Finding 2024-001
Federal Program Information: Federal Direct Student Loan Program (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Enrollment Reporting – The School is required to report enrollment information under the Direct loan program via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types.
Campus Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month.
Program Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including OPEID number, CIP code, CIP year, credit level, program enrollment status, program enrollment effective date, program length, and program begin date.
Condition: During our testing of student enrollment reporting, we noted the following exceptions:
• For 15 of 36 selected students, the School failed to submit the student’s graduated or withdrawn status to NSLDS within the required timeframe.
• For 22 of 36 selected students, the School did not accurately report the student’s campus level enrollment status to the NSLDS.
• For 3 of 25 selected students, there was no Program-Level Record on the NSLDS website to verify the school accurately reported the required significant data elements required by the U.S. Department of Education.
• For 1 of 25 selected students, the School did not accurately report the student’s program level information to NSLDS.
Cause: Insufficient administrative oversight and internal controls with respect to enrollment reporting requirements.
Effect or Potential Effect: The School is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to all aspects of enrollment reporting.
Questioned Costs: None.
Context: We tested a sample of students and found exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements using a statistically valid sample.
Identification as a Repeat Finding: This is a repeat finding from prior the year. This was reported as finding 2023-002 in the 2023 report.
Recommendation: We recommend that the School enhance its procedures and internal controls to ensure that all status changes are submitted to the NSLDS website within the required timeframe and all required data elements are reported on the NSLDS website.
Views of Responsible Officials and Planned Corrective Actions: We concur. We will review our procedures to ensure proper recording of these changes by NSLDS based on our submission to the National Student Clearinghouse. We will also implement an automated monitoring notification system that will alert us within the established timeframe of status changes to ensure accuracy in both third-party systems. Change in our submission process to the National Student Clearinghouse from 30 days to occur weekly to ensure timely reporting to NSLDS. All student records contained in the NSLDS for the Academic Term will be reviewed every month and the student roster will be reviewed weekly for accuracy in both third-party systems. We will complete the corrective action no later than March 31, 2025.
Finding 2024-002
Federal Program Information: COVID-19 Education Stabilization Fund - Higher Education Emergency Relief Fund (“HEERF”) (ALN: 84.425J), The National COVID-19 Resiliency Network (“NCRN”): Mitigating the Impact of COVID-19 on Vulnerable Populations (ALN: 93.137)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): L. Reporting – The School is required to comply with the requirements of Reporting associated with its federal awards.
According to the Uniform Guidance, the School must timely and accurately post the required HEERF quarterly reports to School’s website and must submit an annual HEERF report covering calendar year expenditures. Amounts reported should agree to accounting records that support the audited financial statements and the Schedule of Expenditures of Federal Awards (CARES Act 18004(e); CRRSAA 314(e); 2 CFR 200.328; 2 CFR section 200.329; 34 CFR 75.720(b)).
According to the NCRN grant agreement, the School must timely and accurately submit progress reports quarterly and must submit a final federal financial report (FFR) (SF-425/SF-425A) (OMB No. 0348-0061)). Amounts reported should agree to accounting records that support the audited financial statements and the Schedule of Expenditures of Federal Awards (2 CFR section 200.328).
Condition: During our testing of required reports, we noted the following exceptions:
• For 1 of 4 quarterly HEERF progress reports, the School did not submit the report within the required timeframe.
• For 4 of the 4 quarterly HEERF reports, certain information submitted to the funding agency or posted to the School’s website was not accurately presented and did not reconcile to the School’s records.
• For 1 of 1 NCRN final financial report, the School did not accurately report indirect cost totals that reconciled to the School’s records.
• For 1 of 1 NCRN final financial report, the School did not submit the report within the required timeframe.
Cause: Insufficient administrative oversight and internal controls with respect to reporting compliance requirements.
Effect or Potential Effect: The School does not have policies and procedures in place to ensure that compliance is maintained with respect to the reporting compliance requirements and timely submission of reports.
Questioned Costs: None.
Context: We tested all 4 quarterly HEERF progress reports and the NCRN final financial report and found 5 exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements using a statistically valid sample.
Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2023-003 in the 2023 report.
Recommendation: We recommend that the School enhance procedures and internal controls over the applicable reporting requirements to ensure compliance with federal regulations as well as the grant agreements.
Views of Responsible Officials and Planned Corrective Actions: We concur. We will review our processes and ensure timely and accurate completion of reporting. We will complete the corrective action no later than June 30, 2025.
Finding 2024-002
Federal Program Information: COVID-19 Education Stabilization Fund - Higher Education Emergency Relief Fund (“HEERF”) (ALN: 84.425J), The National COVID-19 Resiliency Network (“NCRN”): Mitigating the Impact of COVID-19 on Vulnerable Populations (ALN: 93.137)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): L. Reporting – The School is required to comply with the requirements of Reporting associated with its federal awards.
According to the Uniform Guidance, the School must timely and accurately post the required HEERF quarterly reports to School’s website and must submit an annual HEERF report covering calendar year expenditures. Amounts reported should agree to accounting records that support the audited financial statements and the Schedule of Expenditures of Federal Awards (CARES Act 18004(e); CRRSAA 314(e); 2 CFR 200.328; 2 CFR section 200.329; 34 CFR 75.720(b)).
According to the NCRN grant agreement, the School must timely and accurately submit progress reports quarterly and must submit a final federal financial report (FFR) (SF-425/SF-425A) (OMB No. 0348-0061)). Amounts reported should agree to accounting records that support the audited financial statements and the Schedule of Expenditures of Federal Awards (2 CFR section 200.328).
Condition: During our testing of required reports, we noted the following exceptions:
• For 1 of 4 quarterly HEERF progress reports, the School did not submit the report within the required timeframe.
• For 4 of the 4 quarterly HEERF reports, certain information submitted to the funding agency or posted to the School’s website was not accurately presented and did not reconcile to the School’s records.
• For 1 of 1 NCRN final financial report, the School did not accurately report indirect cost totals that reconciled to the School’s records.
• For 1 of 1 NCRN final financial report, the School did not submit the report within the required timeframe.
Cause: Insufficient administrative oversight and internal controls with respect to reporting compliance requirements.
Effect or Potential Effect: The School does not have policies and procedures in place to ensure that compliance is maintained with respect to the reporting compliance requirements and timely submission of reports.
Questioned Costs: None.
Context: We tested all 4 quarterly HEERF progress reports and the NCRN final financial report and found 5 exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements using a statistically valid sample.
Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2023-003 in the 2023 report.
Recommendation: We recommend that the School enhance procedures and internal controls over the applicable reporting requirements to ensure compliance with federal regulations as well as the grant agreements.
Views of Responsible Officials and Planned Corrective Actions: We concur. We will review our processes and ensure timely and accurate completion of reporting. We will complete the corrective action no later than June 30, 2025.
Finding 2024-003
Federal Program Information: Research and Development Cluster (ALN: 12.420), The National COVID-19 Resiliency Network (“NCRN”): Mitigating the Impact of COVID-19 on Vulnerable Populations (ALN: 93.137), COVID-19 Education Stabilization Fund - Higher Education Emergency Relief Fund (“HEERF”) (ALN: 84.425J), and Title III Part B Strengthening Historically Black Colleges and Universities (“Title III”) (ALN: 84.031)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) B. Allowable Cost/Cost Principles - Federal grant requirements, § 200.430, provide that salaries and wages charged to federal awards must be based on records that accurately reflect the work performed; be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; be incorporated into the official records of the institution; reasonably reflect the total activity for which the employee is compensated; and support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award.
Condition: During our testing of expenditures, we noted the following exceptions:
• For 1 of 25 selected Research and Development Cluster expenditures, level of effort certifications were not available to support the payroll costs charged to the federal program.
• For 1 of 25 selected NCRN expenditures, level of effort certification did not accurately reflect time and effort charged to the federal program.
• For 12 of 25 selected HEERF expenditures, level of effort certifications were not available to support the payroll costs charged to the federal program.
• For 1 of 25 selected Title III expenditures, level of effort certifications were not available to support the payroll costs charged to the federal program.
