Dairy Business Innovation Initiatives—Cash Management
Background:
During FY 2023-24, UW-Madison expended $9.9 million in federal funds for the DBII grant, which is administered by the U.S. Department of Agriculture. This grant program was first authorized in 2018, and UW Madison has received annual awards for the program since 2019. At least one-half of each award is used for grants to farmers or dairy processors to diversify farming activities, create value-added products, or enhance dairy export programs. For each DBII award UW Madison received, it subawarded approximately 60.0 percent to a subrecipient to assist with administering the grants to farmers and dairy processors under the program.
Criteria:
Under 2 CFR s. 200.305 (b), UW-Madison is required to implement procedures to ensure that the time between payments it makes to the subrecipient and the subrecipient’s disbursement of the funds for program purposes is minimized. Under 2 CFR s. 200.305 (b) (4), UW-Madison is permitted to provide advanced payments to a subrecipient if it determines that the subrecipient lacks sufficient working capital. However, if such an advanced payment is made, the payment should be aligned to the anticipated disbursements and subsequent payments are required to be on a reimbursement basis. Finally, 2 CFR s. 200.305 (b) (12), requires that any payments UW Madison makes to a subrecipient should not result in the subrecipient retaining more than $500 in interest earnings and any interest earnings that exceed $500 should be annually remitted to the federal government.
Condition:
We noted three concerns with UW-Madison cash management procedures for advancing funds to the subrecipient. First, we identified that UW-Madison did not ensure that the time between the subrecipient receiving funds and the subrecipient disbursing the funds to grant recipients was appropriately minimized. According to the subrecipient records, the subrecipient did not begin disbursing funds it received
in June 2023 until January 2024. Second, although UW Madison provided advanced payments to the DBII subrecipient, it did not use the reimbursement method when subsequent payments were made to the subrecipient. Third, UW Madison did not adequately monitor interest that had accrued on the subrecipient’s cash balance. As a result, the subrecipient’s records identified that it had accrued $148,357 in interest earnings in excess of federal requirements from August 2022 to August 2024, and no interest had been returned to the federal government as of June 30, 2024.
Context:
UW Madison made payments totaling $6.3 million to the DBII subrecipient during FY 2023 24, which included advancing funding to the subrecipient to enable the subrecipient to make payments as requested from grant recipients. We reviewed the subrecipient’s financial information to assess UW Madison’s decision to provide advanced payments to the subrecipient on the basis of a lack of sufficient working capital. We also reviewed UW Madison’s procedures for communicating the requirements for funds it advanced to the subrecipient, monitoring the subrecipient’s payments to grant recipients, and assessing how and when to advance funds to the subrecipient based on the payments anticipated for grants awarded. Information provided by the subrecipient indicated that, on average, the subrecipient held a cash balance of $3.9 million each month during FY 2023 24.
Questioned Costs:
None.
Effect:
UW Madison did not comply with federal requirements to ensure that time was minimized between payments to its subrecipient for the DBII grant and when the subrecipient disbursed the funds to grant recipients. In addition, UW-Madison did not comply with federal requirements to return interest earned by its subrecipient in a timely manner.
Cause:
First, UW Madison’s practice of making an advanced payment to the DBII subrecipient at the time a subaward was executed did not evaluate when the subrecipient would need to make payments to grant recipients. After UW-Madison made an initial advanced payment to the subrecipient to assist the subrecipient with managing cash flow needs, it required the subrecipient to expend 80.0 percent of the funds it had advanced before UW Madison would authorize additional payments. UW Madison also made decisions on whether to make further payments to the subrecipient for each subaward rather than reviewing the subrecipient’s available cash balance across multiple subawards. This resulted in the subrecipient having larger balances over time from advanced funds it received under multiple DBII awards.
Second, UW Madison staff indicated that UW Madison did not typically provide advanced payments to a subrecipient. As a result, it did not sufficiently consider all the federal requirements, such as using the reimbursement method for payments to the subrecipient subsequent to the initial advanced payment. UW Madison also did not include all relevant information in its subrecipient agreement related to cash management requirements.
Third, the DBII subrecipient did not inform UW Madison of interest earnings it had accumulated nor did UW Madison inquire with the subrecipient about any interest earnings to assess whether any had been earned in excess of federal requirements. UW Madison did not review aggregated balances from advance payments made under multiple subawards. In July 2024, the DBII subrecipient asked UW Madison
how interest earnings it had accumulated could be expended. UW Madison determined that the funds were required to be returned to the federal government. In October 2024, the subrecipient reported its interest earnings to UW-Madison and subsequently remitted $148,357 to UW Madison. UW Madison returned these funds to the federal government in January 2025.
Recommendation:
We recommend the University of Wisconsin Madison revise and document its procedures for:
-ensuring that its disbursements to the subrecipient complies with all federal cash management requirements;
-identifying applicable federal requirements to include in its subrecipient agreements when advanced cash payments are made, including requirements for interest earnings that results from advanced payments; and
-monitoring interest earnings that accrue to the subrecipient when advanced payments are made and returning in a timely manner any interest that exceeds federal limits.
Finding 2024-713: Dairy Business Innovation Initiatives—Cash Management
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM190100XXXG079 2019
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the cash management compliance requirement.
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendations.
Dairy Business Innovation Initiatives—Subrecipient Monitoring
Background:
During FY 2023-24, UW-Madison expended $9.9 million in federal funds for the DBII grant, which is administered by the U.S. Department of Agriculture. This grant program was first authorized in 2018, and UW-Madison has received annual awards for the program since 2019. UW-Madison subawarded approximately 60.0 percent of each DBII award it received to a subrecipient. The subrecipient’s primary function was to award grants to farmers or dairy processors to diversify farming activities, create value-added products, or enhance dairy export programs.
Criteria:
Under 2 CFR s. 200.332 (e), UW-Madison is required to monitor the activities of a subrecipient as necessary to ensure the subrecipient complies with federal statutes, regulations, and the terms and conditions of the subaward. Additionally, under 2 CFR s. 200.332 (f), pass-through entities must verify that a subrecipient is audited as required by 2 CFR Part 200 Subpart F, which requires that certain entities expending $750,000
or more of federal funds during a year have a single audit performed. UW Madison’s Research and Sponsored Programs (RSP) is responsible for monitoring subrecipient audit requirements prior to entering into contracts. As part of fulfilling its requirements under 2 CFR s. 200.332 (d), RSP requires subrecipients to complete an annual audit certification and provide a copy of its single audit, if applicable.
Condition:
We identified from UW Madison’s expenditures that it made payments to the DBII subrecipient of more than $750,000 during FY 2022-23 and, therefore, the subrecipient should have been subject to a single audit. However, UW Madison did not sufficiently monitor the subrecipient during FY 2023 24 to ensure the subrecipient was audited as required by 2 CFR s. 200.332 (f). The subrecipient did not have a FY 2022-23 single audit performed.
Context:
UW Madison made payments totaling $6.3 million to the DBII subrecipient during FY 2023 24 with a similar amount provided in the prior fiscal year. We reviewed the April 2024 annual audit certification submitted by the subrecipient, which included whether the subrecipient had completed a single audit for FY 2022 23. We searched the federal audit clearinghouse to determine whether the DBII subrecipient had submitted a single audit report. After we raised the issue, UW Madison contacted the subrecipient. UW-Madison indicated to us that the subrecipient had misunderstood the requirements.
Questioned Costs:
None.
Effect:
Without adequate monitoring, there is an increased risk of unallowable costs being charged to the DBII grant, or other noncompliance with federal regulations.
Cause:
RSP did not adequately evaluate the annual audit certification provided by the DBII subrecipient or perform other procedures to identify that an audit was required for the subrecipient.
Recommendation:
We recommend the University of Wisconsin Madison update its procedures for reviewing annual audit certifications received from subrecipients to include reviewing
its expenditures with a subrecipient or other procedures to assist it in assessing subrecipient responses.
Finding 2024-701: Dairy Business Innovation Initiatives—Subrecipient Monitoring
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Dairy Business Innovation Initiatives—Federal Funding Accountability and Transparency Act Reporting
Background:
During FY 2023-24, UW-Madison expended $9.9 million in federal funds for the DBII grant, which is administered by the U.S. Department of Agriculture. This grant program was first authorized in 2018, and UW-Madison has received annual awards for the program since 2019. UW-Madison subawarded approximately 60.0 percent of each DBII award it received to a subrecipient. The subrecipient’s primary function was to award grants to farmers or dairy processors to diversify farming activities, create value-added products, or enhance dairy export programs.
Under the Federal Funding Accountability and Transparency Act (FFATA), a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
Criteria:
Under 2 CFR s. 170, UW-Madison is required to report in the FFATA Subaward Reporting System (FSRS) subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the subaward was made. For example, if the subaward was made on November 7, 2023, it must be reported in FSRS no later than December 31, 2023. DBII subawards of $30,000 or more are subject to FFATA reporting. UW Madison’s RSP is responsible for reporting subaward information to FSRS.
Condition:
Of the two subaward actions that occurred in FY 2023 24 for the DBII grant, we found UW Madison did not report one subaward action in a timely manner in FSRS. Although UW Madison completed a $250,000 subaward modification to a subrecipient in October 2023, it did not submit the information in FSRS until December 2024 after we inquired about FFATA reporting for DBII.
Context:
We discussed with RSP staff its procedures for identifying subawards that require reporting to FSRS. We reviewed subawards UW Madison executed or modified for DBII during FY 2023 24 to identify whether FFATA reporting requirements applied. We assessed whether the subaward actions were accurately and entered into FSRS in a timely manner.
Questioned Costs:
None.
Effect:
UW Madison’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov for DBII. UW Madison did not comply with FFATA requirements for the timely reporting of subawards in FSRS for DBII.
Cause:
RSP staff indicated that an error occurred during the November 2023 submission process that prevented the subaward information from being uploaded in FSRS. A subsequent monthly error report identified that the federal aid identification number was not found in FSRS, yet RSP did not resolve this error until we inquired about FFATA reporting. No other detective procedures were in place to identify that FFATA reporting had not occurred for the subaward.
Recommendation:
We recommend the University of Wisconsin Madison:
-review and update its procedures for reviewing the FFATA Subaward Reporting System (FSRS) reporting errors and taking corrective action in a timely manner on all reported errors; and
-implement other monitoring procedures to ensure FSRS reporting is accurate and completed in a timely manner.
Finding 2024-702: Dairy Business Innovation Initiatives—Federal Funding Accountability and Transparency Act Reporting
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting
Background:
The U.S. Department of Agriculture provides funding to DPI through the programs of CNC. The purpose of these programs is to:
-assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential child care institutions, and summer programs;
-foster healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary schools; and
-encourage the domestic consumption of nutritious agricultural commodities.
DPI subawards CNC funding to schools and other entities to execute the programs.
Under the Federal Funding Accountability and Transparency Act (FFATA), a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
Criteria:
Under 2 CFR s. 170, DPI is required to report in the FFATA Subaward Reporting System (FSRS) subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the subaward was made. For example, if the subaward was made on November 7, 2023, it must be reported in FSRS not later than December 31, 2023. CNC subawards of $30,000 or more are subject to FFATA reporting.
Condition:
Although DPI made subawards of $30,000 or more in CNC funding to schools and other entities in FY 2023-24, DPI did not report any CNC subawards in FSRS during FY 2023-24.
Context:
Of the $361.0 million expended during FY 2023-24 under CNC, DPI disbursed $342.4 million to schools and other entities. We interviewed DPI staff to gain an understanding of the procedures for compiling information for CNC subawards and submitting the information in FSRS.
Questioned Costs:
None.
Effect:
The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov for CNC. DPI did not comply with FFATA requirements for the timely reporting of subawards in FSRS for CNC.
Cause:
Although DPI staff completed FFATA reporting for other grant programs DPI administers, DPI staff did not identify that FFATA reporting requirements applied to CNC. As a result, DPI did not have policies or procedures to collect the required subaward information for CNC programs from DPI’s computer system. Therefore, this information was not reported in FSRS.
As a result of our inquires, DPI staff discussed the requirements with the U.S. Department of Agriculture to understand how to collect the subaward information required to be reported in FSRS for the CNC programs.
