutional Reports), as applicable; and 3) the annual report (Annual Report). The Coronavirus Aid, Relief, and Economic Security (CARES) Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While American Rescue Plan (ARP) does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Per the Form Instructions included on the ?Quarterly Budget and Expenditure Reporting for HEERF I, II, and III (a)(1) Institutional Portion, (a)(2), and (a)(3), if applicable? form, the completed form must be conspicuously posted on the institution?s primary website no later than 10 days after the end of each calendar quarter. Additionally, the Form Instructions include that reports must be maintained for at least three years after the submission of the final report. Condition: Management did not provide sufficient documentation to support the data included in the Annual Report, Quarterly Institutional Reports and Quarterly Student Reports. In addition, for one quarter, a Quarterly Institutional Report and a Quarterly Student Report was not retained on the University?s website. Context: Management provided documentation to support the information included in the reports; however, in several instances, the information provided either did not agree to the data included in the reports or it was unclear as to how the information supported the reports. In addition, the Quarterly Institutional Report and Quarterly Student Report for the quarter ended September 30, 2021 was prepared and posted on the University?s website; however, the reports were erroneously removed. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, documented policies and procedures over reporting for the program were not developed. Additionally, due to staff turnover, information was not retained in a manner that allowed it to be easily retrieved and compiled in a manner supporting the reports. Effect: The reports that were completed could contain inaccurate or incomplete data. In addition, the University was not compliant with the requirement to maintain the reports on the University?s website. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2021-003. Recommendations: As the HEERF Program has ended for the University, we recommend that should similar programs become available in the future, that management develop documented policies and procedures to administer the program and that management maintain documentation to evidence the internal controls. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) and Office of Financial Aid work to follow all federal reporting regulations and guidance mandated for the Federal grant & contract programs. For future programs, the Institutional Research, the Office of Sponsored Projects and the Financial Aid Office will generate the reports and will implement layers of review procedure to ensure that the reports are accurate, complete, submitted timely, and if needed, posted in HPU website. For the Institution portion, the Manager for Grants and Contracts will prepare the grant report and this report will be reviewed by the Assistant VP for OSP. For the student portion the periodic reports will be prepared by the staff of the Office of Financial Aid and will be reviewed by the Director of the Financial Aid office. The Business Office will perform a high-level independent review for completeness and accuracy. Finally, moving forward, all the files and documents that support the grant report will be retained.
Criteria: 2 CFR 200.303(a) requires the non-Federal entity to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing of the HEERF Program, for non-student related payroll and non-payroll expenditures, management did not provide sufficient support for justification for the allocation of these costs to the program. Consequently, we were unable to audit the allowability of these costs. Additionally, for expenditures related to financial aid grants to students, there was no independent review to ensure allowability of costs prior to disbursement. Context: For the non-student payroll-related expenditures, management indicated that department heads and the University?s Office of Sponsored Projects (OSP) held discussions to determine estimates of the time each departments? employees spent on allowable COVID-related activities; however, the discussion related to the rationale, basis and final allocations were not consistently documented. We selected a non-statistical sample of 20 payroll items representing $90,009 of which 17 items representing $75,564 had no documentation of the justification supporting the allocation. Total payroll expenditures for the program were $3,890,213. For non-student non-payroll expenditures, management did not consistently document the justification supporting the allocation of costs to the program. We selected a non-statistical sample of 15 items representing $659,611 of which 5 items representing $76,035 did not have documentation of the justification supporting the allocation. Total non-student non-payroll expenditures for the program were $2,899,106. For the financial aid grants to students, we noted that one person prepares the listing for disbursement with no independent review. Total financial aid grants to students was $4,301,887. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, documented policies and procedures to administer the program were not developed and therefore not all supporting justifications were documented. For financial aid grants to students, management did not design a control to allow to provide for an independent review of allowability prior to disbursement. Effect: Expenditures for non-student related payroll, non-payroll items and financial aid grants to students could be disbursed for unallowable costs. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2021-002. Recommendations: The HEERF Program has ended for the University. We recommend that should similar programs become available in the future, that management develop documented policies and procedures to administer the program and that management maintain documentation to evidence the internal controls. Views of responsible officials: The HPU Financial Aid Office works hard to follow all federal regulations and guidance mandated for the Title IV Federal Student Aid programs. In regards to the distribution of the Federal HEERF fund to HPU students, the HPU Financial Aid Director relied on reports from the SIS (Banner system), Institutional Research, and Accounts Receivable to determine students eligible for HEERF funds. The HPU Financial Aid Office and Office of Sponsored Projects worked hard, and diligently, to award funds to students and expend Institution portion based on the regulations that were provided at the time and not violating the intent of the program, as evidenced by there not being any non-compliance over allowability of costs charged to Federal HEERF fund. For future awards, the Principal Investigator with the assistance of the Office of Sponsored Projects will review diligently the expenditure to be sure the expenditures are within the allowability and terms and conditions of the federal awards. Both offices will work collaboratively so that the internal controls over allowability are strengthened and that the documentation will be strongly implemented and retained. For future programs, the HPU Financial Aid will work to strategically plan, organize, and disburse funds to students and expend Institution funds within the requirements mandated by the United States Department of Education, including strengthening our internal controls over compliance, and increasing the documentation and maintenance of documentation over our existing internal controls for compliance.
Criteria: There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion (Quarterly Student Report); 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Institutional Reports), as applicable; and 3) the annual report (Annual Report). The Coronavirus Aid, Relief, and Economic Security (CARES) Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While American Rescue Plan (ARP) does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Per the Form Instructions included on the ?Quarterly Budget and Expenditure Reporting for HEERF I, II, and III (a)(1) Institutional Portion, (a)(2), and (a)(3), if applicable? form, the completed form must be conspicuously posted on the institution?s primary website no later than 10 days after the end of each calendar quarter. Additionally, the Form Instructions include that reports must be maintained for at least three years after the submission of the final report. Condition: Management did not provide sufficient documentation to support the data included in the Annual Report, Quarterly Institutional Reports and Quarterly Student Reports. In addition, for one quarter, a Quarterly Institutional Report and a Quarterly Student Report was not retained on the University?s website. Context: Management provided documentation to support the information included in the reports; however, in several instances, the information provided either did not agree to the data included in the reports or it was unclear as to how the information supported the reports. In addition, the Quarterly Institutional Report and Quarterly Student Report for the quarter ended September 30, 2021 was prepared and posted on the University?s website; however, the reports were erroneously removed. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, documented policies and procedures over reporting for the program were not developed. Additionally, due to staff turnover, information was not retained in a manner that allowed it to be easily retrieved and compiled in a manner supporting the reports. Effect: The reports that were completed could contain inaccurate or incomplete data. In addition, the University was not compliant with the requirement to maintain the reports on the University?s website. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2021-003. Recommendations: As the HEERF Program has ended for the University, we recommend that should similar programs become available in the future, that management develop documented policies and procedures to administer the program and that management maintain documentation to evidence the internal controls. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) and Office of Financial Aid work to follow all federal reporting regulations and guidance mandated for the Federal grant & contract programs. For future programs, the Institutional Research, the Office of Sponsored Projects and the Financial Aid Office will generate the reports and will implement layers of review procedure to ensure that the reports are accurate, complete, submitted timely, and if needed, posted in HPU website. For the Institution portion, the Manager for Grants and Contracts will prepare the grant report and this report will be reviewed by the Assistant VP for OSP. For the student portion the periodic reports will be prepared by the staff of the Office of Financial Aid and will be reviewed by the Director of the Financial Aid office. The Business Office will perform a high-level independent review for completeness and accuracy. Finally, moving forward, all the files and documents that support the grant report will be retained.
Criteria: 2 CFR 200.303(a) requires the non-Federal entity to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing of the HEERF Program, for non-student related payroll and non-payroll expenditures, management did not provide sufficient support for justification for the allocation of these costs to the program. Consequently, we were unable to audit the allowability of these costs. Additionally, for expenditures related to financial aid grants to students, there was no independent review to ensure allowability of costs prior to disbursement. Context: For the non-student payroll-related expenditures, management indicated that department heads and the University?s Office of Sponsored Projects (OSP) held discussions to determine estimates of the time each departments? employees spent on allowable COVID-related activities; however, the discussion related to the rationale, basis and final allocations were not consistently documented. We selected a non-statistical sample of 20 payroll items representing $90,009 of which 17 items representing $75,564 had no documentation of the justification supporting the allocation. Total payroll expenditures for the program were $3,890,213. For non-student non-payroll expenditures, management did not consistently document the justification supporting the allocation of costs to the program. We selected a non-statistical sample of 15 items representing $659,611 of which 5 items representing $76,035 did not have documentation of the justification supporting the allocation. Total non-student non-payroll expenditures for the program were $2,899,106. For the financial aid grants to students, we noted that one person prepares the listing for disbursement with no independent review. Total financial aid grants to students was $4,301,887. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, documented policies and procedures to administer the program were not developed and therefore not all supporting justifications were documented. For financial aid grants to students, management did not design a control to allow to provide for an independent review of allowability prior to disbursement. Effect: Expenditures for non-student related payroll, non-payroll items and financial aid grants to students could be disbursed for unallowable costs. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2021-002. Recommendations: The HEERF Program has ended for the University. We recommend that should similar programs become available in the future, that management develop documented policies and procedures to administer the program and that management maintain documentation to evidence the internal controls. Views of responsible officials: The HPU Financial Aid Office works hard to follow all federal regulations and guidance mandated for the Title IV Federal Student Aid programs. In regards to the distribution of the Federal HEERF fund to HPU students, the HPU Financial Aid Director relied on reports from the SIS (Banner system), Institutional Research, and Accounts Receivable to determine students eligible for HEERF funds. The HPU Financial Aid Office and Office of Sponsored Projects worked hard, and diligently, to award funds to students and expend Institution portion based on the regulations that were provided at the time and not violating the intent of the program, as evidenced by there not being any non-compliance over allowability of costs charged to Federal HEERF fund. For future awards, the Principal Investigator with the assistance of the Office of Sponsored Projects will review diligently the expenditure to be sure the expenditures are within the allowability and terms and conditions of the federal awards. Both offices will work collaboratively so that the internal controls over allowability are strengthened and that the documentation will be strongly implemented and retained. For future programs, the HPU Financial Aid will work to strategically plan, organize, and disburse funds to students and expend Institution funds within the requirements mandated by the United States Department of Education, including strengthening our internal controls over compliance, and increasing the documentation and maintenance of documentation over our existing internal controls for compliance.