Cause: Insufficient administrative oversight and internal controls with respect to allowable cost/cost principles compliance requirements.
Effect or Potential Effect: The School does not have policies and procedures in place to ensure that compliance is maintained with respect to supporting payroll costs charged to the federal programs.
Questioned Costs: Indeterminable.
Context: We tested a sample of 100 expenditures across four major programs and noted 15 exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements using a statistically valid sample.
Views of Responsible Officials and Planned Corrective Actions: We concur. We are identifying personnel that will be allocated to federal awards to ensure all effort reports are reviewed and certified timely. During the next effort reporting cycle, the school will transition to a new automated system, Cayuse effort reporting. This will give the Office of Grants & Contracts Faculty and Staff increased visibility into the personnel allocated to federal awards in a more efficient manner. We will complete the corrective action no later than June 30, 2025.
Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2023-005 in the 2023 report.
Recommendation: We recommend that the School adhere to its procedures and internal controls over the applicable compliance requirements of allowable costs/cost principles requirements to ensure that the School is appropriately monitoring level of effort reporting in a timely manner.
Finding 2024-003
Federal Program Information: Research and Development Cluster (ALN: 12.420), The National COVID-19 Resiliency Network (“NCRN”): Mitigating the Impact of COVID-19 on Vulnerable Populations (ALN: 93.137), COVID-19 Education Stabilization Fund - Higher Education Emergency Relief Fund (“HEERF”) (ALN: 84.425J), and Title III Part B Strengthening Historically Black Colleges and Universities (“Title III”) (ALN: 84.031)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) B. Allowable Cost/Cost Principles - Federal grant requirements, § 200.430, provide that salaries and wages charged to federal awards must be based on records that accurately reflect the work performed; be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; be incorporated into the official records of the institution; reasonably reflect the total activity for which the employee is compensated; and support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award.
Condition: During our testing of expenditures, we noted the following exceptions:
• For 1 of 25 selected Research and Development Cluster expenditures, level of effort certifications were not available to support the payroll costs charged to the federal program.
• For 1 of 25 selected NCRN expenditures, level of effort certification did not accurately reflect time and effort charged to the federal program.
• For 12 of 25 selected HEERF expenditures, level of effort certifications were not available to support the payroll costs charged to the federal program.
• For 1 of 25 selected Title III expenditures, level of effort certifications were not available to support the payroll costs charged to the federal program.
Cause: Insufficient administrative oversight and internal controls with respect to allowable cost/cost principles compliance requirements.
Effect or Potential Effect: The School does not have policies and procedures in place to ensure that compliance is maintained with respect to supporting payroll costs charged to the federal programs.
Questioned Costs: Indeterminable.
Context: We tested a sample of 100 expenditures across four major programs and noted 15 exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements using a statistically valid sample.
Views of Responsible Officials and Planned Corrective Actions: We concur. We are identifying personnel that will be allocated to federal awards to ensure all effort reports are reviewed and certified timely. During the next effort reporting cycle, the school will transition to a new automated system, Cayuse effort reporting. This will give the Office of Grants & Contracts Faculty and Staff increased visibility into the personnel allocated to federal awards in a more efficient manner. We will complete the corrective action no later than June 30, 2025.
Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2023-005 in the 2023 report.
Recommendation: We recommend that the School adhere to its procedures and internal controls over the applicable compliance requirements of allowable costs/cost principles requirements to ensure that the School is appropriately monitoring level of effort reporting in a timely manner.
Finding 2024-003
Federal Program Information: Research and Development Cluster (ALN: 12.420), The National COVID-19 Resiliency Network (“NCRN”): Mitigating the Impact of COVID-19 on Vulnerable Populations (ALN: 93.137), COVID-19 Education Stabilization Fund - Higher Education Emergency Relief Fund (“HEERF”) (ALN: 84.425J), and Title III Part B Strengthening Historically Black Colleges and Universities (“Title III”) (ALN: 84.031)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) B. Allowable Cost/Cost Principles - Federal grant requirements, § 200.430, provide that salaries and wages charged to federal awards must be based on records that accurately reflect the work performed; be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; be incorporated into the official records of the institution; reasonably reflect the total activity for which the employee is compensated; and support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award.