Recommendation:
We recommend the Wisconsin Department of Public Instruction:
-develop written policies and procedures for identifying when Federal Funding Accountability and Transparency Act (FFATA) reporting requirements are applicable to a federal award it administers;
-develop written policies and procedures for timely identification and reporting of Child Nutrition Cluster program subawards of $30,000 or more, including any amendments or modifications to a subaward, to the FFATA Subaward Reporting System; and
-complete monthly FFATA reporting for the Child Nutrition Cluster programs following the established policies and procedures.
Finding 2024-400: Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting
Child Nutrition Cluster (Assistance Listing numbers 10.553, 10.555, 10.556, 10.559, and 10.582)
Award Numbers Award Years
212WI063N1099 2021
212WI063N1199 2021
212WI063N8903 2021
222WI063N1099 2022
222WI063N1199 2022
222WI063N8903 2022
232WI063N1099 2023
232WI063N1199 2023
232WI063L1603 2023
242WI063N1099 2024
242WI063N1199 2024
242WI063N8903 2024
242WI063L1603 2024
Questioned Costs: None
COVID-19—National School Lunch Program (Assistance Listing number 10.555)
Award Number Award Year
232WI063N8903 2023
Questioned Costs: None
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the reporting compliance requirement.
Response from the Wisconsin Department of Public Instruction: The Wisconsin Department of Public Instruction agrees with the audit finding and recommendations.
Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting
Background:
The U.S. Department of Agriculture provides funding to DPI through the programs of CNC. The purpose of these programs is to:
-assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential child care institutions, and summer programs;
-foster healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary schools; and
-encourage the domestic consumption of nutritious agricultural commodities.
DPI subawards CNC funding to schools and other entities to execute the programs.
Under the Federal Funding Accountability and Transparency Act (FFATA), a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
Criteria:
Under 2 CFR s. 170, DPI is required to report in the FFATA Subaward Reporting System (FSRS) subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the subaward was made. For example, if the subaward was made on November 7, 2023, it must be reported in FSRS not later than December 31, 2023. CNC subawards of $30,000 or more are subject to FFATA reporting.
Condition:
Although DPI made subawards of $30,000 or more in CNC funding to schools and other entities in FY 2023-24, DPI did not report any CNC subawards in FSRS during FY 2023-24.
Context:
Of the $361.0 million expended during FY 2023-24 under CNC, DPI disbursed $342.4 million to schools and other entities. We interviewed DPI staff to gain an understanding of the procedures for compiling information for CNC subawards and submitting the information in FSRS.
Questioned Costs:
None.
Effect:
The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov for CNC. DPI did not comply with FFATA requirements for the timely reporting of subawards in FSRS for CNC.
Cause:
Although DPI staff completed FFATA reporting for other grant programs DPI administers, DPI staff did not identify that FFATA reporting requirements applied to CNC. As a result, DPI did not have policies or procedures to collect the required subaward information for CNC programs from DPI’s computer system. Therefore, this information was not reported in FSRS.
As a result of our inquires, DPI staff discussed the requirements with the U.S. Department of Agriculture to understand how to collect the subaward information required to be reported in FSRS for the CNC programs.
Recommendation:
We recommend the Wisconsin Department of Public Instruction:
-develop written policies and procedures for identifying when Federal Funding Accountability and Transparency Act (FFATA) reporting requirements are applicable to a federal award it administers;
-develop written policies and procedures for timely identification and reporting of Child Nutrition Cluster program subawards of $30,000 or more, including any amendments or modifications to a subaward, to the FFATA Subaward Reporting System; and
-complete monthly FFATA reporting for the Child Nutrition Cluster programs following the established policies and procedures.
Finding 2024-400: Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting
Child Nutrition Cluster (Assistance Listing numbers 10.553, 10.555, 10.556, 10.559, and 10.582)
Award Numbers Award Years
212WI063N1099 2021
212WI063N1199 2021
212WI063N8903 2021
222WI063N1099 2022
222WI063N1199 2022
222WI063N8903 2022
232WI063N1099 2023
232WI063N1199 2023
232WI063L1603 2023
242WI063N1099 2024
242WI063N1199 2024
242WI063N8903 2024
242WI063L1603 2024
Questioned Costs: None
COVID-19—National School Lunch Program (Assistance Listing number 10.555)
Award Number Award Year
232WI063N8903 2023
Questioned Costs: None
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the reporting compliance requirement.
Response from the Wisconsin Department of Public Instruction: The Wisconsin Department of Public Instruction agrees with the audit finding and recommendations.
Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting
Background:
The U.S. Department of Agriculture provides funding to DPI through the programs of CNC. The purpose of these programs is to:
-assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential child care institutions, and summer programs;
-foster healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary schools; and
-encourage the domestic consumption of nutritious agricultural commodities.
DPI subawards CNC funding to schools and other entities to execute the programs.
Under the Federal Funding Accountability and Transparency Act (FFATA), a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
Criteria:
Under 2 CFR s. 170, DPI is required to report in the FFATA Subaward Reporting System (FSRS) subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the subaward was made. For example, if the subaward was made on November 7, 2023, it must be reported in FSRS not later than December 31, 2023. CNC subawards of $30,000 or more are subject to FFATA reporting.
Condition:
Although DPI made subawards of $30,000 or more in CNC funding to schools and other entities in FY 2023-24, DPI did not report any CNC subawards in FSRS during FY 2023-24.
Context:
Of the $361.0 million expended during FY 2023-24 under CNC, DPI disbursed $342.4 million to schools and other entities. We interviewed DPI staff to gain an understanding of the procedures for compiling information for CNC subawards and submitting the information in FSRS.
Questioned Costs:
None.
Effect:
The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov for CNC. DPI did not comply with FFATA requirements for the timely reporting of subawards in FSRS for CNC.
Cause:
Although DPI staff completed FFATA reporting for other grant programs DPI administers, DPI staff did not identify that FFATA reporting requirements applied to CNC. As a result, DPI did not have policies or procedures to collect the required subaward information for CNC programs from DPI’s computer system. Therefore, this information was not reported in FSRS.
As a result of our inquires, DPI staff discussed the requirements with the U.S. Department of Agriculture to understand how to collect the subaward information required to be reported in FSRS for the CNC programs.
Recommendation:
We recommend the Wisconsin Department of Public Instruction:
-develop written policies and procedures for identifying when Federal Funding Accountability and Transparency Act (FFATA) reporting requirements are applicable to a federal award it administers;
-develop written policies and procedures for timely identification and reporting of Child Nutrition Cluster program subawards of $30,000 or more, including any amendments or modifications to a subaward, to the FFATA Subaward Reporting System; and
-complete monthly FFATA reporting for the Child Nutrition Cluster programs following the established policies and procedures.
Finding 2024-400: Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting
Child Nutrition Cluster (Assistance Listing numbers 10.553, 10.555, 10.556, 10.559, and 10.582)
Award Numbers Award Years
212WI063N1099 2021
212WI063N1199 2021
212WI063N8903 2021
222WI063N1099 2022
222WI063N1199 2022
222WI063N8903 2022
232WI063N1099 2023
232WI063N1199 2023
232WI063L1603 2023
242WI063N1099 2024
242WI063N1199 2024
242WI063N8903 2024
242WI063L1603 2024
Questioned Costs: None
COVID-19—National School Lunch Program (Assistance Listing number 10.555)
Award Number Award Year
232WI063N8903 2023
Questioned Costs: None
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the reporting compliance requirement.
Response from the Wisconsin Department of Public Instruction: The Wisconsin Department of Public Instruction agrees with the audit finding and recommendations.
Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting
Background:
The U.S. Department of Agriculture provides funding to DPI through the programs of CNC. The purpose of these programs is to:
-assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential child care institutions, and summer programs;
-foster healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary schools; and
-encourage the domestic consumption of nutritious agricultural commodities.
DPI subawards CNC funding to schools and other entities to execute the programs.
Under the Federal Funding Accountability and Transparency Act (FFATA), a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
Criteria:
Under 2 CFR s. 170, DPI is required to report in the FFATA Subaward Reporting System (FSRS) subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the subaward was made. For example, if the subaward was made on November 7, 2023, it must be reported in FSRS not later than December 31, 2023. CNC subawards of $30,000 or more are subject to FFATA reporting.
Condition:
Although DPI made subawards of $30,000 or more in CNC funding to schools and other entities in FY 2023-24, DPI did not report any CNC subawards in FSRS during FY 2023-24.
Context:
Of the $361.0 million expended during FY 2023-24 under CNC, DPI disbursed $342.4 million to schools and other entities. We interviewed DPI staff to gain an understanding of the procedures for compiling information for CNC subawards and submitting the information in FSRS.
Questioned Costs:
None.
Effect:
The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov for CNC. DPI did not comply with FFATA requirements for the timely reporting of subawards in FSRS for CNC.
Cause:
Although DPI staff completed FFATA reporting for other grant programs DPI administers, DPI staff did not identify that FFATA reporting requirements applied to CNC. As a result, DPI did not have policies or procedures to collect the required subaward information for CNC programs from DPI’s computer system. Therefore, this information was not reported in FSRS.
As a result of our inquires, DPI staff discussed the requirements with the U.S. Department of Agriculture to understand how to collect the subaward information required to be reported in FSRS for the CNC programs.
Recommendation:
We recommend the Wisconsin Department of Public Instruction:
-develop written policies and procedures for identifying when Federal Funding Accountability and Transparency Act (FFATA) reporting requirements are applicable to a federal award it administers;
-develop written policies and procedures for timely identification and reporting of Child Nutrition Cluster program subawards of $30,000 or more, including any amendments or modifications to a subaward, to the FFATA Subaward Reporting System; and
-complete monthly FFATA reporting for the Child Nutrition Cluster programs following the established policies and procedures.
Finding 2024-400: Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting
Child Nutrition Cluster (Assistance Listing numbers 10.553, 10.555, 10.556, 10.559, and 10.582)
Award Numbers Award Years
212WI063N1099 2021
212WI063N1199 2021
212WI063N8903 2021
222WI063N1099 2022
222WI063N1199 2022
222WI063N8903 2022
232WI063N1099 2023
232WI063N1199 2023
232WI063L1603 2023
242WI063N1099 2024
242WI063N1199 2024
242WI063N8903 2024
242WI063L1603 2024
Questioned Costs: None
COVID-19—National School Lunch Program (Assistance Listing number 10.555)
Award Number Award Year
232WI063N8903 2023
Questioned Costs: None
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the reporting compliance requirement.
Response from the Wisconsin Department of Public Instruction: The Wisconsin Department of Public Instruction agrees with the audit finding and recommendations.
Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting
Background:
The U.S. Department of Agriculture provides funding to DPI through the programs of CNC. The purpose of these programs is to:
-assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential child care institutions, and summer programs;
-foster healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary schools; and
-encourage the domestic consumption of nutritious agricultural commodities.
DPI subawards CNC funding to schools and other entities to execute the programs.
Under the Federal Funding Accountability and Transparency Act (FFATA), a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
Criteria:
Under 2 CFR s. 170, DPI is required to report in the FFATA Subaward Reporting System (FSRS) subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the subaward was made. For example, if the subaward was made on November 7, 2023, it must be reported in FSRS not later than December 31, 2023. CNC subawards of $30,000 or more are subject to FFATA reporting.
Condition:
Although DPI made subawards of $30,000 or more in CNC funding to schools and other entities in FY 2023-24, DPI did not report any CNC subawards in FSRS during FY 2023-24.
Context:
Of the $361.0 million expended during FY 2023-24 under CNC, DPI disbursed $342.4 million to schools and other entities. We interviewed DPI staff to gain an understanding of the procedures for compiling information for CNC subawards and submitting the information in FSRS.
Questioned Costs:
None.
Effect:
The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov for CNC. DPI did not comply with FFATA requirements for the timely reporting of subawards in FSRS for CNC.
Cause:
Although DPI staff completed FFATA reporting for other grant programs DPI administers, DPI staff did not identify that FFATA reporting requirements applied to CNC. As a result, DPI did not have policies or procedures to collect the required subaward information for CNC programs from DPI’s computer system. Therefore, this information was not reported in FSRS.