Criteria: There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion (Quarterly Student Report); 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Institutional Reports), as applicable; and 3) the annual report (Annual Report). The Coronavirus Aid, Relief, and Economic Security (CARES) Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While American Rescue Plan (ARP) does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Per the Form Instructions included on the ?Quarterly Budget and Expenditure Reporting for HEERF I, II, and III (a)(1) Institutional Portion, (a)(2), and (a)(3), if applicable? form, the completed form must be conspicuously posted on the institution?s primary website no later than 10 days after the end of each calendar quarter. Additionally, the Form Instructions include that reports must be maintained for at least three years after the submission of the final report. Condition: Management did not provide sufficient documentation to support the data included in the Annual Report, Quarterly Institutional Reports and Quarterly Student Reports. In addition, for one quarter, a Quarterly Institutional Report and a Quarterly Student Report was not retained on the University?s website. Context: Management provided documentation to support the information included in the reports; however, in several instances, the information provided either did not agree to the data included in the reports or it was unclear as to how the information supported the reports. In addition, the Quarterly Institutional Report and Quarterly Student Report for the quarter ended September 30, 2021 was prepared and posted on the University?s website; however, the reports were erroneously removed. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, documented policies and procedures over reporting for the program were not developed. Additionally, due to staff turnover, information was not retained in a manner that allowed it to be easily retrieved and compiled in a manner supporting the reports. Effect: The reports that were completed could contain inaccurate or incomplete data. In addition, the University was not compliant with the requirement to maintain the reports on the University?s website. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2021-003. Recommendations: As the HEERF Program has ended for the University, we recommend that should similar programs become available in the future, that management develop documented policies and procedures to administer the program and that management maintain documentation to evidence the internal controls. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) and Office of Financial Aid work to follow all federal reporting regulations and guidance mandated for the Federal grant & contract programs. For future programs, the Institutional Research, the Office of Sponsored Projects and the Financial Aid Office will generate the reports and will implement layers of review procedure to ensure that the reports are accurate, complete, submitted timely, and if needed, posted in HPU website. For the Institution portion, the Manager for Grants and Contracts will prepare the grant report and this report will be reviewed by the Assistant VP for OSP. For the student portion the periodic reports will be prepared by the staff of the Office of Financial Aid and will be reviewed by the Director of the Financial Aid office. The Business Office will perform a high-level independent review for completeness and accuracy. Finally, moving forward, all the files and documents that support the grant report will be retained.
Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards of that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. The VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements above the micro-purchase threshold. Condition: Procurement documentation for two vendors were not prepared and/or retained to support compliance with the regulations above and the University?s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of twelve vendors with total expenditures greater than the micro-purchase threshold during the fiscal year. For two selections, the University?s VJF documenting and approving the procurement was not prepared. Additionally, one small purchase selection did not include quotes from more than one vendor. Cause: Although the University has established policies and procedures in place over the procurement process, there was a lack of diligence in complying with and/or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will work on strengthening its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained. The Vendor Justification Form will be strictly enforced for purchases meeting the specific threshold amount when procuring using federal funds.
Criteria: 2 CFR 200.303(a) requires the non-Federal entity to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing of the HEERF Program, for non-student related payroll and non-payroll expenditures, management did not provide sufficient support for justification for the allocation of these costs to the program. Consequently, we were unable to audit the allowability of these costs. Additionally, for expenditures related to financial aid grants to students, there was no independent review to ensure allowability of costs prior to disbursement. Context: For the non-student payroll-related expenditures, management indicated that department heads and the University?s Office of Sponsored Projects (OSP) held discussions to determine estimates of the time each departments? employees spent on allowable COVID-related activities; however, the discussion related to the rationale, basis and final allocations were not consistently documented. We selected a non-statistical sample of 20 payroll items representing $90,009 of which 17 items representing $75,564 had no documentation of the justification supporting the allocation. Total payroll expenditures for the program were $3,890,213. For non-student non-payroll expenditures, management did not consistently document the justification supporting the allocation of costs to the program. We selected a non-statistical sample of 15 items representing $659,611 of which 5 items representing $76,035 did not have documentation of the justification supporting the allocation. Total non-student non-payroll expenditures for the program were $2,899,106. For the financial aid grants to students, we noted that one person prepares the listing for disbursement with no independent review. Total financial aid grants to students was $4,301,887. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, documented policies and procedures to administer the program were not developed and therefore not all supporting justifications were documented. For financial aid grants to students, management did not design a control to allow to provide for an independent review of allowability prior to disbursement. Effect: Expenditures for non-student related payroll, non-payroll items and financial aid grants to students could be disbursed for unallowable costs. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2021-002. Recommendations: The HEERF Program has ended for the University. We recommend that should similar programs become available in the future, that management develop documented policies and procedures to administer the program and that management maintain documentation to evidence the internal controls. Views of responsible officials: The HPU Financial Aid Office works hard to follow all federal regulations and guidance mandated for the Title IV Federal Student Aid programs. In regards to the distribution of the Federal HEERF fund to HPU students, the HPU Financial Aid Director relied on reports from the SIS (Banner system), Institutional Research, and Accounts Receivable to determine students eligible for HEERF funds. The HPU Financial Aid Office and Office of Sponsored Projects worked hard, and diligently, to award funds to students and expend Institution portion based on the regulations that were provided at the time and not violating the intent of the program, as evidenced by there not being any non-compliance over allowability of costs charged to Federal HEERF fund. For future awards, the Principal Investigator with the assistance of the Office of Sponsored Projects will review diligently the expenditure to be sure the expenditures are within the allowability and terms and conditions of the federal awards. Both offices will work collaboratively so that the internal controls over allowability are strengthened and that the documentation will be strongly implemented and retained. For future programs, the HPU Financial Aid will work to strategically plan, organize, and disburse funds to students and expend Institution funds within the requirements mandated by the United States Department of Education, including strengthening our internal controls over compliance, and increasing the documentation and maintenance of documentation over our existing internal controls for compliance.
Criteria: There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion (Quarterly Student Report); 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Institutional Reports), as applicable; and 3) the annual report (Annual Report). The Coronavirus Aid, Relief, and Economic Security (CARES) Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While American Rescue Plan (ARP) does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Per the Form Instructions included on the ?Quarterly Budget and Expenditure Reporting for HEERF I, II, and III (a)(1) Institutional Portion, (a)(2), and (a)(3), if applicable? form, the completed form must be conspicuously posted on the institution?s primary website no later than 10 days after the end of each calendar quarter. Additionally, the Form Instructions include that reports must be maintained for at least three years after the submission of the final report. Condition: Management did not provide sufficient documentation to support the data included in the Annual Report, Quarterly Institutional Reports and Quarterly Student Reports. In addition, for one quarter, a Quarterly Institutional Report and a Quarterly Student Report was not retained on the University?s website. Context: Management provided documentation to support the information included in the reports; however, in several instances, the information provided either did not agree to the data included in the reports or it was unclear as to how the information supported the reports. In addition, the Quarterly Institutional Report and Quarterly Student Report for the quarter ended September 30, 2021 was prepared and posted on the University?s website; however, the reports were erroneously removed. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, documented policies and procedures over reporting for the program were not developed. Additionally, due to staff turnover, information was not retained in a manner that allowed it to be easily retrieved and compiled in a manner supporting the reports. Effect: The reports that were completed could contain inaccurate or incomplete data. In addition, the University was not compliant with the requirement to maintain the reports on the University?s website. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2021-003. Recommendations: As the HEERF Program has ended for the University, we recommend that should similar programs become available in the future, that management develop documented policies and procedures to administer the program and that management maintain documentation to evidence the internal controls. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) and Office of Financial Aid work to follow all federal reporting regulations and guidance mandated for the Federal grant & contract programs. For future programs, the Institutional Research, the Office of Sponsored Projects and the Financial Aid Office will generate the reports and will implement layers of review procedure to ensure that the reports are accurate, complete, submitted timely, and if needed, posted in HPU website. For the Institution portion, the Manager for Grants and Contracts will prepare the grant report and this report will be reviewed by the Assistant VP for OSP. For the student portion the periodic reports will be prepared by the staff of the Office of Financial Aid and will be reviewed by the Director of the Financial Aid office. The Business Office will perform a high-level independent review for completeness and accuracy. Finally, moving forward, all the files and documents that support the grant report will be retained.
Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards of that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. The VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements above the micro-purchase threshold. Condition: Procurement documentation for two vendors were not prepared and/or retained to support compliance with the regulations above and the University?s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of twelve vendors with total expenditures greater than the micro-purchase threshold during the fiscal year. For two selections, the University?s VJF documenting and approving the procurement was not prepared. Additionally, one small purchase selection did not include quotes from more than one vendor. Cause: Although the University has established policies and procedures in place over the procurement process, there was a lack of diligence in complying with and/or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will work on strengthening its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained. The Vendor Justification Form will be strictly enforced for purchases meeting the specific threshold amount when procuring using federal funds.
Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. Condition: The physical inventory was not conducted as required. Context: In October 2021, the University conducted a physical inventory of all of its fixed assets which includes property acquired with federal funds. To facilitate the inventory, the University distributed a memo to all department heads detailing the procedures needed to conduct a physical inventory and instructed them to perform a physical inventory in their respective departments by December 1, 2021. During our audit, it was noted that the physical inventory was not completed by all departments. Based on the information provided by management there were 16 property items that were subject to inventory; however, because the inventory documentation provided did not cover all departments, only 1 property item was identified through the physical inventory. Cause: Although the University has procedures in place over the physical inventory of property, there was a lack of diligence in complying with the procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years results in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for the physical inventory of equipment and ensure all departments timely complete the physical inventory. Views of responsible officials: The HPU Fixed Asset Accountant, Federal Grant Project Investigator and Office of Sponsored Projects will work collaboratively to ensure that the physical inventory of all fixed assets which were acquired using federal funds are conducted and completed periodically. This physical inventory monitoring will be done at least, every two years. The team will work on getting all departments covered in the periodic inventory to confirm that the fixed asset listing is complete, updated and maintained.
Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual, corporation, association, unit of government, or legal entity, however organized) they are entering into a covered transaction with is not suspended or debarred by: (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: Verification that an entity was not suspended or debarred was not performed for one entity. Context: The University entered into covered transactions with six entities during the fiscal year. We selected a non-statistical sample of two entities for testing, noting verification that the entity was not suspended or debarred was not performed for one entity. We re-performed the verification and noted the entity did not have any exclusion records, indicating they were not suspended or debarred. Cause: Although the University has established policies and procedures in place over the procurement and suspension and debarment process, there was a lack of diligence in complying with obtaining or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process could result in noncompliance with the procurement and suspension and debarment requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the department to ensure that the required procedure for verification of Suspension and Debarment is consistently conducted and evidence of such procedure is maintained. The OSP Office will strengthen its policies and procedures so that the SAM screenshot for all covered transactions is complete and retained. The Principal Investigator should work collaboratively with the OSP to ensure that the documentation for suspension and debarment for vendors meeting this requirement is obtained and maintained. The Manager for Grants and Contracts will be sure to check the SAM.gov for suspension and debarment and will maintain the documentation. The Assistant VP of the Office of Sponsored Projects will review the documentation.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. Condition: The physical inventory was not conducted as required. Context: In October 2021, the University conducted a physical inventory of all of its fixed assets which includes property acquired with federal funds. To facilitate the inventory, the University distributed a memo to all department heads detailing the procedures needed to conduct a physical inventory and instructed them to perform a physical inventory in their respective departments by December 1, 2021. During our audit, it was noted that the physical inventory was not completed by all departments. Based on the information provided by management there were 16 property items that were subject to inventory; however, because the inventory documentation provided did not cover all departments, only 1 property item was identified through the physical inventory. Cause: Although the University has procedures in place over the physical inventory of property, there was a lack of diligence in complying with the procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years results in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for the physical inventory of equipment and ensure all departments timely complete the physical inventory. Views of responsible officials: The HPU Fixed Asset Accountant, Federal Grant Project Investigator and Office of Sponsored Projects will work collaboratively to ensure that the physical inventory of all fixed assets which were acquired using federal funds are conducted and completed periodically. This physical inventory monitoring will be done at least, every two years. The team will work on getting all departments covered in the periodic inventory to confirm that the fixed asset listing is complete, updated and maintained.
Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual, corporation, association, unit of government, or legal entity, however organized) they are entering into a covered transaction with is not suspended or debarred by: (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: Verification that an entity was not suspended or debarred was not performed for one entity. Context: The University entered into covered transactions with six entities during the fiscal year. We selected a non-statistical sample of two entities for testing, noting verification that the entity was not suspended or debarred was not performed for one entity. We re-performed the verification and noted the entity did not have any exclusion records, indicating they were not suspended or debarred. Cause: Although the University has established policies and procedures in place over the procurement and suspension and debarment process, there was a lack of diligence in complying with obtaining or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process could result in noncompliance with the procurement and suspension and debarment requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the department to ensure that the required procedure for verification of Suspension and Debarment is consistently conducted and evidence of such procedure is maintained. The OSP Office will strengthen its policies and procedures so that the SAM screenshot for all covered transactions is complete and retained. The Principal Investigator should work collaboratively with the OSP to ensure that the documentation for suspension and debarment for vendors meeting this requirement is obtained and maintained. The Manager for Grants and Contracts will be sure to check the SAM.gov for suspension and debarment and will maintain the documentation. The Assistant VP of the Office of Sponsored Projects will review the documentation.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. Condition: The physical inventory was not conducted as required. Context: In October 2021, the University conducted a physical inventory of all of its fixed assets which includes property acquired with federal funds. To facilitate the inventory, the University distributed a memo to all department heads detailing the procedures needed to conduct a physical inventory and instructed them to perform a physical inventory in their respective departments by December 1, 2021. During our audit, it was noted that the physical inventory was not completed by all departments. Based on the information provided by management there were 16 property items that were subject to inventory; however, because the inventory documentation provided did not cover all departments, only 1 property item was identified through the physical inventory. Cause: Although the University has procedures in place over the physical inventory of property, there was a lack of diligence in complying with the procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years results in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for the physical inventory of equipment and ensure all departments timely complete the physical inventory. Views of responsible officials: The HPU Fixed Asset Accountant, Federal Grant Project Investigator and Office of Sponsored Projects will work collaboratively to ensure that the physical inventory of all fixed assets which were acquired using federal funds are conducted and completed periodically. This physical inventory monitoring will be done at least, every two years. The team will work on getting all departments covered in the periodic inventory to confirm that the fixed asset listing is complete, updated and maintained.
Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual, corporation, association, unit of government, or legal entity, however organized) they are entering into a covered transaction with is not suspended or debarred by: (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: Verification that an entity was not suspended or debarred was not performed for one entity. Context: The University entered into covered transactions with six entities during the fiscal year. We selected a non-statistical sample of two entities for testing, noting verification that the entity was not suspended or debarred was not performed for one entity. We re-performed the verification and noted the entity did not have any exclusion records, indicating they were not suspended or debarred. Cause: Although the University has established policies and procedures in place over the procurement and suspension and debarment process, there was a lack of diligence in complying with obtaining or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process could result in noncompliance with the procurement and suspension and debarment requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the department to ensure that the required procedure for verification of Suspension and Debarment is consistently conducted and evidence of such procedure is maintained. The OSP Office will strengthen its policies and procedures so that the SAM screenshot for all covered transactions is complete and retained. The Principal Investigator should work collaboratively with the OSP to ensure that the documentation for suspension and debarment for vendors meeting this requirement is obtained and maintained. The Manager for Grants and Contracts will be sure to check the SAM.gov for suspension and debarment and will maintain the documentation. The Assistant VP of the Office of Sponsored Projects will review the documentation.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. Condition: The physical inventory was not conducted as required. Context: In October 2021, the University conducted a physical inventory of all of its fixed assets which includes property acquired with federal funds. To facilitate the inventory, the University distributed a memo to all department heads detailing the procedures needed to conduct a physical inventory and instructed them to perform a physical inventory in their respective departments by December 1, 2021. During our audit, it was noted that the physical inventory was not completed by all departments. Based on the information provided by management there were 16 property items that were subject to inventory; however, because the inventory documentation provided did not cover all departments, only 1 property item was identified through the physical inventory. Cause: Although the University has procedures in place over the physical inventory of property, there was a lack of diligence in complying with the procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years results in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for the physical inventory of equipment and ensure all departments timely complete the physical inventory. Views of responsible officials: The HPU Fixed Asset Accountant, Federal Grant Project Investigator and Office of Sponsored Projects will work collaboratively to ensure that the physical inventory of all fixed assets which were acquired using federal funds are conducted and completed periodically. This physical inventory monitoring will be done at least, every two years. The team will work on getting all departments covered in the periodic inventory to confirm that the fixed asset listing is complete, updated and maintained.
Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual, corporation, association, unit of government, or legal entity, however organized) they are entering into a covered transaction with is not suspended or debarred by: (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: Verification that an entity was not suspended or debarred was not performed for one entity. Context: The University entered into covered transactions with six entities during the fiscal year. We selected a non-statistical sample of two entities for testing, noting verification that the entity was not suspended or debarred was not performed for one entity. We re-performed the verification and noted the entity did not have any exclusion records, indicating they were not suspended or debarred. Cause: Although the University has established policies and procedures in place over the procurement and suspension and debarment process, there was a lack of diligence in complying with obtaining or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process could result in noncompliance with the procurement and suspension and debarment requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the department to ensure that the required procedure for verification of Suspension and Debarment is consistently conducted and evidence of such procedure is maintained. The OSP Office will strengthen its policies and procedures so that the SAM screenshot for all covered transactions is complete and retained. The Principal Investigator should work collaboratively with the OSP to ensure that the documentation for suspension and debarment for vendors meeting this requirement is obtained and maintained. The Manager for Grants and Contracts will be sure to check the SAM.gov for suspension and debarment and will maintain the documentation. The Assistant VP of the Office of Sponsored Projects will review the documentation.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. Condition: The physical inventory was not conducted as required. Context: In October 2021, the University conducted a physical inventory of all of its fixed assets which includes property acquired with federal funds. To facilitate the inventory, the University distributed a memo to all department heads detailing the procedures needed to conduct a physical inventory and instructed them to perform a physical inventory in their respective departments by December 1, 2021. During our audit, it was noted that the physical inventory was not completed by all departments. Based on the information provided by management there were 16 property items that were subject to inventory; however, because the inventory documentation provided did not cover all departments, only 1 property item was identified through the physical inventory. Cause: Although the University has procedures in place over the physical inventory of property, there was a lack of diligence in complying with the procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years results in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for the physical inventory of equipment and ensure all departments timely complete the physical inventory. Views of responsible officials: The HPU Fixed Asset Accountant, Federal Grant Project Investigator and Office of Sponsored Projects will work collaboratively to ensure that the physical inventory of all fixed assets which were acquired using federal funds are conducted and completed periodically. This physical inventory monitoring will be done at least, every two years. The team will work on getting all departments covered in the periodic inventory to confirm that the fixed asset listing is complete, updated and maintained.
Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual, corporation, association, unit of government, or legal entity, however organized) they are entering into a covered transaction with is not suspended or debarred by: (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: Verification that an entity was not suspended or debarred was not performed for one entity. Context: The University entered into covered transactions with six entities during the fiscal year. We selected a non-statistical sample of two entities for testing, noting verification that the entity was not suspended or debarred was not performed for one entity. We re-performed the verification and noted the entity did not have any exclusion records, indicating they were not suspended or debarred. Cause: Although the University has established policies and procedures in place over the procurement and suspension and debarment process, there was a lack of diligence in complying with obtaining or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process could result in noncompliance with the procurement and suspension and debarment requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the department to ensure that the required procedure for verification of Suspension and Debarment is consistently conducted and evidence of such procedure is maintained. The OSP Office will strengthen its policies and procedures so that the SAM screenshot for all covered transactions is complete and retained. The Principal Investigator should work collaboratively with the OSP to ensure that the documentation for suspension and debarment for vendors meeting this requirement is obtained and maintained. The Manager for Grants and Contracts will be sure to check the SAM.gov for suspension and debarment and will maintain the documentation. The Assistant VP of the Office of Sponsored Projects will review the documentation.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. Condition: The physical inventory was not conducted as required. Context: In October 2021, the University conducted a physical inventory of all of its fixed assets which includes property acquired with federal funds. To facilitate the inventory, the University distributed a memo to all department heads detailing the procedures needed to conduct a physical inventory and instructed them to perform a physical inventory in their respective departments by December 1, 2021. During our audit, it was noted that the physical inventory was not completed by all departments. Based on the information provided by management there were 16 property items that were subject to inventory; however, because the inventory documentation provided did not cover all departments, only 1 property item was identified through the physical inventory. Cause: Although the University has procedures in place over the physical inventory of property, there was a lack of diligence in complying with the procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years results in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for the physical inventory of equipment and ensure all departments timely complete the physical inventory. Views of responsible officials: The HPU Fixed Asset Accountant, Federal Grant Project Investigator and Office of Sponsored Projects will work collaboratively to ensure that the physical inventory of all fixed assets which were acquired using federal funds are conducted and completed periodically. This physical inventory monitoring will be done at least, every two years. The team will work on getting all departments covered in the periodic inventory to confirm that the fixed asset listing is complete, updated and maintained.
Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual, corporation, association, unit of government, or legal entity, however organized) they are entering into a covered transaction with is not suspended or debarred by: (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: Verification that an entity was not suspended or debarred was not performed for one entity. Context: The University entered into covered transactions with six entities during the fiscal year. We selected a non-statistical sample of two entities for testing, noting verification that the entity was not suspended or debarred was not performed for one entity. We re-performed the verification and noted the entity did not have any exclusion records, indicating they were not suspended or debarred. Cause: Although the University has established policies and procedures in place over the procurement and suspension and debarment process, there was a lack of diligence in complying with obtaining or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process could result in noncompliance with the procurement and suspension and debarment requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the department to ensure that the required procedure for verification of Suspension and Debarment is consistently conducted and evidence of such procedure is maintained. The OSP Office will strengthen its policies and procedures so that the SAM screenshot for all covered transactions is complete and retained. The Principal Investigator should work collaboratively with the OSP to ensure that the documentation for suspension and debarment for vendors meeting this requirement is obtained and maintained. The Manager for Grants and Contracts will be sure to check the SAM.gov for suspension and debarment and will maintain the documentation. The Assistant VP of the Office of Sponsored Projects will review the documentation.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. Condition: The physical inventory was not conducted as required. Context: In October 2021, the University conducted a physical inventory of all of its fixed assets which includes property acquired with federal funds. To facilitate the inventory, the University distributed a memo to all department heads detailing the procedures needed to conduct a physical inventory and instructed them to perform a physical inventory in their respective departments by December 1, 2021. During our audit, it was noted that the physical inventory was not completed by all departments. Based on the information provided by management there were 16 property items that were subject to inventory; however, because the inventory documentation provided did not cover all departments, only 1 property item was identified through the physical inventory. Cause: Although the University has procedures in place over the physical inventory of property, there was a lack of diligence in complying with the procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years results in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for the physical inventory of equipment and ensure all departments timely complete the physical inventory. Views of responsible officials: The HPU Fixed Asset Accountant, Federal Grant Project Investigator and Office of Sponsored Projects will work collaboratively to ensure that the physical inventory of all fixed assets which were acquired using federal funds are conducted and completed periodically. This physical inventory monitoring will be done at least, every two years. The team will work on getting all departments covered in the periodic inventory to confirm that the fixed asset listing is complete, updated and maintained.
Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual, corporation, association, unit of government, or legal entity, however organized) they are entering into a covered transaction with is not suspended or debarred by: (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: Verification that an entity was not suspended or debarred was not performed for one entity. Context: The University entered into covered transactions with six entities during the fiscal year. We selected a non-statistical sample of two entities for testing, noting verification that the entity was not suspended or debarred was not performed for one entity. We re-performed the verification and noted the entity did not have any exclusion records, indicating they were not suspended or debarred. Cause: Although the University has established policies and procedures in place over the procurement and suspension and debarment process, there was a lack of diligence in complying with obtaining or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process could result in noncompliance with the procurement and suspension and debarment requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the department to ensure that the required procedure for verification of Suspension and Debarment is consistently conducted and evidence of such procedure is maintained. The OSP Office will strengthen its policies and procedures so that the SAM screenshot for all covered transactions is complete and retained. The Principal Investigator should work collaboratively with the OSP to ensure that the documentation for suspension and debarment for vendors meeting this requirement is obtained and maintained. The Manager for Grants and Contracts will be sure to check the SAM.gov for suspension and debarment and will maintain the documentation. The Assistant VP of the Office of Sponsored Projects will review the documentation.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. Condition: The physical inventory was not conducted as required. Context: In October 2021, the University conducted a physical inventory of all of its fixed assets which includes property acquired with federal funds. To facilitate the inventory, the University distributed a memo to all department heads detailing the procedures needed to conduct a physical inventory and instructed them to perform a physical inventory in their respective departments by December 1, 2021. During our audit, it was noted that the physical inventory was not completed by all departments. Based on the information provided by management there were 16 property items that were subject to inventory; however, because the inventory documentation provided did not cover all departments, only 1 property item was identified through the physical inventory. Cause: Although the University has procedures in place over the physical inventory of property, there was a lack of diligence in complying with the procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years results in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for the physical inventory of equipment and ensure all departments timely complete the physical inventory. Views of responsible officials: The HPU Fixed Asset Accountant, Federal Grant Project Investigator and Office of Sponsored Projects will work collaboratively to ensure that the physical inventory of all fixed assets which were acquired using federal funds are conducted and completed periodically. This physical inventory monitoring will be done at least, every two years. The team will work on getting all departments covered in the periodic inventory to confirm that the fixed asset listing is complete, updated and maintained.
Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual, corporation, association, unit of government, or legal entity, however organized) they are entering into a covered transaction with is not suspended or debarred by: (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: Verification that an entity was not suspended or debarred was not performed for one entity. Context: The University entered into covered transactions with six entities during the fiscal year. We selected a non-statistical sample of two entities for testing, noting verification that the entity was not suspended or debarred was not performed for one entity. We re-performed the verification and noted the entity did not have any exclusion records, indicating they were not suspended or debarred. Cause: Although the University has established policies and procedures in place over the procurement and suspension and debarment process, there was a lack of diligence in complying with obtaining or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process could result in noncompliance with the procurement and suspension and debarment requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the department to ensure that the required procedure for verification of Suspension and Debarment is consistently conducted and evidence of such procedure is maintained. The OSP Office will strengthen its policies and procedures so that the SAM screenshot for all covered transactions is complete and retained. The Principal Investigator should work collaboratively with the OSP to ensure that the documentation for suspension and debarment for vendors meeting this requirement is obtained and maintained. The Manager for Grants and Contracts will be sure to check the SAM.gov for suspension and debarment and will maintain the documentation. The Assistant VP of the Office of Sponsored Projects will review the documentation.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. Condition: The physical inventory was not conducted as required. Context: In October 2021, the University conducted a physical inventory of all of its fixed assets which includes property acquired with federal funds. To facilitate the inventory, the University distributed a memo to all department heads detailing the procedures needed to conduct a physical inventory and instructed them to perform a physical inventory in their respective departments by December 1, 2021. During our audit, it was noted that the physical inventory was not completed by all departments. Based on the information provided by management there were 16 property items that were subject to inventory; however, because the inventory documentation provided did not cover all departments, only 1 property item was identified through the physical inventory. Cause: Although the University has procedures in place over the physical inventory of property, there was a lack of diligence in complying with the procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years results in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for the physical inventory of equipment and ensure all departments timely complete the physical inventory. Views of responsible officials: The HPU Fixed Asset Accountant, Federal Grant Project Investigator and Office of Sponsored Projects will work collaboratively to ensure that the physical inventory of all fixed assets which were acquired using federal funds are conducted and completed periodically. This physical inventory monitoring will be done at least, every two years. The team will work on getting all departments covered in the periodic inventory to confirm that the fixed asset listing is complete, updated and maintained.
Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual, corporation, association, unit of government, or legal entity, however organized) they are entering into a covered transaction with is not suspended or debarred by: (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: Verification that an entity was not suspended or debarred was not performed for one entity. Context: The University entered into covered transactions with six entities during the fiscal year. We selected a non-statistical sample of two entities for testing, noting verification that the entity was not suspended or debarred was not performed for one entity. We re-performed the verification and noted the entity did not have any exclusion records, indicating they were not suspended or debarred. Cause: Although the University has established policies and procedures in place over the procurement and suspension and debarment process, there was a lack of diligence in complying with obtaining or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process could result in noncompliance with the procurement and suspension and debarment requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the department to ensure that the required procedure for verification of Suspension and Debarment is consistently conducted and evidence of such procedure is maintained. The OSP Office will strengthen its policies and procedures so that the SAM screenshot for all covered transactions is complete and retained. The Principal Investigator should work collaboratively with the OSP to ensure that the documentation for suspension and debarment for vendors meeting this requirement is obtained and maintained. The Manager for Grants and Contracts will be sure to check the SAM.gov for suspension and debarment and will maintain the documentation. The Assistant VP of the Office of Sponsored Projects will review the documentation.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. Condition: The physical inventory was not conducted as required. Context: In October 2021, the University conducted a physical inventory of all of its fixed assets which includes property acquired with federal funds. To facilitate the inventory, the University distributed a memo to all department heads detailing the procedures needed to conduct a physical inventory and instructed them to perform a physical inventory in their respective departments by December 1, 2021. During our audit, it was noted that the physical inventory was not completed by all departments. Based on the information provided by management there were 16 property items that were subject to inventory; however, because the inventory documentation provided did not cover all departments, only 1 property item was identified through the physical inventory. Cause: Although the University has procedures in place over the physical inventory of property, there was a lack of diligence in complying with the procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years results in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for the physical inventory of equipment and ensure all departments timely complete the physical inventory. Views of responsible officials: The HPU Fixed Asset Accountant, Federal Grant Project Investigator and Office of Sponsored Projects will work collaboratively to ensure that the physical inventory of all fixed assets which were acquired using federal funds are conducted and completed periodically. This physical inventory monitoring will be done at least, every two years. The team will work on getting all departments covered in the periodic inventory to confirm that the fixed asset listing is complete, updated and maintained.
Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual, corporation, association, unit of government, or legal entity, however organized) they are entering into a covered transaction with is not suspended or debarred by: (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: Verification that an entity was not suspended or debarred was not performed for one entity. Context: The University entered into covered transactions with six entities during the fiscal year. We selected a non-statistical sample of two entities for testing, noting verification that the entity was not suspended or debarred was not performed for one entity. We re-performed the verification and noted the entity did not have any exclusion records, indicating they were not suspended or debarred. Cause: Although the University has established policies and procedures in place over the procurement and suspension and debarment process, there was a lack of diligence in complying with obtaining or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process could result in noncompliance with the procurement and suspension and debarment requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the department to ensure that the required procedure for verification of Suspension and Debarment is consistently conducted and evidence of such procedure is maintained. The OSP Office will strengthen its policies and procedures so that the SAM screenshot for all covered transactions is complete and retained. The Principal Investigator should work collaboratively with the OSP to ensure that the documentation for suspension and debarment for vendors meeting this requirement is obtained and maintained. The Manager for Grants and Contracts will be sure to check the SAM.gov for suspension and debarment and will maintain the documentation. The Assistant VP of the Office of Sponsored Projects will review the documentation.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. Condition: The physical inventory was not conducted as required. Context: In October 2021, the University conducted a physical inventory of all of its fixed assets which includes property acquired with federal funds. To facilitate the inventory, the University distributed a memo to all department heads detailing the procedures needed to conduct a physical inventory and instructed them to perform a physical inventory in their respective departments by December 1, 2021. During our audit, it was noted that the physical inventory was not completed by all departments. Based on the information provided by management there were 16 property items that were subject to inventory; however, because the inventory documentation provided did not cover all departments, only 1 property item was identified through the physical inventory. Cause: Although the University has procedures in place over the physical inventory of property, there was a lack of diligence in complying with the procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years results in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for the physical inventory of equipment and ensure all departments timely complete the physical inventory. Views of responsible officials: The HPU Fixed Asset Accountant, Federal Grant Project Investigator and Office of Sponsored Projects will work collaboratively to ensure that the physical inventory of all fixed assets which were acquired using federal funds are conducted and completed periodically. This physical inventory monitoring will be done at least, every two years. The team will work on getting all departments covered in the periodic inventory to confirm that the fixed asset listing is complete, updated and maintained.
Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual, corporation, association, unit of government, or legal entity, however organized) they are entering into a covered transaction with is not suspended or debarred by: (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: Verification that an entity was not suspended or debarred was not performed for one entity. Context: The University entered into covered transactions with six entities during the fiscal year. We selected a non-statistical sample of two entities for testing, noting verification that the entity was not suspended or debarred was not performed for one entity. We re-performed the verification and noted the entity did not have any exclusion records, indicating they were not suspended or debarred. Cause: Although the University has established policies and procedures in place over the procurement and suspension and debarment process, there was a lack of diligence in complying with obtaining or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process could result in noncompliance with the procurement and suspension and debarment requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the department to ensure that the required procedure for verification of Suspension and Debarment is consistently conducted and evidence of such procedure is maintained. The OSP Office will strengthen its policies and procedures so that the SAM screenshot for all covered transactions is complete and retained. The Principal Investigator should work collaboratively with the OSP to ensure that the documentation for suspension and debarment for vendors meeting this requirement is obtained and maintained. The Manager for Grants and Contracts will be sure to check the SAM.gov for suspension and debarment and will maintain the documentation. The Assistant VP of the Office of Sponsored Projects will review the documentation.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. Condition: The physical inventory was not conducted as required. Context: In October 2021, the University conducted a physical inventory of all of its fixed assets which includes property acquired with federal funds. To facilitate the inventory, the University distributed a memo to all department heads detailing the procedures needed to conduct a physical inventory and instructed them to perform a physical inventory in their respective departments by December 1, 2021. During our audit, it was noted that the physical inventory was not completed by all departments. Based on the information provided by management there were 16 property items that were subject to inventory; however, because the inventory documentation provided did not cover all departments, only 1 property item was identified through the physical inventory. Cause: Although the University has procedures in place over the physical inventory of property, there was a lack of diligence in complying with the procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years results in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for the physical inventory of equipment and ensure all departments timely complete the physical inventory. Views of responsible officials: The HPU Fixed Asset Accountant, Federal Grant Project Investigator and Office of Sponsored Projects will work collaboratively to ensure that the physical inventory of all fixed assets which were acquired using federal funds are conducted and completed periodically. This physical inventory monitoring will be done at least, every two years. The team will work on getting all departments covered in the periodic inventory to confirm that the fixed asset listing is complete, updated and maintained.
Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual, corporation, association, unit of government, or legal entity, however organized) they are entering into a covered transaction with is not suspended or debarred by: (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: Verification that an entity was not suspended or debarred was not performed for one entity. Context: The University entered into covered transactions with six entities during the fiscal year. We selected a non-statistical sample of two entities for testing, noting verification that the entity was not suspended or debarred was not performed for one entity. We re-performed the verification and noted the entity did not have any exclusion records, indicating they were not suspended or debarred. Cause: Although the University has established policies and procedures in place over the procurement and suspension and debarment process, there was a lack of diligence in complying with obtaining or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process could result in noncompliance with the procurement and suspension and debarment requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the department to ensure that the required procedure for verification of Suspension and Debarment is consistently conducted and evidence of such procedure is maintained. The OSP Office will strengthen its policies and procedures so that the SAM screenshot for all covered transactions is complete and retained. The Principal Investigator should work collaboratively with the OSP to ensure that the documentation for suspension and debarment for vendors meeting this requirement is obtained and maintained. The Manager for Grants and Contracts will be sure to check the SAM.gov for suspension and debarment and will maintain the documentation. The Assistant VP of the Office of Sponsored Projects will review the documentation.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.303(a) requires the non-Federal entity to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing of the HEERF Program, for non-student related payroll and non-payroll expenditures, management did not provide sufficient support for justification for the allocation of these costs to the program. Consequently, we were unable to audit the allowability of these costs. Additionally, for expenditures related to financial aid grants to students, there was no independent review to ensure allowability of costs prior to disbursement. Context: For the non-student payroll-related expenditures, management indicated that department heads and the University?s Office of Sponsored Projects (OSP) held discussions to determine estimates of the time each departments? employees spent on allowable COVID-related activities; however, the discussion related to the rationale, basis and final allocations were not consistently documented. We selected a non-statistical sample of 20 payroll items representing $90,009 of which 17 items representing $75,564 had no documentation of the justification supporting the allocation. Total payroll expenditures for the program were $3,890,213. For non-student non-payroll expenditures, management did not consistently document the justification supporting the allocation of costs to the program. We selected a non-statistical sample of 15 items representing $659,611 of which 5 items representing $76,035 did not have documentation of the justification supporting the allocation. Total non-student non-payroll expenditures for the program were $2,899,106. For the financial aid grants to students, we noted that one person prepares the listing for disbursement with no independent review. Total financial aid grants to students was $4,301,887. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, documented policies and procedures to administer the program were not developed and therefore not all supporting justifications were documented. For financial aid grants to students, management did not design a control to allow to provide for an independent review of allowability prior to disbursement. Effect: Expenditures for non-student related payroll, non-payroll items and financial aid grants to students could be disbursed for unallowable costs. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2021-002. Recommendations: The HEERF Program has ended for the University. We recommend that should similar programs become available in the future, that management develop documented policies and procedures to administer the program and that management maintain documentation to evidence the internal controls. Views of responsible officials: The HPU Financial Aid Office works hard to follow all federal regulations and guidance mandated for the Title IV Federal Student Aid programs. In regards to the distribution of the Federal HEERF fund to HPU students, the HPU Financial Aid Director relied on reports from the SIS (Banner system), Institutional Research, and Accounts Receivable to determine students eligible for HEERF funds. The HPU Financial Aid Office and Office of Sponsored Projects worked hard, and diligently, to award funds to students and expend Institution portion based on the regulations that were provided at the time and not violating the intent of the program, as evidenced by there not being any non-compliance over allowability of costs charged to Federal HEERF fund. For future awards, the Principal Investigator with the assistance of the Office of Sponsored Projects will review diligently the expenditure to be sure the expenditures are within the allowability and terms and conditions of the federal awards. Both offices will work collaboratively so that the internal controls over allowability are strengthened and that the documentation will be strongly implemented and retained. For future programs, the HPU Financial Aid will work to strategically plan, organize, and disburse funds to students and expend Institution funds within the requirements mandated by the United States Department of Education, including strengthening our internal controls over compliance, and increasing the documentation and maintenance of documentation over our existing internal controls for compliance.