Condition: During our testing of expenditures, we noted the following exceptions:
• For 1 of 25 selected Research and Development Cluster expenditures, level of effort certifications were not available to support the payroll costs charged to the federal program.
• For 1 of 25 selected NCRN expenditures, level of effort certification did not accurately reflect time and effort charged to the federal program.
• For 12 of 25 selected HEERF expenditures, level of effort certifications were not available to support the payroll costs charged to the federal program.
• For 1 of 25 selected Title III expenditures, level of effort certifications were not available to support the payroll costs charged to the federal program.
Cause: Insufficient administrative oversight and internal controls with respect to allowable cost/cost principles compliance requirements.
Effect or Potential Effect: The School does not have policies and procedures in place to ensure that compliance is maintained with respect to supporting payroll costs charged to the federal programs.
Questioned Costs: Indeterminable.
Context: We tested a sample of 100 expenditures across four major programs and noted 15 exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements using a statistically valid sample.
Views of Responsible Officials and Planned Corrective Actions: We concur. We are identifying personnel that will be allocated to federal awards to ensure all effort reports are reviewed and certified timely. During the next effort reporting cycle, the school will transition to a new automated system, Cayuse effort reporting. This will give the Office of Grants & Contracts Faculty and Staff increased visibility into the personnel allocated to federal awards in a more efficient manner. We will complete the corrective action no later than June 30, 2025.
Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2023-005 in the 2023 report.
Recommendation: We recommend that the School adhere to its procedures and internal controls over the applicable compliance requirements of allowable costs/cost principles requirements to ensure that the School is appropriately monitoring level of effort reporting in a timely manner.
Finding 2024-003
Federal Program Information: Research and Development Cluster (ALN: 12.420), The National COVID-19 Resiliency Network (“NCRN”): Mitigating the Impact of COVID-19 on Vulnerable Populations (ALN: 93.137), COVID-19 Education Stabilization Fund - Higher Education Emergency Relief Fund (“HEERF”) (ALN: 84.425J), and Title III Part B Strengthening Historically Black Colleges and Universities (“Title III”) (ALN: 84.031)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) B. Allowable Cost/Cost Principles - Federal grant requirements, § 200.430, provide that salaries and wages charged to federal awards must be based on records that accurately reflect the work performed; be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; be incorporated into the official records of the institution; reasonably reflect the total activity for which the employee is compensated; and support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award.
Condition: During our testing of expenditures, we noted the following exceptions:
• For 1 of 25 selected Research and Development Cluster expenditures, level of effort certifications were not available to support the payroll costs charged to the federal program.
• For 1 of 25 selected NCRN expenditures, level of effort certification did not accurately reflect time and effort charged to the federal program.
• For 12 of 25 selected HEERF expenditures, level of effort certifications were not available to support the payroll costs charged to the federal program.
• For 1 of 25 selected Title III expenditures, level of effort certifications were not available to support the payroll costs charged to the federal program.
Cause: Insufficient administrative oversight and internal controls with respect to allowable cost/cost principles compliance requirements.
Effect or Potential Effect: The School does not have policies and procedures in place to ensure that compliance is maintained with respect to supporting payroll costs charged to the federal programs.
Questioned Costs: Indeterminable.
Context: We tested a sample of 100 expenditures across four major programs and noted 15 exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements using a statistically valid sample.
Views of Responsible Officials and Planned Corrective Actions: We concur. We are identifying personnel that will be allocated to federal awards to ensure all effort reports are reviewed and certified timely. During the next effort reporting cycle, the school will transition to a new automated system, Cayuse effort reporting. This will give the Office of Grants & Contracts Faculty and Staff increased visibility into the personnel allocated to federal awards in a more efficient manner. We will complete the corrective action no later than June 30, 2025.
Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2023-005 in the 2023 report.
Recommendation: We recommend that the School adhere to its procedures and internal controls over the applicable compliance requirements of allowable costs/cost principles requirements to ensure that the School is appropriately monitoring level of effort reporting in a timely manner.