As a result of our inquires, DPI staff discussed the requirements with the U.S. Department of Agriculture to understand how to collect the subaward information required to be reported in FSRS for the CNC programs.
Recommendation:
We recommend the Wisconsin Department of Public Instruction:
-develop written policies and procedures for identifying when Federal Funding Accountability and Transparency Act (FFATA) reporting requirements are applicable to a federal award it administers;
-develop written policies and procedures for timely identification and reporting of Child Nutrition Cluster program subawards of $30,000 or more, including any amendments or modifications to a subaward, to the FFATA Subaward Reporting System; and
-complete monthly FFATA reporting for the Child Nutrition Cluster programs following the established policies and procedures.
Finding 2024-400: Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting
Child Nutrition Cluster (Assistance Listing numbers 10.553, 10.555, 10.556, 10.559, and 10.582)
Award Numbers Award Years
212WI063N1099 2021
212WI063N1199 2021
212WI063N8903 2021
222WI063N1099 2022
222WI063N1199 2022
222WI063N8903 2022
232WI063N1099 2023
232WI063N1199 2023
232WI063L1603 2023
242WI063N1099 2024
242WI063N1199 2024
242WI063N8903 2024
242WI063L1603 2024
Questioned Costs: None
COVID-19—National School Lunch Program (Assistance Listing number 10.555)
Award Number Award Year
232WI063N8903 2023
Questioned Costs: None
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the reporting compliance requirement.
Response from the Wisconsin Department of Public Instruction: The Wisconsin Department of Public Instruction agrees with the audit finding and recommendations.
Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting
Background:
The U.S. Department of Agriculture provides funding to DPI through the programs of CNC. The purpose of these programs is to:
-assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential child care institutions, and summer programs;
-foster healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary schools; and
-encourage the domestic consumption of nutritious agricultural commodities.
DPI subawards CNC funding to schools and other entities to execute the programs.
Under the Federal Funding Accountability and Transparency Act (FFATA), a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
Criteria:
Under 2 CFR s. 170, DPI is required to report in the FFATA Subaward Reporting System (FSRS) subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the subaward was made. For example, if the subaward was made on November 7, 2023, it must be reported in FSRS not later than December 31, 2023. CNC subawards of $30,000 or more are subject to FFATA reporting.
Condition:
Although DPI made subawards of $30,000 or more in CNC funding to schools and other entities in FY 2023-24, DPI did not report any CNC subawards in FSRS during FY 2023-24.
Context:
Of the $361.0 million expended during FY 2023-24 under CNC, DPI disbursed $342.4 million to schools and other entities. We interviewed DPI staff to gain an understanding of the procedures for compiling information for CNC subawards and submitting the information in FSRS.
Questioned Costs:
None.
Effect:
The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov for CNC. DPI did not comply with FFATA requirements for the timely reporting of subawards in FSRS for CNC.
Cause:
Although DPI staff completed FFATA reporting for other grant programs DPI administers, DPI staff did not identify that FFATA reporting requirements applied to CNC. As a result, DPI did not have policies or procedures to collect the required subaward information for CNC programs from DPI’s computer system. Therefore, this information was not reported in FSRS.
As a result of our inquires, DPI staff discussed the requirements with the U.S. Department of Agriculture to understand how to collect the subaward information required to be reported in FSRS for the CNC programs.
Recommendation:
We recommend the Wisconsin Department of Public Instruction:
-develop written policies and procedures for identifying when Federal Funding Accountability and Transparency Act (FFATA) reporting requirements are applicable to a federal award it administers;
-develop written policies and procedures for timely identification and reporting of Child Nutrition Cluster program subawards of $30,000 or more, including any amendments or modifications to a subaward, to the FFATA Subaward Reporting System; and
-complete monthly FFATA reporting for the Child Nutrition Cluster programs following the established policies and procedures.
Finding 2024-400: Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting
Child Nutrition Cluster (Assistance Listing numbers 10.553, 10.555, 10.556, 10.559, and 10.582)
Award Numbers Award Years
212WI063N1099 2021
212WI063N1199 2021
212WI063N8903 2021
222WI063N1099 2022
222WI063N1199 2022
222WI063N8903 2022
232WI063N1099 2023
232WI063N1199 2023
232WI063L1603 2023
242WI063N1099 2024
242WI063N1199 2024
242WI063N8903 2024
242WI063L1603 2024
Questioned Costs: None
COVID-19—National School Lunch Program (Assistance Listing number 10.555)
Award Number Award Year
232WI063N8903 2023
Questioned Costs: None
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the reporting compliance requirement.
Response from the Wisconsin Department of Public Instruction: The Wisconsin Department of Public Instruction agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Supplemental Nutrition Assistance Program—Subrecipient Monitoring
Background:
The USDA provides funding to DHS for the Supplemental Nutrition Assistance Program (SNAP) Cluster, which provides funding for SNAP benefits (Assistance Listing number 10.551). These SNAP benefits assist low-income households to buy the food needed for good health. The SNAP Cluster also provides funding for the State Administrative Matching Grants for SNAP (Assistance Listing number 10.561), which is used to pay administrative costs related to the provision and oversight of benefits. To administer the SNAP program, DHS contracts with ten multi-county income maintenance consortia, which are made up of county staff. These income maintenance consortia are responsible for a variety of administrative tasks, including program enrollment and caseload management, and are required to meet certain performance measures specified in the contract. DHS uses GEARS to process the reimbursement requests for these consortia, which are considered subrecipients.
Criteria:
DHS administers federal programs that are subject to Uniform Guidance. Uniform Guidance includes the following requirements related to the monitoring of subrecipients:
-2 CFR s. 200.332 (b) requires DHS to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring; and
-2 CFR s. 200.332 (d) through (f) requires DHS to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
DHS established policies requiring grant administrators to conduct a risk assessment for every subaward of federal funds and to use the risk assessment to determine the frequency and extent of monitoring. DHS policies include a subrecipient risk assessment template to assist grant administrators in completing the risk assessment and determining the risk level of the subrecipient. DHS policies also require grant administrators to monitor subrecipients based on the risk assessments. DHS policies indicate that monitoring may include providing subrecipient training and technical assistance; performing desk reviews of the subrecipient’s records; and performing on-site reviews of the subrecipient’s records and operations.
Condition:
We found DHS did not perform the required risk assessments for the income maintenance consortia in FY 2020-21, FY 2021-22, FY 2022-23, and FY 2023-24. In addition, DHS did not define the level of monitoring to be performed based on the completed risk assessments. For example, there was no documentation to indicate the level monitoring required for low-, moderate-, and high-risk subrecipients, including the reliance that could be placed on the review of subrecipient single audit reports and whether additional fiscal monitoring such as a review of financial information to assess the allowability of reimbursement requests would be needed.
DHS did perform monitoring procedures for each income maintenance consortia related to the contractual performance measures, including standards for timely processing of applications. DHS also performed annual management evaluations related to specific topics.
Context:
DHS expended $105.7 million in federal funds to administer the SNAP program during FY 2023-24, including $61.3 million that was provided to subrecipients, of which $37.5 million was provided to the income maintenance consortia agencies for program administration. We interviewed DHS staff to gain an understanding of DHS policies and procedures for processing reimbursement requests from subrecipients and its policies and procedures for monitoring subrecipients to ensure the subaward was used for authorized purposes, complied with the terms and conditions of the subaward, and achieved performance goals.
Questioned Costs:
None.
Effect:
Because its subrecipient monitoring procedures were insufficient, and because DHS did not perform any required risk assessments in the last four fiscal years, DHS is at increased risk of noncompliance with federal regulations for the SNAP program. Further, there is an increased risk of improper payments for the SNAP program.
Cause:
DHS did not complete the required risk assessments or develop and document a plan related to the monitoring necessary for each level of subrecipient risk. Although DHS performed certain monitoring related to contractual performance measures, these procedures were not part of a documented monitoring plan and there was no assessment of additional procedures that could have been determined necessary based upon the risk assessments.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-complete risk assessments for each income maintenance consortia receiving administrative funding under the Supplemental Nutrition Assistance Program;
-develop and document a written monitoring plan that includes a description of the monitoring expected for low-, moderate-, and high-risk subrecipients to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals;
-specify in the written monitoring plan how existing monitoring procedures are incorporated into the plan and assess what additional monitoring procedures may be needed; and
-implement the written monitoring plan and maintain documentation related to the monitoring performed.
Finding 2024-308: Supplemental Nutrition Assistance Program—Subrecipient Monitoring
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting
Background:
The U.S. Department of Agriculture provides funding to DPI through the programs of CNC. The purpose of these programs is to:
-assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential child care institutions, and summer programs;
-foster healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary schools; and
-encourage the domestic consumption of nutritious agricultural commodities.
DPI subawards CNC funding to schools and other entities to execute the programs.
Under the Federal Funding Accountability and Transparency Act (FFATA), a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
Criteria:
Under 2 CFR s. 170, DPI is required to report in the FFATA Subaward Reporting System (FSRS) subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the subaward was made. For example, if the subaward was made on November 7, 2023, it must be reported in FSRS not later than December 31, 2023. CNC subawards of $30,000 or more are subject to FFATA reporting.
Condition:
Although DPI made subawards of $30,000 or more in CNC funding to schools and other entities in FY 2023-24, DPI did not report any CNC subawards in FSRS during FY 2023-24.
Context:
Of the $361.0 million expended during FY 2023-24 under CNC, DPI disbursed $342.4 million to schools and other entities. We interviewed DPI staff to gain an understanding of the procedures for compiling information for CNC subawards and submitting the information in FSRS.
Questioned Costs:
None.
Effect:
The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov for CNC. DPI did not comply with FFATA requirements for the timely reporting of subawards in FSRS for CNC.
Cause:
Although DPI staff completed FFATA reporting for other grant programs DPI administers, DPI staff did not identify that FFATA reporting requirements applied to CNC. As a result, DPI did not have policies or procedures to collect the required subaward information for CNC programs from DPI’s computer system. Therefore, this information was not reported in FSRS.
As a result of our inquires, DPI staff discussed the requirements with the U.S. Department of Agriculture to understand how to collect the subaward information required to be reported in FSRS for the CNC programs.
Recommendation:
We recommend the Wisconsin Department of Public Instruction:
-develop written policies and procedures for identifying when Federal Funding Accountability and Transparency Act (FFATA) reporting requirements are applicable to a federal award it administers;
-develop written policies and procedures for timely identification and reporting of Child Nutrition Cluster program subawards of $30,000 or more, including any amendments or modifications to a subaward, to the FFATA Subaward Reporting System; and
-complete monthly FFATA reporting for the Child Nutrition Cluster programs following the established policies and procedures.
Finding 2024-400: Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting
Child Nutrition Cluster (Assistance Listing numbers 10.553, 10.555, 10.556, 10.559, and 10.582)
Award Numbers Award Years
212WI063N1099 2021
212WI063N1199 2021
212WI063N8903 2021
222WI063N1099 2022
222WI063N1199 2022
222WI063N8903 2022
232WI063N1099 2023
232WI063N1199 2023
232WI063L1603 2023
242WI063N1099 2024
242WI063N1199 2024
242WI063N8903 2024
242WI063L1603 2024
Questioned Costs: None
COVID-19—National School Lunch Program (Assistance Listing number 10.555)
Award Number Award Year
232WI063N8903 2023
Questioned Costs: None
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the reporting compliance requirement.
Response from the Wisconsin Department of Public Instruction: The Wisconsin Department of Public Instruction agrees with the audit finding and recommendations.
Summer Electronic Benefit Transfer Program for Children—Cash Management
Background:
The U.S. Department of Agriculture (USDA) provides funding to DHS for the Summer Electronic Benefit Transfer Program for Children (Summer EBT) (Assistance Listing number 10.646). This program provides food benefits during the summer months to families with children who were determined eligible for free or reduced-price school meals in the prior school year or during the summer.