Criteria: There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion (Quarterly Student Report); 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Institutional Reports), as applicable; and 3) the annual report (Annual Report). The Coronavirus Aid, Relief, and Economic Security (CARES) Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While American Rescue Plan (ARP) does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Per the Form Instructions included on the ?Quarterly Budget and Expenditure Reporting for HEERF I, II, and III (a)(1) Institutional Portion, (a)(2), and (a)(3), if applicable? form, the completed form must be conspicuously posted on the institution?s primary website no later than 10 days after the end of each calendar quarter. Additionally, the Form Instructions include that reports must be maintained for at least three years after the submission of the final report. Condition: Management did not provide sufficient documentation to support the data included in the Annual Report, Quarterly Institutional Reports and Quarterly Student Reports. In addition, for one quarter, a Quarterly Institutional Report and a Quarterly Student Report was not retained on the University?s website. Context: Management provided documentation to support the information included in the reports; however, in several instances, the information provided either did not agree to the data included in the reports or it was unclear as to how the information supported the reports. In addition, the Quarterly Institutional Report and Quarterly Student Report for the quarter ended September 30, 2021 was prepared and posted on the University?s website; however, the reports were erroneously removed. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, documented policies and procedures over reporting for the program were not developed. Additionally, due to staff turnover, information was not retained in a manner that allowed it to be easily retrieved and compiled in a manner supporting the reports. Effect: The reports that were completed could contain inaccurate or incomplete data. In addition, the University was not compliant with the requirement to maintain the reports on the University?s website. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2021-003. Recommendations: As the HEERF Program has ended for the University, we recommend that should similar programs become available in the future, that management develop documented policies and procedures to administer the program and that management maintain documentation to evidence the internal controls. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) and Office of Financial Aid work to follow all federal reporting regulations and guidance mandated for the Federal grant & contract programs. For future programs, the Institutional Research, the Office of Sponsored Projects and the Financial Aid Office will generate the reports and will implement layers of review procedure to ensure that the reports are accurate, complete, submitted timely, and if needed, posted in HPU website. For the Institution portion, the Manager for Grants and Contracts will prepare the grant report and this report will be reviewed by the Assistant VP for OSP. For the student portion the periodic reports will be prepared by the staff of the Office of Financial Aid and will be reviewed by the Director of the Financial Aid office. The Business Office will perform a high-level independent review for completeness and accuracy. Finally, moving forward, all the files and documents that support the grant report will be retained.
Criteria: 2 CFR 200.303(a) requires the non-Federal entity to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing of the HEERF Program, for non-student related payroll and non-payroll expenditures, management did not provide sufficient support for justification for the allocation of these costs to the program. Consequently, we were unable to audit the allowability of these costs. Additionally, for expenditures related to financial aid grants to students, there was no independent review to ensure allowability of costs prior to disbursement. Context: For the non-student payroll-related expenditures, management indicated that department heads and the University?s Office of Sponsored Projects (OSP) held discussions to determine estimates of the time each departments? employees spent on allowable COVID-related activities; however, the discussion related to the rationale, basis and final allocations were not consistently documented. We selected a non-statistical sample of 20 payroll items representing $90,009 of which 17 items representing $75,564 had no documentation of the justification supporting the allocation. Total payroll expenditures for the program were $3,890,213. For non-student non-payroll expenditures, management did not consistently document the justification supporting the allocation of costs to the program. We selected a non-statistical sample of 15 items representing $659,611 of which 5 items representing $76,035 did not have documentation of the justification supporting the allocation. Total non-student non-payroll expenditures for the program were $2,899,106. For the financial aid grants to students, we noted that one person prepares the listing for disbursement with no independent review. Total financial aid grants to students was $4,301,887. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, documented policies and procedures to administer the program were not developed and therefore not all supporting justifications were documented. For financial aid grants to students, management did not design a control to allow to provide for an independent review of allowability prior to disbursement. Effect: Expenditures for non-student related payroll, non-payroll items and financial aid grants to students could be disbursed for unallowable costs. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2021-002. Recommendations: The HEERF Program has ended for the University. We recommend that should similar programs become available in the future, that management develop documented policies and procedures to administer the program and that management maintain documentation to evidence the internal controls. Views of responsible officials: The HPU Financial Aid Office works hard to follow all federal regulations and guidance mandated for the Title IV Federal Student Aid programs. In regards to the distribution of the Federal HEERF fund to HPU students, the HPU Financial Aid Director relied on reports from the SIS (Banner system), Institutional Research, and Accounts Receivable to determine students eligible for HEERF funds. The HPU Financial Aid Office and Office of Sponsored Projects worked hard, and diligently, to award funds to students and expend Institution portion based on the regulations that were provided at the time and not violating the intent of the program, as evidenced by there not being any non-compliance over allowability of costs charged to Federal HEERF fund. For future awards, the Principal Investigator with the assistance of the Office of Sponsored Projects will review diligently the expenditure to be sure the expenditures are within the allowability and terms and conditions of the federal awards. Both offices will work collaboratively so that the internal controls over allowability are strengthened and that the documentation will be strongly implemented and retained. For future programs, the HPU Financial Aid will work to strategically plan, organize, and disburse funds to students and expend Institution funds within the requirements mandated by the United States Department of Education, including strengthening our internal controls over compliance, and increasing the documentation and maintenance of documentation over our existing internal controls for compliance.
Criteria: There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion (Quarterly Student Report); 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Institutional Reports), as applicable; and 3) the annual report (Annual Report). The Coronavirus Aid, Relief, and Economic Security (CARES) Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While American Rescue Plan (ARP) does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Per the Form Instructions included on the ?Quarterly Budget and Expenditure Reporting for HEERF I, II, and III (a)(1) Institutional Portion, (a)(2), and (a)(3), if applicable? form, the completed form must be conspicuously posted on the institution?s primary website no later than 10 days after the end of each calendar quarter. Additionally, the Form Instructions include that reports must be maintained for at least three years after the submission of the final report. Condition: Management did not provide sufficient documentation to support the data included in the Annual Report, Quarterly Institutional Reports and Quarterly Student Reports. In addition, for one quarter, a Quarterly Institutional Report and a Quarterly Student Report was not retained on the University?s website. Context: Management provided documentation to support the information included in the reports; however, in several instances, the information provided either did not agree to the data included in the reports or it was unclear as to how the information supported the reports. In addition, the Quarterly Institutional Report and Quarterly Student Report for the quarter ended September 30, 2021 was prepared and posted on the University?s website; however, the reports were erroneously removed. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, documented policies and procedures over reporting for the program were not developed. Additionally, due to staff turnover, information was not retained in a manner that allowed it to be easily retrieved and compiled in a manner supporting the reports. Effect: The reports that were completed could contain inaccurate or incomplete data. In addition, the University was not compliant with the requirement to maintain the reports on the University?s website. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2021-003. Recommendations: As the HEERF Program has ended for the University, we recommend that should similar programs become available in the future, that management develop documented policies and procedures to administer the program and that management maintain documentation to evidence the internal controls. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) and Office of Financial Aid work to follow all federal reporting regulations and guidance mandated for the Federal grant & contract programs. For future programs, the Institutional Research, the Office of Sponsored Projects and the Financial Aid Office will generate the reports and will implement layers of review procedure to ensure that the reports are accurate, complete, submitted timely, and if needed, posted in HPU website. For the Institution portion, the Manager for Grants and Contracts will prepare the grant report and this report will be reviewed by the Assistant VP for OSP. For the student portion the periodic reports will be prepared by the staff of the Office of Financial Aid and will be reviewed by the Director of the Financial Aid office. The Business Office will perform a high-level independent review for completeness and accuracy. Finally, moving forward, all the files and documents that support the grant report will be retained.