Finding 2024-001
Federal Program Information: Federal Direct Student Loan Program (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Enrollment Reporting – The School is required to report enrollment information under the Direct loan program via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types.
Campus Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month.
Program Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including OPEID number, CIP code, CIP year, credit level, program enrollment status, program enrollment effective date, program length, and program begin date.
Condition: During our testing of student enrollment reporting, we noted the following exceptions:
• For 15 of 36 selected students, the School failed to submit the student’s graduated or withdrawn status to NSLDS within the required timeframe.
• For 22 of 36 selected students, the School did not accurately report the student’s campus level enrollment status to the NSLDS.
• For 3 of 25 selected students, there was no Program-Level Record on the NSLDS website to verify the school accurately reported the required significant data elements required by the U.S. Department of Education.
• For 1 of 25 selected students, the School did not accurately report the student’s program level information to NSLDS.
Cause: Insufficient administrative oversight and internal controls with respect to enrollment reporting requirements.
Effect or Potential Effect: The School is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to all aspects of enrollment reporting.
Questioned Costs: None.
Context: We tested a sample of students and found exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements using a statistically valid sample.
Identification as a Repeat Finding: This is a repeat finding from prior the year. This was reported as finding 2023-002 in the 2023 report.
Recommendation: We recommend that the School enhance its procedures and internal controls to ensure that all status changes are submitted to the NSLDS website within the required timeframe and all required data elements are reported on the NSLDS website.
Views of Responsible Officials and Planned Corrective Actions: We concur. We will review our procedures to ensure proper recording of these changes by NSLDS based on our submission to the National Student Clearinghouse. We will also implement an automated monitoring notification system that will alert us within the established timeframe of status changes to ensure accuracy in both third-party systems. Change in our submission process to the National Student Clearinghouse from 30 days to occur weekly to ensure timely reporting to NSLDS. All student records contained in the NSLDS for the Academic Term will be reviewed every month and the student roster will be reviewed weekly for accuracy in both third-party systems. We will complete the corrective action no later than March 31, 2025.
Finding 2024-002
Federal Program Information: COVID-19 Education Stabilization Fund - Higher Education Emergency Relief Fund (“HEERF”) (ALN: 84.425J), The National COVID-19 Resiliency Network (“NCRN”): Mitigating the Impact of COVID-19 on Vulnerable Populations (ALN: 93.137)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): L. Reporting – The School is required to comply with the requirements of Reporting associated with its federal awards.
According to the Uniform Guidance, the School must timely and accurately post the required HEERF quarterly reports to School’s website and must submit an annual HEERF report covering calendar year expenditures. Amounts reported should agree to accounting records that support the audited financial statements and the Schedule of Expenditures of Federal Awards (CARES Act 18004(e); CRRSAA 314(e); 2 CFR 200.328; 2 CFR section 200.329; 34 CFR 75.720(b)).
According to the NCRN grant agreement, the School must timely and accurately submit progress reports quarterly and must submit a final federal financial report (FFR) (SF-425/SF-425A) (OMB No. 0348-0061)). Amounts reported should agree to accounting records that support the audited financial statements and the Schedule of Expenditures of Federal Awards (2 CFR section 200.328).
Condition: During our testing of required reports, we noted the following exceptions:
• For 1 of 4 quarterly HEERF progress reports, the School did not submit the report within the required timeframe.
• For 4 of the 4 quarterly HEERF reports, certain information submitted to the funding agency or posted to the School’s website was not accurately presented and did not reconcile to the School’s records.
• For 1 of 1 NCRN final financial report, the School did not accurately report indirect cost totals that reconciled to the School’s records.
• For 1 of 1 NCRN final financial report, the School did not submit the report within the required timeframe.
Cause: Insufficient administrative oversight and internal controls with respect to reporting compliance requirements.
Effect or Potential Effect: The School does not have policies and procedures in place to ensure that compliance is maintained with respect to the reporting compliance requirements and timely submission of reports.
Questioned Costs: None.
Context: We tested all 4 quarterly HEERF progress reports and the NCRN final financial report and found 5 exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements using a statistically valid sample.
Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2023-003 in the 2023 report.
Recommendation: We recommend that the School enhance procedures and internal controls over the applicable reporting requirements to ensure compliance with federal regulations as well as the grant agreements.
Views of Responsible Officials and Planned Corrective Actions: We concur. We will review our processes and ensure timely and accurate completion of reporting. We will complete the corrective action no later than June 30, 2025.
Finding 2024-002
Federal Program Information: COVID-19 Education Stabilization Fund - Higher Education Emergency Relief Fund (“HEERF”) (ALN: 84.425J), The National COVID-19 Resiliency Network (“NCRN”): Mitigating the Impact of COVID-19 on Vulnerable Populations (ALN: 93.137)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): L. Reporting – The School is required to comply with the requirements of Reporting associated with its federal awards.
According to the Uniform Guidance, the School must timely and accurately post the required HEERF quarterly reports to School’s website and must submit an annual HEERF report covering calendar year expenditures. Amounts reported should agree to accounting records that support the audited financial statements and the Schedule of Expenditures of Federal Awards (CARES Act 18004(e); CRRSAA 314(e); 2 CFR 200.328; 2 CFR section 200.329; 34 CFR 75.720(b)).
According to the NCRN grant agreement, the School must timely and accurately submit progress reports quarterly and must submit a final federal financial report (FFR) (SF-425/SF-425A) (OMB No. 0348-0061)). Amounts reported should agree to accounting records that support the audited financial statements and the Schedule of Expenditures of Federal Awards (2 CFR section 200.328).
Condition: During our testing of required reports, we noted the following exceptions:
• For 1 of 4 quarterly HEERF progress reports, the School did not submit the report within the required timeframe.
• For 4 of the 4 quarterly HEERF reports, certain information submitted to the funding agency or posted to the School’s website was not accurately presented and did not reconcile to the School’s records.
• For 1 of 1 NCRN final financial report, the School did not accurately report indirect cost totals that reconciled to the School’s records.
• For 1 of 1 NCRN final financial report, the School did not submit the report within the required timeframe.
Cause: Insufficient administrative oversight and internal controls with respect to reporting compliance requirements.
Effect or Potential Effect: The School does not have policies and procedures in place to ensure that compliance is maintained with respect to the reporting compliance requirements and timely submission of reports.
Questioned Costs: None.
Context: We tested all 4 quarterly HEERF progress reports and the NCRN final financial report and found 5 exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements using a statistically valid sample.
Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2023-003 in the 2023 report.
Recommendation: We recommend that the School enhance procedures and internal controls over the applicable reporting requirements to ensure compliance with federal regulations as well as the grant agreements.
Views of Responsible Officials and Planned Corrective Actions: We concur. We will review our processes and ensure timely and accurate completion of reporting. We will complete the corrective action no later than June 30, 2025.
Finding 2024-003
Federal Program Information: Research and Development Cluster (ALN: 12.420), The National COVID-19 Resiliency Network (“NCRN”): Mitigating the Impact of COVID-19 on Vulnerable Populations (ALN: 93.137), COVID-19 Education Stabilization Fund - Higher Education Emergency Relief Fund (“HEERF”) (ALN: 84.425J), and Title III Part B Strengthening Historically Black Colleges and Universities (“Title III”) (ALN: 84.031)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) B. Allowable Cost/Cost Principles - Federal grant requirements, § 200.430, provide that salaries and wages charged to federal awards must be based on records that accurately reflect the work performed; be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; be incorporated into the official records of the institution; reasonably reflect the total activity for which the employee is compensated; and support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award.
Condition: During our testing of expenditures, we noted the following exceptions:
• For 1 of 25 selected Research and Development Cluster expenditures, level of effort certifications were not available to support the payroll costs charged to the federal program.
• For 1 of 25 selected NCRN expenditures, level of effort certification did not accurately reflect time and effort charged to the federal program.
• For 12 of 25 selected HEERF expenditures, level of effort certifications were not available to support the payroll costs charged to the federal program.
• For 1 of 25 selected Title III expenditures, level of effort certifications were not available to support the payroll costs charged to the federal program.