This program was authorized under the Consolidated Appropriations Act of 2023, which was enacted in December 2022. DHS received approval for its Summer EBT program on March 22, 2024, and received an initial grant award on April 9, 2024. The program began operations in summer 2024. Under the program, participants received benefits of $120 for each eligible child. These benefits were issued on EBT cards that participants used to purchase food at approved retailers.
Criteria:
The Summer EBT program is subject to the requirements of 31 CFR Part 205, Subpart B, including that the State must minimize the time between the drawdown of federal funds from the federal government and the disbursement for federal program purposes. Further, the regulations state that the timing and amount of funds transferred must be as close as is administratively feasible to a state’s actual cash outlay for direct program costs. DOA, which processes federal reimbursement requests for most state agencies, has defined administratively feasible as receiving federal funds within five days of the recording of expenditures.
The USDA issued guidance defined the federal share of expenditures as disbursements for direct charges related to Summer EBT benefits. This guidance further defined the federal share of unliquidated obligations as the value of benefits that have been issued to participants, but for which no cash disbursements have been made. Based upon this guidance, expenditures or disbursements under the Summer EBT program are incurred when participants have used the issued benefits to purchase food at an approved retailer.
Summer EBT is also subject to 2 CFR Part 200, Subpart E, which provides requirements for determination of allowable costs to be charged to a federal award, including that the costs be necessary, reasonable, and adequately documented.
Condition:
DHS established the Summer EBT program through STAR, the State’s accounting system, to allow for the drawdown of federal funds once expenditures were recorded in the accounting system. On June 18, 2024, DHS recorded an expenditure in the Summer EBT program for $58.3 million that resulted in the drawdown of $58.3 million in federal Summer EBT funds. In reviewing the expenditure transaction, we found that DHS
did not base the $58.3 million transaction on actual expenditures for Summer EBT benefits. Rather, the expenditure transaction was comprised of $50.9 million in benefits that were approved to be issued on participants’ EBT cards on June 22, 2024, and $7.2 million related to benefits that were expected to be issued at a future date after certain information was received to issue benefits. Because the expenditure was not based on participants’ food purchases, federal funds were drawn in advance of program expenditures.
DHS established a separate bank account to allow for the settlement of participants’ food purchases with the retailers. On June 21, 2024, a deposit of $58.3 million was made to this account. As of June 30, 2024, $23.2 million in benefits were used by participants on food purchases, which were settled or credited to this account. A balance of $35.1 million remained in the account on June 30, 2024. In addition, the account earned interest totaling $60,212 for June 2024.
Context:
We reviewed FY 2023-24 DHS transactions recorded in June 2024 and identified a $58.3 million expenditure transaction that was coded to a new federal program: Summer EBT. We followed up with DHS on the transaction to discuss its purpose and the requirements of this program. We reviewed supporting documentation provided, including bank account statements, and reviewed the federal program requirements.
Questioned Costs:
We question at least $35,050,325, which was the balance of the federal funds drawn and not spent by participants as of June 30, 2024.
Effect:
DHS recorded program expenditures that were not supported, DHS received federal funds in advance of program expenditures for Summer EBT, and DHS did not minimize the time between the drawdown of federal funds from the federal government and the disbursement for federal program purposes, resulting in noncompliance with allowable cost and federal cash management requirements. In addition, the federal reports DHS prepared and submitted for the program inaccurately reported program expenditures based on what had been recorded in STAR, the State’s accounting system, and not the actual program expenditures.
Cause:
DHS indicated the process of drawing federal funds through STAR, the State’s accounting systemy, did not provide for the receipt of federal funds that would allow for daily settlement of participants’ food purchases. As a result, DHS developed a process that would provide sufficient cash-on-hand. However, in doing so, DHS recorded expenditures prior to participants’ food purchases, and DHS did not properly consider federal cash management requirements under which the State must minimize the time between the recording of the expenditure and the drawdown of federal funds.
Recommendation:
We recommend the Wisconsin Department of Health Services review its procedures and make updates that will:
-ensure recorded expenditures are supported by program expenditures; and
-minimize the time between the recording of expenditures and the drawdown of federal funds.
Finding 2024-301: Summer Electronic Benefit Transfer Program for Children—Cash Management
Summer Electronic Benefit Transfer Program for Children
(Assistance Listing number 10.646)
Award Number Award Year
202424N117542 2024
Questioned Costs: $35,050,325
Type of Finding: Material Weakness, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Rebuttal from the Wisconsin Legislative Audit Bureau: In its corrective action plan on page 345, the Department of Health Services agreed with the cash management concerns reported by the Bureau, but stated it did not consider the questioned costs to be inappropriate federal spending. In addition, the Department of Health Services noted that it completed a reconciliation of funds received to funds spent for children in this program and returned the unspent balance to the federal government in September 2024.
However, a questioned cost is defined by 2 CFR s. 200.1 as an amount expended or received from a federal award, that in the auditor’s judgment:
-is noncompliant or suspected noncompliant with federal statutes, regulations, or the terms and conditions of the federal award;
-lacked adequate documentation to support compliance; or
-appeared unreasonable and did not reflect the actions a prudent person would take in the circumstances.
As reported in the finding, United States Department of Agriculture guidance indicates that expenditures or disbursements under the Summer Electronic Benefit Transfer Program for Children are incurred when participants have used the issued benefits to purchase food. The amount questioned was the balance of the federal funds drawn and not spent by participants as of June 30, 2024. This amount met the criteria of a questioned cost due to noncompliance with federal regulations and a lack of adequate documentation to support compliance. In addition, the return of $14.2 million to the federal government in September 2024 further indicates that the amounts drawn in June 2024 were not supported.
Homeowner Assistance Fund—Service Organization Internal Controls
Background:
Under the American Rescue Plan Act (ARPA) of 2021, the U.S. Department of the Treasury (U.S. Treasury) provided funding to DOA’s Division of Energy, Housing and Community Resources (DEHCR) for the HAF program. This program was established to mitigate financial hardships associated with the public health emergency, including for the purpose of preventing homeowner mortgage delinquencies, defaults, foreclosures, losses of utilities or home energy services, and displacements of homeowners experiencing financial hardship after January 21, 2020.
To administer the HAF program, DOA contracted with a service organization to host and maintain a computer system to assist in determining the eligibility of individuals applying for HAF benefits, approving these benefits, storing information on HAF applicants, and for reporting HAF activities to the federal government.
During our FY 2022-23 single audit (report 24-3), we identified concerns that DOA did not have sufficient procedures in place to obtain the service organization audit report from its service organization for HAF nor to use the service organization audit report as a tool to assess the effectiveness of the internal controls for the computer system maintained by the service organization. We recommended that DOA obtain the service organization audit report for the computer system used to administer the HAF program and complete a review of this report, assess the effectiveness of the internal controls for the computer system maintained by the service organization, and review the complementary user entity controls at DOA that are required to be in place for it to rely on the service organization audit report. In addition, DOA was to document its review, and to implement user entity controls if needed (Finding 2023-101).
In its response to our recommendations, and as noted in the Summary Schedule of Prior Audit Findings, DOA requested and received the service organization audit report. In addition, DOA developed procedures to:
-review the service organization audit report;
-assess of the effectiveness of the internal controls on the computer system maintained by the service organization; and
-review the complementary user entity controls that are required to be in place for it to rely on the service organization audit report, and to implement user entity controls if needed.
DOA indicated it had completed in June 2024 a preliminary review of the service organization audit report, including the opinion, testing exceptions, and complementary user-entity controls, but DOA had not completed its assessment of the effectiveness of the internal controls on the computer system maintained by the service organization nor documented its review.
Criteria:
Under 2 CFR s. 200.303, DOA is responsible for establishing and maintaining effective internal control over federal awards to provide reasonable assurance that federal awards are managed in compliance with federal statutes, regulations, and the award terms and conditions. This includes instances in which management contracts with a service organization, which is an organization that provides services to another entity and whose services are relevant to the entity’s internal controls.
When using a service organization, the entity should gain assurances that the internal controls at the service organization are operating effectively because weaknesses in the service organization’s internal controls could affect the activity of the entity. Such assurances could be gained through a service organization audit, which includes a report on the service organization’s internal controls by an independent auditor. One type of audit that may be completed includes an opinion on the fairness of management’s description of the internal controls in place at the service organization, whether the auditor believes the service organization’s internal controls are suitably designed to achieve the internal control objectives, and whether the service organization’s internal controls are effective at achieving the internal control objectives. In addition, an entity relying on a service organization audit report should review the complementary user entity controls referenced in the report and ensure these controls or others are in place at the entity.
If an entity relying on a service organization does not obtain a service organization audit report, the entity should ensure it has assessed the work being completed by the service organization, and it has implemented procedures to ensure both the accuracy of processing completed by the service organization and the information provided by the service organization.
Condition:
In May 2024, DOA requested and received the April 2024 service organization audit report that covered the period from September 1, 2023, to February 29, 2024. We found that DOA developed procedures to review the service organization audit report, assess the effectiveness of the internal controls on the computer system maintained by the service organization, and assess the complementary user entity controls. However, DOA did not complete its review and assessment of the April 2024 service organization audit report during FY 2023-24.
Context:
During FY 2023-24, DOA expended $30.9 million in HAF funding. DOA reported that $27.8 million, or 89.9 percent of the expenditures, was for benefit payments to various entities such as mortgage and utility companies on behalf of individuals who had their eligibility determinations processed by the computer system maintained by DOA’s service organization. We reviewed and discussed with DEHCR its procedures for determining eligibility for HAF participants, including its reliance on the computer system maintained by the service organization.
Questioned Costs:
None.
Effect:
DOA and the federal government cannot be assured that the service organization controls are effective in determining eligibility or completing federal reporting for HAF.
Cause:
Although DOA developed procedures to obtain and review the service organization audit report for HAF, it did not complete its review and assessment of the service organization audit report until October 2024.
Recommendation:
We recommend the Wisconsin Department of Administration implement its new policies and procedures to review and assess the service organization audit report for the Homeowner Assistance Fund to establish and maintain effective internal control over federal awards.
Finding 2024-100: Homeowner Assistance Fund—Service Organization Internal Controls
COVID-19—Homeowner Assistance Fund (Assistance Listing number 21.026)
Award Number Award Year
None 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendation.
Coronavirus State and Local Fiscal Recovery Funds—Suspension and Debarment Requirements
Background:
The State was advanced a total of $3.0 billion under the CSLFRF program in FY 2020-21 and FY 2021-22, from the U.S. Department of the Treasury (U.S. Treasury). CSLFRF was created under the American Rescue Plan Act (ARPA), and later revised by the Consolidated Appropriations Act, 2023. CSLFRF is administered by DOA.
DOA expended funding under CSLFRF for various programs that it established. In addition, DOA entered into a memorandum of understanding (MOU) with various state agencies to administer several different programs funded by CSLFRF. In June 2022, DOA entered into an MOU with UW System Administration called the Mental Health Initiative, with the goal of making mental health resources available to students by contracting with providers, providing training to enhance the capacity of university staff to deliver mental health programming, and providing grants to UW institutions to develop mental health programs. In addition, in April 2024 UW System Administration’s Office of Business and Entrepreneurship entered into a subgrant agreement with WEDC to administer technical assistance to grantees of WEDC’s Main Street Bounceback Program using CSLFRF funding.
Criteria:
2 CFR s. 200.214 prohibits recipients of federal funding from entering into contracts with suspended or debarred parties. Further, 2 CFR s. 180.300 requires recipients of federal funding to ensure they do not enter into a contract with a suspended or debarred party by completing one of the following steps:
-reviewing the suspended and debarred parties listing on SAM.gov;
-collecting a certification from the party that they are not suspended or debarred; or
-including a clause or condition regarding suspension and debarment in the procurement contract.
Condition:
We found that UW System Administration entered into contracts with vendors to administer the Mental Health Initiative and the subgrant with WEDC. UW System Administration did not complete or document that it completed any of the required steps to ensure the parties were not suspended or debarred.