Criteria: 2 CFR 200.303(a) requires the non-Federal entity to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing of the HEERF Program, for non-student related payroll and non-payroll expenditures, management did not provide sufficient support for justification for the allocation of these costs to the program. Consequently, we were unable to audit the allowability of these costs. Additionally, for expenditures related to financial aid grants to students, there was no independent review to ensure allowability of costs prior to disbursement. Context: For the non-student payroll-related expenditures, management indicated that department heads and the University?s Office of Sponsored Projects (OSP) held discussions to determine estimates of the time each departments? employees spent on allowable COVID-related activities; however, the discussion related to the rationale, basis and final allocations were not consistently documented. We selected a non-statistical sample of 20 payroll items representing $90,009 of which 17 items representing $75,564 had no documentation of the justification supporting the allocation. Total payroll expenditures for the program were $3,890,213. For non-student non-payroll expenditures, management did not consistently document the justification supporting the allocation of costs to the program. We selected a non-statistical sample of 15 items representing $659,611 of which 5 items representing $76,035 did not have documentation of the justification supporting the allocation. Total non-student non-payroll expenditures for the program were $2,899,106. For the financial aid grants to students, we noted that one person prepares the listing for disbursement with no independent review. Total financial aid grants to students was $4,301,887. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, documented policies and procedures to administer the program were not developed and therefore not all supporting justifications were documented. For financial aid grants to students, management did not design a control to allow to provide for an independent review of allowability prior to disbursement. Effect: Expenditures for non-student related payroll, non-payroll items and financial aid grants to students could be disbursed for unallowable costs. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2021-002. Recommendations: The HEERF Program has ended for the University. We recommend that should similar programs become available in the future, that management develop documented policies and procedures to administer the program and that management maintain documentation to evidence the internal controls. Views of responsible officials: The HPU Financial Aid Office works hard to follow all federal regulations and guidance mandated for the Title IV Federal Student Aid programs. In regards to the distribution of the Federal HEERF fund to HPU students, the HPU Financial Aid Director relied on reports from the SIS (Banner system), Institutional Research, and Accounts Receivable to determine students eligible for HEERF funds. The HPU Financial Aid Office and Office of Sponsored Projects worked hard, and diligently, to award funds to students and expend Institution portion based on the regulations that were provided at the time and not violating the intent of the program, as evidenced by there not being any non-compliance over allowability of costs charged to Federal HEERF fund. For future awards, the Principal Investigator with the assistance of the Office of Sponsored Projects will review diligently the expenditure to be sure the expenditures are within the allowability and terms and conditions of the federal awards. Both offices will work collaboratively so that the internal controls over allowability are strengthened and that the documentation will be strongly implemented and retained. For future programs, the HPU Financial Aid will work to strategically plan, organize, and disburse funds to students and expend Institution funds within the requirements mandated by the United States Department of Education, including strengthening our internal controls over compliance, and increasing the documentation and maintenance of documentation over our existing internal controls for compliance.
Criteria: There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion (Quarterly Student Report); 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Institutional Reports), as applicable; and 3) the annual report (Annual Report). The Coronavirus Aid, Relief, and Economic Security (CARES) Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While American Rescue Plan (ARP) does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Per the Form Instructions included on the ?Quarterly Budget and Expenditure Reporting for HEERF I, II, and III (a)(1) Institutional Portion, (a)(2), and (a)(3), if applicable? form, the completed form must be conspicuously posted on the institution?s primary website no later than 10 days after the end of each calendar quarter. Additionally, the Form Instructions include that reports must be maintained for at least three years after the submission of the final report. Condition: Management did not provide sufficient documentation to support the data included in the Annual Report, Quarterly Institutional Reports and Quarterly Student Reports. In addition, for one quarter, a Quarterly Institutional Report and a Quarterly Student Report was not retained on the University?s website. Context: Management provided documentation to support the information included in the reports; however, in several instances, the information provided either did not agree to the data included in the reports or it was unclear as to how the information supported the reports. In addition, the Quarterly Institutional Report and Quarterly Student Report for the quarter ended September 30, 2021 was prepared and posted on the University?s website; however, the reports were erroneously removed. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, documented policies and procedures over reporting for the program were not developed. Additionally, due to staff turnover, information was not retained in a manner that allowed it to be easily retrieved and compiled in a manner supporting the reports. Effect: The reports that were completed could contain inaccurate or incomplete data. In addition, the University was not compliant with the requirement to maintain the reports on the University?s website. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2021-003. Recommendations: As the HEERF Program has ended for the University, we recommend that should similar programs become available in the future, that management develop documented policies and procedures to administer the program and that management maintain documentation to evidence the internal controls. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) and Office of Financial Aid work to follow all federal reporting regulations and guidance mandated for the Federal grant & contract programs. For future programs, the Institutional Research, the Office of Sponsored Projects and the Financial Aid Office will generate the reports and will implement layers of review procedure to ensure that the reports are accurate, complete, submitted timely, and if needed, posted in HPU website. For the Institution portion, the Manager for Grants and Contracts will prepare the grant report and this report will be reviewed by the Assistant VP for OSP. For the student portion the periodic reports will be prepared by the staff of the Office of Financial Aid and will be reviewed by the Director of the Financial Aid office. The Business Office will perform a high-level independent review for completeness and accuracy. Finally, moving forward, all the files and documents that support the grant report will be retained.
Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards of that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. The VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements above the micro-purchase threshold. Condition: Procurement documentation for two vendors were not prepared and/or retained to support compliance with the regulations above and the University?s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of twelve vendors with total expenditures greater than the micro-purchase threshold during the fiscal year. For two selections, the University?s VJF documenting and approving the procurement was not prepared. Additionally, one small purchase selection did not include quotes from more than one vendor. Cause: Although the University has established policies and procedures in place over the procurement process, there was a lack of diligence in complying with and/or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will work on strengthening its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained. The Vendor Justification Form will be strictly enforced for purchases meeting the specific threshold amount when procuring using federal funds.
Criteria: 2 CFR 200.303(a) requires the non-Federal entity to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing of the HEERF Program, for non-student related payroll and non-payroll expenditures, management did not provide sufficient support for justification for the allocation of these costs to the program. Consequently, we were unable to audit the allowability of these costs. Additionally, for expenditures related to financial aid grants to students, there was no independent review to ensure allowability of costs prior to disbursement. Context: For the non-student payroll-related expenditures, management indicated that department heads and the University?s Office of Sponsored Projects (OSP) held discussions to determine estimates of the time each departments? employees spent on allowable COVID-related activities; however, the discussion related to the rationale, basis and final allocations were not consistently documented. We selected a non-statistical sample of 20 payroll items representing $90,009 of which 17 items representing $75,564 had no documentation of the justification supporting the allocation. Total payroll expenditures for the program were $3,890,213. For non-student non-payroll expenditures, management did not consistently document the justification supporting the allocation of costs to the program. We selected a non-statistical sample of 15 items representing $659,611 of which 5 items representing $76,035 did not have documentation of the justification supporting the allocation. Total non-student non-payroll expenditures for the program were $2,899,106. For the financial aid grants to students, we noted that one person prepares the listing for disbursement with no independent review. Total financial aid grants to students was $4,301,887. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, documented policies and procedures to administer the program were not developed and therefore not all supporting justifications were documented. For financial aid grants to students, management did not design a control to allow to provide for an independent review of allowability prior to disbursement. Effect: Expenditures for non-student related payroll, non-payroll items and financial aid grants to students could be disbursed for unallowable costs. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2021-002. Recommendations: The HEERF Program has ended for the University. We recommend that should similar programs become available in the future, that management develop documented policies and procedures to administer the program and that management maintain documentation to evidence the internal controls. Views of responsible officials: The HPU Financial Aid Office works hard to follow all federal regulations and guidance mandated for the Title IV Federal Student Aid programs. In regards to the distribution of the Federal HEERF fund to HPU students, the HPU Financial Aid Director relied on reports from the SIS (Banner system), Institutional Research, and Accounts Receivable to determine students eligible for HEERF funds. The HPU Financial Aid Office and Office of Sponsored Projects worked hard, and diligently, to award funds to students and expend Institution portion based on the regulations that were provided at the time and not violating the intent of the program, as evidenced by there not being any non-compliance over allowability of costs charged to Federal HEERF fund. For future awards, the Principal Investigator with the assistance of the Office of Sponsored Projects will review diligently the expenditure to be sure the expenditures are within the allowability and terms and conditions of the federal awards. Both offices will work collaboratively so that the internal controls over allowability are strengthened and that the documentation will be strongly implemented and retained. For future programs, the HPU Financial Aid will work to strategically plan, organize, and disburse funds to students and expend Institution funds within the requirements mandated by the United States Department of Education, including strengthening our internal controls over compliance, and increasing the documentation and maintenance of documentation over our existing internal controls for compliance.
Criteria: There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion (Quarterly Student Report); 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Institutional Reports), as applicable; and 3) the annual report (Annual Report). The Coronavirus Aid, Relief, and Economic Security (CARES) Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While American Rescue Plan (ARP) does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Per the Form Instructions included on the ?Quarterly Budget and Expenditure Reporting for HEERF I, II, and III (a)(1) Institutional Portion, (a)(2), and (a)(3), if applicable? form, the completed form must be conspicuously posted on the institution?s primary website no later than 10 days after the end of each calendar quarter. Additionally, the Form Instructions include that reports must be maintained for at least three years after the submission of the final report. Condition: Management did not provide sufficient documentation to support the data included in the Annual Report, Quarterly Institutional Reports and Quarterly Student Reports. In addition, for one quarter, a Quarterly Institutional Report and a Quarterly Student Report was not retained on the University?s website. Context: Management provided documentation to support the information included in the reports; however, in several instances, the information provided either did not agree to the data included in the reports or it was unclear as to how the information supported the reports. In addition, the Quarterly Institutional Report and Quarterly Student Report for the quarter ended September 30, 2021 was prepared and posted on the University?s website; however, the reports were erroneously removed. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, documented policies and procedures over reporting for the program were not developed. Additionally, due to staff turnover, information was not retained in a manner that allowed it to be easily retrieved and compiled in a manner supporting the reports. Effect: The reports that were completed could contain inaccurate or incomplete data. In addition, the University was not compliant with the requirement to maintain the reports on the University?s website. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2021-003. Recommendations: As the HEERF Program has ended for the University, we recommend that should similar programs become available in the future, that management develop documented policies and procedures to administer the program and that management maintain documentation to evidence the internal controls. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) and Office of Financial Aid work to follow all federal reporting regulations and guidance mandated for the Federal grant & contract programs. For future programs, the Institutional Research, the Office of Sponsored Projects and the Financial Aid Office will generate the reports and will implement layers of review procedure to ensure that the reports are accurate, complete, submitted timely, and if needed, posted in HPU website. For the Institution portion, the Manager for Grants and Contracts will prepare the grant report and this report will be reviewed by the Assistant VP for OSP. For the student portion the periodic reports will be prepared by the staff of the Office of Financial Aid and will be reviewed by the Director of the Financial Aid office. The Business Office will perform a high-level independent review for completeness and accuracy. Finally, moving forward, all the files and documents that support the grant report will be retained.
Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards of that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. The VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements above the micro-purchase threshold. Condition: Procurement documentation for two vendors were not prepared and/or retained to support compliance with the regulations above and the University?s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of twelve vendors with total expenditures greater than the micro-purchase threshold during the fiscal year. For two selections, the University?s VJF documenting and approving the procurement was not prepared. Additionally, one small purchase selection did not include quotes from more than one vendor. Cause: Although the University has established policies and procedures in place over the procurement process, there was a lack of diligence in complying with and/or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will work on strengthening its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained. The Vendor Justification Form will be strictly enforced for purchases meeting the specific threshold amount when procuring using federal funds.
Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. Condition: The physical inventory was not conducted as required. Context: In October 2021, the University conducted a physical inventory of all of its fixed assets which includes property acquired with federal funds. To facilitate the inventory, the University distributed a memo to all department heads detailing the procedures needed to conduct a physical inventory and instructed them to perform a physical inventory in their respective departments by December 1, 2021. During our audit, it was noted that the physical inventory was not completed by all departments. Based on the information provided by management there were 16 property items that were subject to inventory; however, because the inventory documentation provided did not cover all departments, only 1 property item was identified through the physical inventory. Cause: Although the University has procedures in place over the physical inventory of property, there was a lack of diligence in complying with the procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years results in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for the physical inventory of equipment and ensure all departments timely complete the physical inventory. Views of responsible officials: The HPU Fixed Asset Accountant, Federal Grant Project Investigator and Office of Sponsored Projects will work collaboratively to ensure that the physical inventory of all fixed assets which were acquired using federal funds are conducted and completed periodically. This physical inventory monitoring will be done at least, every two years. The team will work on getting all departments covered in the periodic inventory to confirm that the fixed asset listing is complete, updated and maintained.
Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual, corporation, association, unit of government, or legal entity, however organized) they are entering into a covered transaction with is not suspended or debarred by: (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: Verification that an entity was not suspended or debarred was not performed for one entity. Context: The University entered into covered transactions with six entities during the fiscal year. We selected a non-statistical sample of two entities for testing, noting verification that the entity was not suspended or debarred was not performed for one entity. We re-performed the verification and noted the entity did not have any exclusion records, indicating they were not suspended or debarred. Cause: Although the University has established policies and procedures in place over the procurement and suspension and debarment process, there was a lack of diligence in complying with obtaining or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process could result in noncompliance with the procurement and suspension and debarment requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the department to ensure that the required procedure for verification of Suspension and Debarment is consistently conducted and evidence of such procedure is maintained. The OSP Office will strengthen its policies and procedures so that the SAM screenshot for all covered transactions is complete and retained. The Principal Investigator should work collaboratively with the OSP to ensure that the documentation for suspension and debarment for vendors meeting this requirement is obtained and maintained. The Manager for Grants and Contracts will be sure to check the SAM.gov for suspension and debarment and will maintain the documentation. The Assistant VP of the Office of Sponsored Projects will review the documentation.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. Condition: The physical inventory was not conducted as required. Context: In October 2021, the University conducted a physical inventory of all of its fixed assets which includes property acquired with federal funds. To facilitate the inventory, the University distributed a memo to all department heads detailing the procedures needed to conduct a physical inventory and instructed them to perform a physical inventory in their respective departments by December 1, 2021. During our audit, it was noted that the physical inventory was not completed by all departments. Based on the information provided by management there were 16 property items that were subject to inventory; however, because the inventory documentation provided did not cover all departments, only 1 property item was identified through the physical inventory. Cause: Although the University has procedures in place over the physical inventory of property, there was a lack of diligence in complying with the procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years results in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for the physical inventory of equipment and ensure all departments timely complete the physical inventory. Views of responsible officials: The HPU Fixed Asset Accountant, Federal Grant Project Investigator and Office of Sponsored Projects will work collaboratively to ensure that the physical inventory of all fixed assets which were acquired using federal funds are conducted and completed periodically. This physical inventory monitoring will be done at least, every two years. The team will work on getting all departments covered in the periodic inventory to confirm that the fixed asset listing is complete, updated and maintained.
Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual, corporation, association, unit of government, or legal entity, however organized) they are entering into a covered transaction with is not suspended or debarred by: (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: Verification that an entity was not suspended or debarred was not performed for one entity. Context: The University entered into covered transactions with six entities during the fiscal year. We selected a non-statistical sample of two entities for testing, noting verification that the entity was not suspended or debarred was not performed for one entity. We re-performed the verification and noted the entity did not have any exclusion records, indicating they were not suspended or debarred. Cause: Although the University has established policies and procedures in place over the procurement and suspension and debarment process, there was a lack of diligence in complying with obtaining or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process could result in noncompliance with the procurement and suspension and debarment requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the department to ensure that the required procedure for verification of Suspension and Debarment is consistently conducted and evidence of such procedure is maintained. The OSP Office will strengthen its policies and procedures so that the SAM screenshot for all covered transactions is complete and retained. The Principal Investigator should work collaboratively with the OSP to ensure that the documentation for suspension and debarment for vendors meeting this requirement is obtained and maintained. The Manager for Grants and Contracts will be sure to check the SAM.gov for suspension and debarment and will maintain the documentation. The Assistant VP of the Office of Sponsored Projects will review the documentation.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. Condition: The physical inventory was not conducted as required. Context: In October 2021, the University conducted a physical inventory of all of its fixed assets which includes property acquired with federal funds. To facilitate the inventory, the University distributed a memo to all department heads detailing the procedures needed to conduct a physical inventory and instructed them to perform a physical inventory in their respective departments by December 1, 2021. During our audit, it was noted that the physical inventory was not completed by all departments. Based on the information provided by management there were 16 property items that were subject to inventory; however, because the inventory documentation provided did not cover all departments, only 1 property item was identified through the physical inventory. Cause: Although the University has procedures in place over the physical inventory of property, there was a lack of diligence in complying with the procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years results in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for the physical inventory of equipment and ensure all departments timely complete the physical inventory. Views of responsible officials: The HPU Fixed Asset Accountant, Federal Grant Project Investigator and Office of Sponsored Projects will work collaboratively to ensure that the physical inventory of all fixed assets which were acquired using federal funds are conducted and completed periodically. This physical inventory monitoring will be done at least, every two years. The team will work on getting all departments covered in the periodic inventory to confirm that the fixed asset listing is complete, updated and maintained.
Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual, corporation, association, unit of government, or legal entity, however organized) they are entering into a covered transaction with is not suspended or debarred by: (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: Verification that an entity was not suspended or debarred was not performed for one entity. Context: The University entered into covered transactions with six entities during the fiscal year. We selected a non-statistical sample of two entities for testing, noting verification that the entity was not suspended or debarred was not performed for one entity. We re-performed the verification and noted the entity did not have any exclusion records, indicating they were not suspended or debarred. Cause: Although the University has established policies and procedures in place over the procurement and suspension and debarment process, there was a lack of diligence in complying with obtaining or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process could result in noncompliance with the procurement and suspension and debarment requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the department to ensure that the required procedure for verification of Suspension and Debarment is consistently conducted and evidence of such procedure is maintained. The OSP Office will strengthen its policies and procedures so that the SAM screenshot for all covered transactions is complete and retained. The Principal Investigator should work collaboratively with the OSP to ensure that the documentation for suspension and debarment for vendors meeting this requirement is obtained and maintained. The Manager for Grants and Contracts will be sure to check the SAM.gov for suspension and debarment and will maintain the documentation. The Assistant VP of the Office of Sponsored Projects will review the documentation.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. Condition: The physical inventory was not conducted as required. Context: In October 2021, the University conducted a physical inventory of all of its fixed assets which includes property acquired with federal funds. To facilitate the inventory, the University distributed a memo to all department heads detailing the procedures needed to conduct a physical inventory and instructed them to perform a physical inventory in their respective departments by December 1, 2021. During our audit, it was noted that the physical inventory was not completed by all departments. Based on the information provided by management there were 16 property items that were subject to inventory; however, because the inventory documentation provided did not cover all departments, only 1 property item was identified through the physical inventory. Cause: Although the University has procedures in place over the physical inventory of property, there was a lack of diligence in complying with the procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years results in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for the physical inventory of equipment and ensure all departments timely complete the physical inventory. Views of responsible officials: The HPU Fixed Asset Accountant, Federal Grant Project Investigator and Office of Sponsored Projects will work collaboratively to ensure that the physical inventory of all fixed assets which were acquired using federal funds are conducted and completed periodically. This physical inventory monitoring will be done at least, every two years. The team will work on getting all departments covered in the periodic inventory to confirm that the fixed asset listing is complete, updated and maintained.
Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual, corporation, association, unit of government, or legal entity, however organized) they are entering into a covered transaction with is not suspended or debarred by: (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: Verification that an entity was not suspended or debarred was not performed for one entity. Context: The University entered into covered transactions with six entities during the fiscal year. We selected a non-statistical sample of two entities for testing, noting verification that the entity was not suspended or debarred was not performed for one entity. We re-performed the verification and noted the entity did not have any exclusion records, indicating they were not suspended or debarred. Cause: Although the University has established policies and procedures in place over the procurement and suspension and debarment process, there was a lack of diligence in complying with obtaining or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process could result in noncompliance with the procurement and suspension and debarment requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the department to ensure that the required procedure for verification of Suspension and Debarment is consistently conducted and evidence of such procedure is maintained. The OSP Office will strengthen its policies and procedures so that the SAM screenshot for all covered transactions is complete and retained. The Principal Investigator should work collaboratively with the OSP to ensure that the documentation for suspension and debarment for vendors meeting this requirement is obtained and maintained. The Manager for Grants and Contracts will be sure to check the SAM.gov for suspension and debarment and will maintain the documentation. The Assistant VP of the Office of Sponsored Projects will review the documentation.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.