Cause: Insufficient administrative oversight and internal controls with respect to allowable cost/cost principles compliance requirements.
Effect or Potential Effect: The School does not have policies and procedures in place to ensure that compliance is maintained with respect to supporting payroll costs charged to the federal programs.
Questioned Costs: Indeterminable.
Context: We tested a sample of 100 expenditures across four major programs and noted 15 exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements using a statistically valid sample.
Views of Responsible Officials and Planned Corrective Actions: We concur. We are identifying personnel that will be allocated to federal awards to ensure all effort reports are reviewed and certified timely. During the next effort reporting cycle, the school will transition to a new automated system, Cayuse effort reporting. This will give the Office of Grants & Contracts Faculty and Staff increased visibility into the personnel allocated to federal awards in a more efficient manner. We will complete the corrective action no later than June 30, 2025.
Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2023-005 in the 2023 report.
Recommendation: We recommend that the School adhere to its procedures and internal controls over the applicable compliance requirements of allowable costs/cost principles requirements to ensure that the School is appropriately monitoring level of effort reporting in a timely manner.
Finding 2024-003
Federal Program Information: Research and Development Cluster (ALN: 12.420), The National COVID-19 Resiliency Network (“NCRN”): Mitigating the Impact of COVID-19 on Vulnerable Populations (ALN: 93.137), COVID-19 Education Stabilization Fund - Higher Education Emergency Relief Fund (“HEERF”) (ALN: 84.425J), and Title III Part B Strengthening Historically Black Colleges and Universities (“Title III”) (ALN: 84.031)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) B. Allowable Cost/Cost Principles - Federal grant requirements, § 200.430, provide that salaries and wages charged to federal awards must be based on records that accurately reflect the work performed; be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; be incorporated into the official records of the institution; reasonably reflect the total activity for which the employee is compensated; and support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award.
Condition: During our testing of expenditures, we noted the following exceptions:
• For 1 of 25 selected Research and Development Cluster expenditures, level of effort certifications were not available to support the payroll costs charged to the federal program.
• For 1 of 25 selected NCRN expenditures, level of effort certification did not accurately reflect time and effort charged to the federal program.
• For 12 of 25 selected HEERF expenditures, level of effort certifications were not available to support the payroll costs charged to the federal program.
• For 1 of 25 selected Title III expenditures, level of effort certifications were not available to support the payroll costs charged to the federal program.
Cause: Insufficient administrative oversight and internal controls with respect to allowable cost/cost principles compliance requirements.
Effect or Potential Effect: The School does not have policies and procedures in place to ensure that compliance is maintained with respect to supporting payroll costs charged to the federal programs.
Questioned Costs: Indeterminable.
Context: We tested a sample of 100 expenditures across four major programs and noted 15 exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements using a statistically valid sample.
Views of Responsible Officials and Planned Corrective Actions: We concur. We are identifying personnel that will be allocated to federal awards to ensure all effort reports are reviewed and certified timely. During the next effort reporting cycle, the school will transition to a new automated system, Cayuse effort reporting. This will give the Office of Grants & Contracts Faculty and Staff increased visibility into the personnel allocated to federal awards in a more efficient manner. We will complete the corrective action no later than June 30, 2025.
Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2023-005 in the 2023 report.
Recommendation: We recommend that the School adhere to its procedures and internal controls over the applicable compliance requirements of allowable costs/cost principles requirements to ensure that the School is appropriately monitoring level of effort reporting in a timely manner.
Finding 2024-003
Federal Program Information: Research and Development Cluster (ALN: 12.420), The National COVID-19 Resiliency Network (“NCRN”): Mitigating the Impact of COVID-19 on Vulnerable Populations (ALN: 93.137), COVID-19 Education Stabilization Fund - Higher Education Emergency Relief Fund (“HEERF”) (ALN: 84.425J), and Title III Part B Strengthening Historically Black Colleges and Universities (“Title III”) (ALN: 84.031)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) B. Allowable Cost/Cost Principles - Federal grant requirements, § 200.430, provide that salaries and wages charged to federal awards must be based on records that accurately reflect the work performed; be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; be incorporated into the official records of the institution; reasonably reflect the total activity for which the employee is compensated; and support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award.