Context:
The MOU with DOA provided UW System Administration $5.0 million in CSLFRF funding for the Mental Health Initiative and, in FY 2023-24, UW System Administration expended $1.7 million. We inquired of UW System Administration staff regarding procedures for ensuring UW System Administration does not enter into a contract with a suspended or debarred party. We also reviewed payments made to vendors and reviewed contracts for two vendors, and reviewed the suspended and debarred parties listing on SAM.gov. We found one of the vendors was registered on SAM.gov and was not on the suspended and debarred parties listing. However, the other vendor was not registered on SAM.gov, so we could not determine the suspension and debarment status of this vendor.
The subgrant from WEDC provided UW System Administration $5.0 million in CSLFRF funding, of which UW System Administration expended $666,000 in FY 2023-24. We inquired of staff in UW System Administration’s Office of Business and Entrepreneurship regarding its procedures for ensuring it does not enter into a contract with a suspended or debarred party. We also reviewed payments made to vendors and reviewed contracts for two vendors, and reviewed the suspended and debarred parties listing on SAM.gov. We found the vendors for the WEDC subgrant were not registered on SAM.gov, so we could not determine the suspension and debarment status of these vendors.
Questioned Costs:
None.
Effect:
UW System Administration is at increased risk of entering into a contract with a suspended or debarred party, and is in noncompliance with federal requirements.
Cause:
UW System Administration staff administering the Mental Health Initiative were unaware of the suspension and debarment requirements, and UW System Administration did not have procedures in place to meet the federal requirements. UW System Administration staff indicated that responsibility for and debarment requirements was transitioned to UW-Madison, Research and Sponsored Programs in FY 2024-25.
Staff in UW System Administration’s Office of Business and Entrepreneurship who administer the WEDC subgrant noted that they review SAM.gov, as well as other types of vendor checks but did not maintain documentation of the review.
Recommendation:
We recommend the University of Wisconsin System Administration implement procedures to ensure the suspension and debarment requirements are met and documentation is maintained to demonstrate the requirements were met.
Finding 2024-714: Coronavirus State and Local Fiscal Recovery Funds—Suspension and Debarment Requirements
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Numbers Award Years
None 2021
Subgrant KSP FY 24-53693 2024
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendation.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
Background:
The State was advanced a total of $3.0 billion under the CSLFRF program in FY 2020-21 and FY 2021-22, from the U.S. Department of the Treasury (U.S. Treasury). CSLFRF was created under the American Rescue Plan Act (ARPA), and later revised by the Consolidated Appropriations Act, 2023. CSLFRF is administered by DOA. CSLFRF funding has certain eligible uses, including those in an eligible use category for the provision of government services to the extent revenue losses due to the public health emergency reduced revenues. CSLFRF recipients calculated lost revenues for the years 2020, 2021, 2022, and 2023 based on a formula in the 2022 Treasury final rule to determine the amount of CSLFRF funds that may be used for the provision of government services in the eligible use category.
DOA expended funding under CSLFRF for various programs that it established. In addition, DOA entered into a memorandum of understanding (MOU) with
various state agencies to administer several different programs funded by CSLFRF. In June 2022, DOA entered into an MOU with DHS related to COVID-19 vaccination distribution.
Criteria:
Under the 2022 Treasury final rule, U.S. Treasury determined that CSLFRF funding available for the provision of government services may be used to meet the non-federal match requirements of other federal programs. Further, CSLFRF funding available under other eligible use categories may not be used to meet the non-federal match requirements of other programs, unless specifically allowed by statute.
Condition:
DHS used CSLFRF funding to meet its match requirement for the Disaster Grants - Public Assistance (Presidentially Declared Disasters) (Public Assistance) (Assistance Listing number 97.036). DHS recorded a transaction of $862,677 to its COVID-19 vaccination distribution program in January 2024, and counted this transaction as part of meeting its non-federal match requirement under the Public Assistance grant. The COVID-19 vaccination distribution program is reported under the U.S. Treasury eligible use category related to responding to the public health emergency and its negative impacts. Under this eligible use category, DHS is not allowed to use CSLFRF funding as non-federal match for another federal program.
Context:
During FY 2023-24, DHS expended $39.0 million in CSLFRF funding. We interviewed DHS staff to gain an understanding of DHS’s administration of the CSLFRF funding, including how it assessed using CSLFRF funding to meet its non-federal match for other federal programs. We reviewed general ledger transactions made by DHS for the CSLFRF grant, identified the DHS transaction, and followed up with DHS regarding the purpose of the transaction. DHS is responsible for ensuring costs charged to federal grant programs meet the federal requirements.
Questioned Costs:
$862,677
Effect:
DHS is in noncompliance with federal requirements for allowable uses of CSLFRF funding and DHS did not meet its non-federal match requirements for the Public Assistance grant, because DHS used CSLFRF funding to meet the non-federal match requirement.
Cause:
DHS staff indicated they were not aware of the eligible use category for its COVID-19 vaccination distribution project funded by CSLFRF. Further, the MOU between DOA and DHS did not include information to allow DHS to understand what the eligible use category was or the restrictions related to the use of the funds to meet non-federal match for other federal grants. DOA did provide DHS with information regarding the eligible use category through quarterly reporting requirements to the U.S. Treasury. Further, DOA and DHS staff indicated regular discussions occurred between the two agencies regarding the CSLFRF funding.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-take steps to further its understanding of the Coronavirus State and Local Fiscal Recovery Funds grant it is administering to ensure it administers the grant in compliance with all federal rules; and
-review the non-federal match requirements for the Public Assistance grant and ensure it has met the non-federal match requirements.
Finding 2024-304: Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: $862,677
Type of Finding: Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services disagrees with the audit finding and recommendations.
Rebuttal from the Wisconsin Legislative Audit Bureau: In its corrective action plan on page 351, the Department of Health Services (DHS) indicated that it disagrees with the unallowable costs identified in this finding and noted that the costs are allowable in accordance with its memorandum of understanding with the Department of Administration and the 2022 Treasury final rule. As stated in the finding, DHS used $862,677 in expenditures under its COVID-19 vaccination distribution program as match for the Public Assistance grant. The 2022 Treasury final rule and the U.S. Department of the Treasury (U.S. Treasury) frequently asked questions related to the Coronavirus State Local and Fiscal Recovery Funds (CSLFRF) grant indicate that only funding under the revenue loss eligible use category may be used to meet non-federal match for another federal program. Therefore, using the expenditures for the COVID-19 vaccination distribution program as the non-federal match for the Public Assistance grant is not allowable.
DHS indicated that “given the nature of these expenditures, they would not have been unallowable, except for their misclassification on the federal report.” We note that the COVID-19 vaccination distribution program has been reported under the public health eligible use category since its inception. Therefore, no misclassification occurred on the federal report.
DHS noted that its position is supported by the fact that no accounting entries were needed to resolve the eligible use category for the purpose of federal reporting.
As we have stated, this issue relates to the unallowable use of CSLFRF funding as non-federal match for another federal program. This is not a federal reporting issue.
We note that subsequent to our questions regarding the use of these funds for non-federal match, the State created a new U.S. Treasury project called COVID-19 Vaccination Non-Federal Match with a budget of $862,677 and reported the project under the revenue loss eligible use category in its report filed for the quarter ended December 31, 2024. Although the State chose to address the finding in this manner, it does not change the fact that DHS was non-compliant with the matching requirements of the CSLFRF grant when it used the funding from the COVID-19 vaccination distribution program as non-federal match for another federal program.
Coronavirus State and Local Fiscal Recovery Funds—Suspension and Debarment Requirements
Background:
The State was advanced a total of $3.0 billion under the CSLFRF program in FY 2020-21 and FY 2021-22, from the U.S. Department of the Treasury (U.S. Treasury). CSLFRF was created under the American Rescue Plan Act (ARPA), and later revised by the Consolidated Appropriations Act, 2023. CSLFRF is administered by DOA.
DOA expended funding under CSLFRF for various programs that it established. In addition, DOA entered into a memorandum of understanding (MOU) with various state agencies to administer several different programs funded by CSLFRF. In January 2022, DOA entered into an MOU with Tourism called the Tourism Marketing Initiative. The goal of the initiative related to implementing marketing and communications initiatives to support the travel, hospitality, and adjacent industries to recover from the public health emergency.
Criteria:
2 CFR s. 200.214 prohibits recipients of federal funding from entering into contracts with suspended or debarred parties. Further, 2 CFR s. 180.300 requires recipients of federal funding to ensure they do not enter into a contract with a suspended or debarred party by completing one of the following steps:
-reviewing the suspended and debarred parties listing on SAM.gov;
-collecting a certification from the party that they are not suspended or debarred; or
-including a clause or condition regarding suspension and debarment in the procurement contract.
Condition:
Although Tourism entered into contracts with vendors to administer the Tourism Marketing Initiative, we found that Tourism completed none of the required steps to ensure the parties were not suspended or debarred.
Context:
The MOU with DOA provided Tourism $7.5 million in CSLFRF funding for the Tourism Marketing Initiative. Tourism expended $972,295 for the initiative in FY 2023-24. We inquired of Tourism staff regarding the agency’s procedures for ensuring it does not enter into a contract with a suspended or debarred party. We also reviewed payments made to vendors and reviewed contracts for five vendors, two of which were entered into during FY 2023-24 and two of which were amended during FY 2023-24.
Questioned Costs:
None.
Effect:
Tourism is at increased risk of entering into a contract with a suspended or debarred party and is in noncompliance with federal requirements.
Cause:
Tourism does not administer significant federal funding. Tourism staff indicated they were unaware of the suspension and debarment requirements and had not developed procedures sufficient and appropriate to meet the federal requirements.
Recommendation:
We recommend the Wisconsin Department of Tourism establish procedures to ensure it does not contract with suspended or debarred parties and complies fully with all applicable federal requirements for funds it administers.
Finding 2024-903: Coronavirus State and Local Fiscal Recovery Funds—Suspension and Debarment Requirements
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Tourism: The Wisconsin Department of Tourism agrees with the audit finding and recommendation.
Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
Background:
The State was advanced a total of $3.0 billion under the CSLFRF program in FY 2020-21 and FY 2021-22, from the U.S. Department of the Treasury (U.S. Treasury). CSLFRF was created under the American Rescue Plan Act (ARPA), and later revised by the Consolidated Appropriations Act, 2023. CSLFRF is administered by DOA.
DOA expended funding under CSLFRF for various programs that it established. In addition, DOA entered into a memorandum of understanding (MOU) with various state agencies to administer several different programs funded by CSLFRF. In January 2022, DOA entered into an MOU with SPD to provide assistance to SPD to hire staff to fill project positions to address its case backlog. Through position requests to DOA in 2021, 2022, and 2023, SPD received approval to create 65.0 two-year project positions to be funded by the CSLFRF grant.
Criteria:
Under 2 CFR s. 200.303, SPD is responsible for establishing and maintaining effective internal control over federal awards to provide reasonable assurance that federal awards are managed in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, SPD is required to follow U.S. Treasury guidance that requires it to maintain documentation to demonstrate that CSLFRF funding was used in accordance with federal regulations.
Condition:
We reviewed payroll records to determine whether employee time charged to the CSLFRF grant was approved by an appropriate supervisor with knowledge of the employee’s work effort. We reviewed the approvals for a selection of 15 project employees at SPD funded by the CSLFRF grant and found that time was approved by an appropriate supervisor for all but one of the employees. We found that the time for one employee was not approved in STAR HCM, the State’s payroll system. Certain amounts charged to the grant for this employee were unallowable to be charged to the grant. This employee was appointed to one of the project positions funded by the CSLFRF grant under the MOU with DOA. This employee left state service on October 6 2023, and was appointed to the project position beginning on October 9, 2023. The employee ended employment with SPD on November 17, 2023. During the three pay periods between October 9, 2023, and November 17, 2023, the employee recorded 3 days of work time and 27 days of leave. Further, on November 30, 2023, the employee was paid $86,605 for accumulated unused leave earned in their previous position.
Context:
During FY 2023-24, SPD expended $5.6 million in CSLFRF funding. We interviewed SPD staff to gain an understanding of SPD’s administration of the CSLFRF funding, including how it charged payroll costs to the CSLFRF grant. We reviewed payroll transactions made by SPD for the CSLFRF program, identified the payout for a terminated employee, and followed up with SPD regarding the purpose of the transaction.
Questioned Costs:
$107,164, which consists of $86,605 in payment for unused leave and $20,559 in leave taken during the three-week period the employee worked in the project position.
Effect:
SPD charged payroll costs to the CSLFRF grant that did not relate to the underlying project positions established in the MOU with DOA.
Cause:
SPD staff indicated that charging the CSLFRF grant for the costs related to the unused leave for the employee was an oversight. According to SPD staff, the former employee made a decision to terminate from the project position and the unused leave was inadvertently charged to the grant. SPD staff did not explain why the 27 days of leave was charged to the grant during the months of October and November of 2023, or why the employee’s time was not approved in STAR.
Recommendation:
We recommend the Wisconsin State Public Defender’s Office:
-review and update its procedures to ensure employee timesheets are appropriately approved by a supervisor with knowledge of each employee’s work effort;
-review and update its procedures to ensure costs are charged to the correct accounting codes and funding sources are appropriately used;
-take steps to ensure it administers the funding for the Coronavirus State and Local Fiscal Recovery Funds grant in compliance with the memorandum of understanding with the Department of Administration and with federal rules; and
-adjust its accounting records to use a different funding source for the leave and termination payments for unused leave for the employee identified during the audit.
Finding 2024-902: Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: $107,164
Type of Finding: Noncompliance
Response from the Wisconsin State Public Defender’s Office: The Wisconsin State Public Defender’s Office agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Coronavirus State and Local Fiscal Recovery Funds—Suspension and Debarment Requirements
Background:
The State was advanced a total of $3.0 billion under the CSLFRF program in FY 2020-21 and FY 2021-22, from the U.S. Department of the Treasury (U.S. Treasury). CSLFRF was created under the American Rescue Plan Act (ARPA), and later revised by the Consolidated Appropriations Act, 2023. CSLFRF is administered by DOA.
DOA expended funding under CSLFRF for various programs that it established. In addition, DOA entered into a memorandum of understanding (MOU) with various state agencies to administer several different programs funded by CSLFRF. In June 2022, DOA entered into an MOU with UW System Administration called the Mental Health Initiative, with the goal of making mental health resources available to students by contracting with providers, providing training to enhance the capacity of university staff to deliver mental health programming, and providing grants to UW institutions to develop mental health programs. In addition, in April 2024 UW System Administration’s Office of Business and Entrepreneurship entered into a subgrant agreement with WEDC to administer technical assistance to grantees of WEDC’s Main Street Bounceback Program using CSLFRF funding.
Criteria:
2 CFR s. 200.214 prohibits recipients of federal funding from entering into contracts with suspended or debarred parties. Further, 2 CFR s. 180.300 requires recipients of federal funding to ensure they do not enter into a contract with a suspended or debarred party by completing one of the following steps:
-reviewing the suspended and debarred parties listing on SAM.gov;
-collecting a certification from the party that they are not suspended or debarred; or
-including a clause or condition regarding suspension and debarment in the procurement contract.
Condition:
We found that UW System Administration entered into contracts with vendors to administer the Mental Health Initiative and the subgrant with WEDC. UW System Administration did not complete or document that it completed any of the required steps to ensure the parties were not suspended or debarred.
Context:
The MOU with DOA provided UW System Administration $5.0 million in CSLFRF funding for the Mental Health Initiative and, in FY 2023-24, UW System Administration expended $1.7 million. We inquired of UW System Administration staff regarding procedures for ensuring UW System Administration does not enter into a contract with a suspended or debarred party. We also reviewed payments made to vendors and reviewed contracts for two vendors, and reviewed the suspended and debarred parties listing on SAM.gov. We found one of the vendors was registered on SAM.gov and was not on the suspended and debarred parties listing. However, the other vendor was not registered on SAM.gov, so we could not determine the suspension and debarment status of this vendor.
The subgrant from WEDC provided UW System Administration $5.0 million in CSLFRF funding, of which UW System Administration expended $666,000 in FY 2023-24. We inquired of staff in UW System Administration’s Office of Business and Entrepreneurship regarding its procedures for ensuring it does not enter into a contract with a suspended or debarred party. We also reviewed payments made to vendors and reviewed contracts for two vendors, and reviewed the suspended and debarred parties listing on SAM.gov. We found the vendors for the WEDC subgrant were not registered on SAM.gov, so we could not determine the suspension and debarment status of these vendors.
Questioned Costs:
None.
Effect:
UW System Administration is at increased risk of entering into a contract with a suspended or debarred party, and is in noncompliance with federal requirements.
Cause:
UW System Administration staff administering the Mental Health Initiative were unaware of the suspension and debarment requirements, and UW System Administration did not have procedures in place to meet the federal requirements. UW System Administration staff indicated that responsibility for and debarment requirements was transitioned to UW-Madison, Research and Sponsored Programs in FY 2024-25.
Staff in UW System Administration’s Office of Business and Entrepreneurship who administer the WEDC subgrant noted that they review SAM.gov, as well as other types of vendor checks but did not maintain documentation of the review.
Recommendation:
We recommend the University of Wisconsin System Administration implement procedures to ensure the suspension and debarment requirements are met and documentation is maintained to demonstrate the requirements were met.
Finding 2024-714: Coronavirus State and Local Fiscal Recovery Funds—Suspension and Debarment Requirements
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Numbers Award Years
None 2021
Subgrant KSP FY 24-53693 2024
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendation.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Coronavirus State and Local Fiscal Recovery Funds—Suspension and Debarment Requirements
Background:
The State was advanced a total of $3.0 billion under the CSLFRF program in FY 2020-21 and FY 2021-22, from the U.S. Treasury. CSLFRF was created under ARPA, and later revised by the Consolidated Appropriations Act, 2023. CSLFRF is administered by DOA. DOA expended funding under CSLFRF for various programs that it established. In addition, DOA entered into an MOU with various state agencies to administer several different programs funded by CSLFRF. DOA entered into an MOU with DWD called the Workforce Innovation Grant (WIG) Program, which allowed DWD to provide grant funding to governments, nonprofit organizations, and tribal governments to design and innovate plans for addressing workforce challenges caused by the public health emergency. In April 2024, DWD entered into an agreement with UW-Eau Claire to administer a grant under the WIG Program.
Criteria:
2 CFR s. 200.214 prohibits recipients of federal funding from entering into contracts with suspended or debarred parties. Further, 2 CFR s. 180.300 requires recipients of federal funding to ensure they do not enter into a contract with a suspended or debarred party by completing one of the following steps:
-reviewing the suspended and debarred parties listing on SAM.gov;
-collecting a certification from the party that they are not suspended or debarred; or
-including a clause or condition regarding suspension and debarment in the procurement contract.
Condition:
We found that UW-Eau Claire entered into contracts with vendors to administer its WIG Program and, for some contracts, it did not complete or document that it completed any of the required steps to ensure the parties were not suspended or debarred.
Context:
The agreement with DWD provides UW-Eau Claire $9.4 million in CSLFRF funding for its WIG Program. We inquired of UW-Eau Claire staff regarding its procedures for ensuring it does not enter into a contract with a suspended or debarred party. We also reviewed payments made to vendors. For two of the seven vendor contracts we reviewed, we found that UW-Eau Claire did not perform procedures related to suspension and debarment. We found both vendors were registered on SAM.gov and were not on the suspended and debarred parties listing.
Questioned Costs:
None.
Effect:
UW-Eau Claire is at increased risk of entering into a contract with a suspended or debarred party, and is in noncompliance with federal requirements.
Cause:
UW-Eau Claire staff administering the grant indicated that it was not identified during the procurement process that these two contracts related to federal funding and, therefore, that a review of each vendor’s suspension and debarment status was needed.
Recommendation:
We recommend the University of Wisconsin-Eau Claire implement procedures to ensure the suspension and debarment requirements are met and documentation is maintained to support that the requirements are met.
Finding 2024-715: Coronavirus State and Local Fiscal Recovery Funds—Suspension and Debarment Requirements
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Eau Claire: The University of Wisconsin-Eau Claire agrees with the audit finding and recommendation.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Coronavirus State and Local Fiscal Recovery Funds—Suspension and Debarment Requirements
Background:
The State was advanced a total of $3.0 billion under the CSLFRF program in FY 2020-21 and FY 2021-22, from the U.S. Department of the Treasury (U.S. Treasury). CSLFRF was created under the American Rescue Plan Act (ARPA), and later revised by the Consolidated Appropriations Act, 2023. CSLFRF is administered by DOA.
DOA expended funding under CSLFRF for various programs that it established. In addition, DOA entered into a memorandum of understanding (MOU) with various state agencies to administer several different programs funded by CSLFRF. In June 2022, DOA entered into an MOU with UW System Administration called the Mental Health Initiative, with the goal of making mental health resources available to students by contracting with providers, providing training to enhance the capacity of university staff to deliver mental health programming, and providing grants to UW institutions to develop mental health programs. In addition, in April 2024 UW System Administration’s Office of Business and Entrepreneurship entered into a subgrant agreement with WEDC to administer technical assistance to grantees of WEDC’s Main Street Bounceback Program using CSLFRF funding.
Criteria:
2 CFR s. 200.214 prohibits recipients of federal funding from entering into contracts with suspended or debarred parties. Further, 2 CFR s. 180.300 requires recipients of federal funding to ensure they do not enter into a contract with a suspended or debarred party by completing one of the following steps:
-reviewing the suspended and debarred parties listing on SAM.gov;
-collecting a certification from the party that they are not suspended or debarred; or
-including a clause or condition regarding suspension and debarment in the procurement contract.
Condition:
We found that UW System Administration entered into contracts with vendors to administer the Mental Health Initiative and the subgrant with WEDC. UW System Administration did not complete or document that it completed any of the required steps to ensure the parties were not suspended or debarred.
Context:
The MOU with DOA provided UW System Administration $5.0 million in CSLFRF funding for the Mental Health Initiative and, in FY 2023-24, UW System Administration expended $1.7 million. We inquired of UW System Administration staff regarding procedures for ensuring UW System Administration does not enter into a contract with a suspended or debarred party. We also reviewed payments made to vendors and reviewed contracts for two vendors, and reviewed the suspended and debarred parties listing on SAM.gov. We found one of the vendors was registered on SAM.gov and was not on the suspended and debarred parties listing. However, the other vendor was not registered on SAM.gov, so we could not determine the suspension and debarment status of this vendor.
The subgrant from WEDC provided UW System Administration $5.0 million in CSLFRF funding, of which UW System Administration expended $666,000 in FY 2023-24. We inquired of staff in UW System Administration’s Office of Business and Entrepreneurship regarding its procedures for ensuring it does not enter into a contract with a suspended or debarred party. We also reviewed payments made to vendors and reviewed contracts for two vendors, and reviewed the suspended and debarred parties listing on SAM.gov. We found the vendors for the WEDC subgrant were not registered on SAM.gov, so we could not determine the suspension and debarment status of these vendors.
Questioned Costs:
None.
Effect:
UW System Administration is at increased risk of entering into a contract with a suspended or debarred party, and is in noncompliance with federal requirements.
Cause:
UW System Administration staff administering the Mental Health Initiative were unaware of the suspension and debarment requirements, and UW System Administration did not have procedures in place to meet the federal requirements. UW System Administration staff indicated that responsibility for and debarment requirements was transitioned to UW-Madison, Research and Sponsored Programs in FY 2024-25.
Staff in UW System Administration’s Office of Business and Entrepreneurship who administer the WEDC subgrant noted that they review SAM.gov, as well as other types of vendor checks but did not maintain documentation of the review.
Recommendation:
We recommend the University of Wisconsin System Administration implement procedures to ensure the suspension and debarment requirements are met and documentation is maintained to demonstrate the requirements were met.