Condition: During our testing of expenditures, we noted the following exceptions:
• For 1 of 25 selected Research and Development Cluster expenditures, level of effort certifications were not available to support the payroll costs charged to the federal program.
• For 1 of 25 selected NCRN expenditures, level of effort certification did not accurately reflect time and effort charged to the federal program.
• For 12 of 25 selected HEERF expenditures, level of effort certifications were not available to support the payroll costs charged to the federal program.
• For 1 of 25 selected Title III expenditures, level of effort certifications were not available to support the payroll costs charged to the federal program.
Cause: Insufficient administrative oversight and internal controls with respect to allowable cost/cost principles compliance requirements.
Effect or Potential Effect: The School does not have policies and procedures in place to ensure that compliance is maintained with respect to supporting payroll costs charged to the federal programs.
Questioned Costs: Indeterminable.
Context: We tested a sample of 100 expenditures across four major programs and noted 15 exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements using a statistically valid sample.
Views of Responsible Officials and Planned Corrective Actions: We concur. We are identifying personnel that will be allocated to federal awards to ensure all effort reports are reviewed and certified timely. During the next effort reporting cycle, the school will transition to a new automated system, Cayuse effort reporting. This will give the Office of Grants & Contracts Faculty and Staff increased visibility into the personnel allocated to federal awards in a more efficient manner. We will complete the corrective action no later than June 30, 2025.
Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2023-005 in the 2023 report.
Recommendation: We recommend that the School adhere to its procedures and internal controls over the applicable compliance requirements of allowable costs/cost principles requirements to ensure that the School is appropriately monitoring level of effort reporting in a timely manner.
Finding 2024-003
Federal Program Information: Research and Development Cluster (ALN: 12.420), The National COVID-19 Resiliency Network (“NCRN”): Mitigating the Impact of COVID-19 on Vulnerable Populations (ALN: 93.137), COVID-19 Education Stabilization Fund - Higher Education Emergency Relief Fund (“HEERF”) (ALN: 84.425J), and Title III Part B Strengthening Historically Black Colleges and Universities (“Title III”) (ALN: 84.031)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) B. Allowable Cost/Cost Principles - Federal grant requirements, § 200.430, provide that salaries and wages charged to federal awards must be based on records that accurately reflect the work performed; be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; be incorporated into the official records of the institution; reasonably reflect the total activity for which the employee is compensated; and support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award.
Condition: During our testing of expenditures, we noted the following exceptions:
• For 1 of 25 selected Research and Development Cluster expenditures, level of effort certifications were not available to support the payroll costs charged to the federal program.
• For 1 of 25 selected NCRN expenditures, level of effort certification did not accurately reflect time and effort charged to the federal program.
• For 12 of 25 selected HEERF expenditures, level of effort certifications were not available to support the payroll costs charged to the federal program.
• For 1 of 25 selected Title III expenditures, level of effort certifications were not available to support the payroll costs charged to the federal program.
Cause: Insufficient administrative oversight and internal controls with respect to allowable cost/cost principles compliance requirements.
Effect or Potential Effect: The School does not have policies and procedures in place to ensure that compliance is maintained with respect to supporting payroll costs charged to the federal programs.
Questioned Costs: Indeterminable.
Context: We tested a sample of 100 expenditures across four major programs and noted 15 exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements using a statistically valid sample.
Views of Responsible Officials and Planned Corrective Actions: We concur. We are identifying personnel that will be allocated to federal awards to ensure all effort reports are reviewed and certified timely. During the next effort reporting cycle, the school will transition to a new automated system, Cayuse effort reporting. This will give the Office of Grants & Contracts Faculty and Staff increased visibility into the personnel allocated to federal awards in a more efficient manner. We will complete the corrective action no later than June 30, 2025.
Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2023-005 in the 2023 report.
Recommendation: We recommend that the School adhere to its procedures and internal controls over the applicable compliance requirements of allowable costs/cost principles requirements to ensure that the School is appropriately monitoring level of effort reporting in a timely manner.