Finding 2024-714: Coronavirus State and Local Fiscal Recovery Funds—Suspension and Debarment Requirements
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Numbers Award Years
None 2021
Subgrant KSP FY 24-53693 2024
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendation.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
Background:
The State was advanced a total of $3.0 billion under the CSLFRF program in FY 2020-21 and FY 2021-22, from the U.S. Department of the Treasury (U.S. Treasury). CSLFRF was created under the American Rescue Plan Act (ARPA), and later revised by the Consolidated Appropriations Act, 2023. CSLFRF is administered by DOA. CSLFRF funding has certain eligible uses, including those in an eligible use category for the provision of government services to the extent revenue losses due to the public health emergency reduced revenues. CSLFRF recipients calculated lost revenues for the years 2020, 2021, 2022, and 2023 based on a formula in the 2022 Treasury final rule to determine the amount of CSLFRF funds that may be used for the provision of government services in the eligible use category.
DOA expended funding under CSLFRF for various programs that it established. In addition, DOA entered into a memorandum of understanding (MOU) with
various state agencies to administer several different programs funded by CSLFRF. In June 2022, DOA entered into an MOU with DHS related to COVID-19 vaccination distribution.
Criteria:
Under the 2022 Treasury final rule, U.S. Treasury determined that CSLFRF funding available for the provision of government services may be used to meet the non-federal match requirements of other federal programs. Further, CSLFRF funding available under other eligible use categories may not be used to meet the non-federal match requirements of other programs, unless specifically allowed by statute.
Condition:
DHS used CSLFRF funding to meet its match requirement for the Disaster Grants - Public Assistance (Presidentially Declared Disasters) (Public Assistance) (Assistance Listing number 97.036). DHS recorded a transaction of $862,677 to its COVID-19 vaccination distribution program in January 2024, and counted this transaction as part of meeting its non-federal match requirement under the Public Assistance grant. The COVID-19 vaccination distribution program is reported under the U.S. Treasury eligible use category related to responding to the public health emergency and its negative impacts. Under this eligible use category, DHS is not allowed to use CSLFRF funding as non-federal match for another federal program.
Context:
During FY 2023-24, DHS expended $39.0 million in CSLFRF funding. We interviewed DHS staff to gain an understanding of DHS’s administration of the CSLFRF funding, including how it assessed using CSLFRF funding to meet its non-federal match for other federal programs. We reviewed general ledger transactions made by DHS for the CSLFRF grant, identified the DHS transaction, and followed up with DHS regarding the purpose of the transaction. DHS is responsible for ensuring costs charged to federal grant programs meet the federal requirements.
Questioned Costs:
$862,677
Effect:
DHS is in noncompliance with federal requirements for allowable uses of CSLFRF funding and DHS did not meet its non-federal match requirements for the Public Assistance grant, because DHS used CSLFRF funding to meet the non-federal match requirement.
Cause:
DHS staff indicated they were not aware of the eligible use category for its COVID-19 vaccination distribution project funded by CSLFRF. Further, the MOU between DOA and DHS did not include information to allow DHS to understand what the eligible use category was or the restrictions related to the use of the funds to meet non-federal match for other federal grants. DOA did provide DHS with information regarding the eligible use category through quarterly reporting requirements to the U.S. Treasury. Further, DOA and DHS staff indicated regular discussions occurred between the two agencies regarding the CSLFRF funding.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-take steps to further its understanding of the Coronavirus State and Local Fiscal Recovery Funds grant it is administering to ensure it administers the grant in compliance with all federal rules; and
-review the non-federal match requirements for the Public Assistance grant and ensure it has met the non-federal match requirements.
Finding 2024-304: Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: $862,677
Type of Finding: Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services disagrees with the audit finding and recommendations.
Rebuttal from the Wisconsin Legislative Audit Bureau: In its corrective action plan on page 351, the Department of Health Services (DHS) indicated that it disagrees with the unallowable costs identified in this finding and noted that the costs are allowable in accordance with its memorandum of understanding with the Department of Administration and the 2022 Treasury final rule. As stated in the finding, DHS used $862,677 in expenditures under its COVID-19 vaccination distribution program as match for the Public Assistance grant. The 2022 Treasury final rule and the U.S. Department of the Treasury (U.S. Treasury) frequently asked questions related to the Coronavirus State Local and Fiscal Recovery Funds (CSLFRF) grant indicate that only funding under the revenue loss eligible use category may be used to meet non-federal match for another federal program. Therefore, using the expenditures for the COVID-19 vaccination distribution program as the non-federal match for the Public Assistance grant is not allowable.
DHS indicated that “given the nature of these expenditures, they would not have been unallowable, except for their misclassification on the federal report.” We note that the COVID-19 vaccination distribution program has been reported under the public health eligible use category since its inception. Therefore, no misclassification occurred on the federal report.
DHS noted that its position is supported by the fact that no accounting entries were needed to resolve the eligible use category for the purpose of federal reporting.
As we have stated, this issue relates to the unallowable use of CSLFRF funding as non-federal match for another federal program. This is not a federal reporting issue.
We note that subsequent to our questions regarding the use of these funds for non-federal match, the State created a new U.S. Treasury project called COVID-19 Vaccination Non-Federal Match with a budget of $862,677 and reported the project under the revenue loss eligible use category in its report filed for the quarter ended December 31, 2024. Although the State chose to address the finding in this manner, it does not change the fact that DHS was non-compliant with the matching requirements of the CSLFRF grant when it used the funding from the COVID-19 vaccination distribution program as non-federal match for another federal program.
Coronavirus State and Local Fiscal Recovery Funds—Suspension and Debarment Requirements
Background:
The State was advanced a total of $3.0 billion under the CSLFRF program in FY 2020-21 and FY 2021-22, from the U.S. Department of the Treasury (U.S. Treasury). CSLFRF was created under the American Rescue Plan Act (ARPA), and later revised by the Consolidated Appropriations Act, 2023. CSLFRF is administered by DOA.
DOA expended funding under CSLFRF for various programs that it established. In addition, DOA entered into a memorandum of understanding (MOU) with various state agencies to administer several different programs funded by CSLFRF. In January 2022, DOA entered into an MOU with Tourism called the Tourism Marketing Initiative. The goal of the initiative related to implementing marketing and communications initiatives to support the travel, hospitality, and adjacent industries to recover from the public health emergency.
Criteria:
2 CFR s. 200.214 prohibits recipients of federal funding from entering into contracts with suspended or debarred parties. Further, 2 CFR s. 180.300 requires recipients of federal funding to ensure they do not enter into a contract with a suspended or debarred party by completing one of the following steps:
-reviewing the suspended and debarred parties listing on SAM.gov;
-collecting a certification from the party that they are not suspended or debarred; or
-including a clause or condition regarding suspension and debarment in the procurement contract.
Condition:
Although Tourism entered into contracts with vendors to administer the Tourism Marketing Initiative, we found that Tourism completed none of the required steps to ensure the parties were not suspended or debarred.
Context:
The MOU with DOA provided Tourism $7.5 million in CSLFRF funding for the Tourism Marketing Initiative. Tourism expended $972,295 for the initiative in FY 2023-24. We inquired of Tourism staff regarding the agency’s procedures for ensuring it does not enter into a contract with a suspended or debarred party. We also reviewed payments made to vendors and reviewed contracts for five vendors, two of which were entered into during FY 2023-24 and two of which were amended during FY 2023-24.
Questioned Costs:
None.
Effect:
Tourism is at increased risk of entering into a contract with a suspended or debarred party and is in noncompliance with federal requirements.
Cause:
Tourism does not administer significant federal funding. Tourism staff indicated they were unaware of the suspension and debarment requirements and had not developed procedures sufficient and appropriate to meet the federal requirements.
Recommendation:
We recommend the Wisconsin Department of Tourism establish procedures to ensure it does not contract with suspended or debarred parties and complies fully with all applicable federal requirements for funds it administers.
Finding 2024-903: Coronavirus State and Local Fiscal Recovery Funds—Suspension and Debarment Requirements
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Tourism: The Wisconsin Department of Tourism agrees with the audit finding and recommendation.
Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
Background:
The State was advanced a total of $3.0 billion under the CSLFRF program in FY 2020-21 and FY 2021-22, from the U.S. Department of the Treasury (U.S. Treasury). CSLFRF was created under the American Rescue Plan Act (ARPA), and later revised by the Consolidated Appropriations Act, 2023. CSLFRF is administered by DOA.
DOA expended funding under CSLFRF for various programs that it established. In addition, DOA entered into a memorandum of understanding (MOU) with various state agencies to administer several different programs funded by CSLFRF. In January 2022, DOA entered into an MOU with SPD to provide assistance to SPD to hire staff to fill project positions to address its case backlog. Through position requests to DOA in 2021, 2022, and 2023, SPD received approval to create 65.0 two-year project positions to be funded by the CSLFRF grant.
Criteria:
Under 2 CFR s. 200.303, SPD is responsible for establishing and maintaining effective internal control over federal awards to provide reasonable assurance that federal awards are managed in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, SPD is required to follow U.S. Treasury guidance that requires it to maintain documentation to demonstrate that CSLFRF funding was used in accordance with federal regulations.
Condition:
We reviewed payroll records to determine whether employee time charged to the CSLFRF grant was approved by an appropriate supervisor with knowledge of the employee’s work effort. We reviewed the approvals for a selection of 15 project employees at SPD funded by the CSLFRF grant and found that time was approved by an appropriate supervisor for all but one of the employees. We found that the time for one employee was not approved in STAR HCM, the State’s payroll system. Certain amounts charged to the grant for this employee were unallowable to be charged to the grant. This employee was appointed to one of the project positions funded by the CSLFRF grant under the MOU with DOA. This employee left state service on October 6 2023, and was appointed to the project position beginning on October 9, 2023. The employee ended employment with SPD on November 17, 2023. During the three pay periods between October 9, 2023, and November 17, 2023, the employee recorded 3 days of work time and 27 days of leave. Further, on November 30, 2023, the employee was paid $86,605 for accumulated unused leave earned in their previous position.
Context:
During FY 2023-24, SPD expended $5.6 million in CSLFRF funding. We interviewed SPD staff to gain an understanding of SPD’s administration of the CSLFRF funding, including how it charged payroll costs to the CSLFRF grant. We reviewed payroll transactions made by SPD for the CSLFRF program, identified the payout for a terminated employee, and followed up with SPD regarding the purpose of the transaction.
Questioned Costs:
$107,164, which consists of $86,605 in payment for unused leave and $20,559 in leave taken during the three-week period the employee worked in the project position.
Effect:
SPD charged payroll costs to the CSLFRF grant that did not relate to the underlying project positions established in the MOU with DOA.
Cause:
SPD staff indicated that charging the CSLFRF grant for the costs related to the unused leave for the employee was an oversight. According to SPD staff, the former employee made a decision to terminate from the project position and the unused leave was inadvertently charged to the grant. SPD staff did not explain why the 27 days of leave was charged to the grant during the months of October and November of 2023, or why the employee’s time was not approved in STAR.
Recommendation:
We recommend the Wisconsin State Public Defender’s Office:
-review and update its procedures to ensure employee timesheets are appropriately approved by a supervisor with knowledge of each employee’s work effort;
-review and update its procedures to ensure costs are charged to the correct accounting codes and funding sources are appropriately used;
-take steps to ensure it administers the funding for the Coronavirus State and Local Fiscal Recovery Funds grant in compliance with the memorandum of understanding with the Department of Administration and with federal rules; and
-adjust its accounting records to use a different funding source for the leave and termination payments for unused leave for the employee identified during the audit.
Finding 2024-902: Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: $107,164
Type of Finding: Noncompliance
Response from the Wisconsin State Public Defender’s Office: The Wisconsin State Public Defender’s Office agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to Federal Funding Accountability and Transparency Act (FFATA) reporting for certain grant programs administered by the State. During FY 2023-24, DOA’s Division of Executive Budget and Finance was responsible for uploading required FFATA information into the FFATA Subaward Reporting System (FSRS) based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DOA also provided guidance and technical assistance to agencies on FFATA reporting requirements.
During our FY 2022-23 single audit (report 24-3), we identified concerns that DOA’s method of reporting modifications to subawards in FSRS resulted in an overstatement of the subaward information in FSRS and on USAspending.gov. In report 24-3, we recommended that DOA alter its approach and report only the amount of subaward modifications, update guidance to agencies, and provide training to state agencies on appropriate reporting (Finding 2023-106). We also recommended that DOA maintain its current approach of reporting cumulative amounts with subaward modifications only if it received specific guidance from the Office of Management and Budget (OMB) that its current reporting was appropriate. DOA agreed with our recommendations. Further, in January 2025 the U.S. Department of Health and Human Services sustained the audit finding and recommended that DOA revise and resubmit any reports that contained inaccurate data.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance on FSRS.gov indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Further, guidance posted on the U.S. General Services Administration (GSA) website in spring 2024 provided clarification that when a subaward is modified, the preparer should update the original entry in FSRS. The guidance also indicated that if information for a subaward changes, the preparer is to update the original report in FSRS.
Condition:
In response to our prior year recommendation, DOA contacted OMB for clarification on the FFATA reporting requirements. OMB’s response indicated that DOA should “use the total amount after adjusted,” in reporting subaward modifications in FSRS. DOA interpreted this guidance to mean it would continue its established process for reporting subaward modifications by reporting the cumulative amount of the subaward, not just the modification, in FSRS. Therefore, DOA did not alter its reporting of subaward modifications in FSRS for FY 2023-24. For example, in reviewing subaward information on USAspending.gov for a subaward related to the Temporary Assistance for Needy Families grant (Assistance Listing number 93.558), we found that the total subaward was overstated on USAspending.gov because DOA reported cumulative amounts for each modification.
Context:
DOA staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including the departments of Children and Families and Natural Resources. We discussed DOA’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov, and the updated guidance on the GSA website. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2023-24 for which FFATA reporting was subject to audit and for which DOA was responsible for FFATA reporting. We also followed up on the status of the prior year audit finding and the steps DOA took to address the finding.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USAspending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
In our prior audit, DOA indicated that it relied on guidance from an OMB official who indicated that cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. In our current audit, DOA relied on its March 2024 inquiries of OMB subsequent to our recommendations in March 2024, which DOA interpreted as a requirement to continue its current procedures.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report subaward modifications as an adjustment to the original subaward record in the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission in FSRS; and
-provide training to state agencies to ensure consistent reporting across state agencies.
Finding 2024-101: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02393 2018
00E02349 2018
00E02456 2019
00E02824 2020
00E03252 2022
00E03490 2023
Questioned Costs: None
Temporary Assistance for Needy Families (Assistance Listing number 93.558)
Award Number Award Year
2301WITANF 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Geographic Programs - Great Lakes Restoration Initiative—Federal Financial Reporting
Background:
The DNR receives federal funding from the U.S. Environmental Protection Agency (EPA) for the GLRI program. The objective of the GLRI program is to advance protection and restoration of the Great Lakes Basin Ecosystem through the funding of various projects.
Criteria:
Under 2 CFR s. 200.328, and at least annually, DNR must submit the Federal Financial Report (FFR) to the EPA for each project of the GLRI program. DNR is required to submit annual FFRs no later than 90 calendar days after the project’s reporting period and final FFRs no later than 120 calendar days after the conclusion of the project’s period of performance. The EPA may grant extension of reporting due dates when requested and justified by the recipient.
Condition:
DNR did not submit FFRs in a timely manner for six of the nine annual FFR reports we tested for the GLRI program, and DNR did not request an extension of reporting due dates from the EPA. The six annual FFRs we tested were completed between 17 and 219 calendar days past the due date. For example, four FFRs we tested had a reporting period end date of March 31, 2024, and a report due date of June 29, 2024. DNR filed the annual FFRs on November 1, 2024, which was 125 days past the due date. For five of the six annual FFRs we tested that were late, we noted that DNR submitted the FFRs after our inquiry and request to review the FFRs. For each of the six FFRs, we found that DNR retained documentation to support the amounts included in the reports and the information in the FFRs was accurate.
Context:
During FY 2023-24, DNR expended $15.5 million under the GLRI program. We interviewed DNR staff to gain an understanding of its procedures for preparing FFRs for GLRI projects. During FY 2023-24, DNR was required to submit 20 annual FFRs and 2 final FFRs for GLRI projects to the EPA. We reviewed nine of the annual FFRs and the 2 final FFRs. We requested DNR’s documentation to support the information reported in the FFRs.
Questioned Costs:
None.
Effect:
The EPA did not have timely financial reports to assess DNR’s management of GLRI projects.
Cause:
DNR did not have sufficient procedures in place to track when annual FFRs were required to be submitted for GLRI projects. Although DNR’s procedures require the GLRI program’s grant accountant to monitor FFR due dates, that position was vacant during FY 2023-24 and filled in FY 2024-25. DNR indicated that other grant accountants completed some reporting for the GLRI program, but not all reporting was completed until after we made inquiries of DNR staff in October 2024. DNR staff indicated that they began to implement changes in October 2024 to more effectively track FFR due dates by having DNR’s Management and Grant Accounting Section Chief monitor the FFR reporting schedule.
Recommendation:
We recommend the Wisconsin Department of Natural Resources develop and implement policies and procedures for tracking and submitting timely federal financial reports for the Geographic Programs - Great Lakes Restoration Initiative program.
Finding 2024-800: Geographic Programs - Great Lakes Restoration Initiative—Federal Financial Reporting
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02393 2018
00E02456 2019
00E02487 2019
00E02824 2020
00E02979 2021
00E02975 2021
00E03010 2021
00E03068 2021
03E00712 2022
01E03010 2022
00E03149 2022
00E03187 2022
00E03188 2022
00E03250 2022
00E03252 2022
00E03589 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Natural Resources: The Wisconsin Department of Natural Resources agrees with the audit finding and recommendation.
Geographic Programs - Great Lakes Restoration Initiative—Subrecipient Monitoring
Background:
DNR receives federal funding from the EPA for the GLRI program. The objective of the GLRI program is to advance protection and restoration of the Great Lakes Basin Ecosystem through the funding of various projects. To administer the GLRI program, DNR contracts with subrecipients located around the State, including counties, cities, and sewage districts.
During our FY 2022-23 single audit (report 24-3), we identified that DNR did not perform subrecipient risk assessments or have a plan to monitor subrecipients for the GLRI program based on the risk assessments. Further, DNR did not have sufficient procedures in place to ensure all GLRI subrecipient single audit reports were being obtained and reviewed. We recommended that DNR develop a written monitoring plan for the GLRI program that includes policies and procedures for:
-completing risk assessments for each subrecipient;
-the specific monitoring steps that are required based on the level of subrecipient risk identified in a risk assessment;
-independently identifying and reviewing subrecipient single audit reports, if applicable; and
-maintaining documentation of all subrecipient monitoring activities (Finding 2023-800).
During FY 2023-24, and in response to our recommendations, DNR developed policies and procedures for monitoring and performing risk assessments of the GLRI subrecipients. In addition, DNR developed procedures to ensure GLRI subrecipient single audit reports were being obtained and reviewed. DNR completed its review of these reports in May 2024.
Criteria:
DNR administers federal programs that are subject to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Uniform Guidance includes three requirements related to the monitoring of subrecipients. First, 2 CFR s. 200.332 (a) (1) requires DNR to communicate certain award information to subrecipients at the time of the subaward. Second, 2 CFR s. 200.332 (b) requires DNR to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring. Finally, 2 CFR s. 200.332 (d) through (f) requires DNR to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
An EPA subaward policy further clarifies that the Uniform Guidance provisions are applicable to its grant programs, including a requirement for DNR to establish and follow a system for evaluating the risks of subrecipient noncompliance with laws, regulations, and the terms and conditions of the subaward, as required by 2 CFR ss. 200.332 (b) and (d). This policy also requires DNR to document its evaluations. In addition, EPA’s policy requires that DNR establish and follow a process for deciding whether to impose additional requirements on subrecipients based on the risk assessments.
Condition:
In response to our FY 2023-24 recommendation, in June 2024 DNR developed policies and procedures for monitoring GLRI subrecipients, including procedures for completing a risk assessment for each GLRI subrecipient and ranking each subrecipient based on the risk assessment to determine the level of monitoring needed. However, DNR did not complete risk assessments for any of its GLRI subrecipients during FY 2023-24.
Context:
DNR expended $15.5 million under the GLRI program during FY 2023-24, including $4.0 million that it provided to 21 subrecipients. We interviewed DNR staff to gain an understanding of its procedures for monitoring subrecipients. We reviewed the agreements between DNR and the subrecipients to identify whether DNR had communicated the required award information to them. We also reviewed monitoring activities DNR performed for the GLRI program, including DNR’s process to review subrecipient single audit reports and DNR’s monitoring of subrecipients through progress reporting and reimbursement requests. Finally, we reviewed and discussed with DNR staff the new procedures for completing subrecipient risk assessments.
Questioned Costs:
None.
Effect:
Because DNR did not comply with all subrecipient monitoring compliance requirements for the GLRI program, there is a higher risk that DNR and its GLRI subrecipients are not in compliance with all federal requirements.
Cause:
Although DNR developed policies and procedures for monitoring and performing risk assessments for the GLRI subrecipients, it did not complete risk assessments for the GLRI subrecipients during FY 2023-24. DNR indicated it would implement its policies and procedures for monitoring and performing risk assessments for the GLRI subrecipients as new subawards are created in FY 2024-25. However, DNR should also perform risk assessments for existing GLRI subrecipients to ensure its monitoring of the activities for ongoing GLRI projects is appropriate.
Recommendation:
We recommend the Wisconsin Department of Natural Resources implement its new monitoring policies and procedures for completing risk assessments for each subrecipient of the Geographic Programs - Great Lakes Restoration Initiative program, including for all its existing subrecipients for ongoing projects.
Finding 2024-801: Geographic Programs - Great Lakes Restoration Initiative—Subrecipient Monitoring
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02393 2018
00E02456 2019
00E02490 2019
00E02824 2020
00E02975 2021
00E02979 2021
00E03010 2021
03E00712 2022
01E03010 2022
00E03149 2022
00E03250 2022
00E03252 2022
00E03490 2023
00E03486 2023
00E03589 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Natural Resources: The Wisconsin Department of Natural Resources agrees with the audit finding and recommendation.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Background:
DHHS provides funding to DHS for SABG, the ELC grant, the Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response, which DHS refers to as the Public Health Emergency Response grant, and the Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises program, which DHS refers to as the Health Disparities grant. These grants have various health-related purposes. To fulfill the purpose of each grant, DHS subawards funds to various entities, including counties, tribal governments, and other nonprofit organizations. In addition, under the SABG grant, amounts are provided by DHS to DCF and the University of Wisconsin-Madison (UW-Madison), which further subgrant to various entities.
Under FFATA, a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
In our FY 2022-23 audit (report 24-3), we identified that DHS had not accurately reported information in FSRS for several grants. We recommended DHS improve its procedures to accurately report required award information in a timely manner, including the date the subaward agreement was signed, and develop procedures to identify and report subawards made by state agencies to which it had transferred federal funding (Finding 2023-304).
Criteria:
Under 2 CFR s. 170, and as the prime grant awardee for these grants, DHS has overall responsibility for FFATA reporting and is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2023, it must be reported no later than January 31, 2024. The information required to be reported in FSRS includes several key data elements such as information about the recipient, the amount of the award, the project description, and the date the subaward agreement was signed.
Condition:
We selected a total of 34 subawards made by DHS under these grants during FY 2023-24 for testing, and we identified that 28 of the 34 subawards were not reported in a timely manner. We found that 14 of the 20 SABG subawards were not reported in a timely manner. For example, under the SABG grant, ten subawards were reported in August 2024, which was between seven to ten months after the date of the subaward.
In addition, we identified the obligation date was not accurate to within 10 days of the date the subaward agreement was signed for two subawards made under the SABG grant. We also found that none of the ELC, Public Health Emergency Response, and Health Disparities subawards we tested were reported in a timely manner. In addition, we found the project description was not completed accurately for ten subawards, including three for SABG subawards, two for ELC subawards, two for Public Health Emergency Response subawards, and three for Health Disparities subawards. Finally, we found that DHS did not report in FSRS any of the seven subawards DCF made under the SABG grant. DHS also did not report in FSRS the one subaward UW-Madison made under the SABG grant.
Context:
During FY 2023-24, DHS expended:
-$35.1 million under the SABG grant, of which $31.1 million was provided to subrecipients;
-$46.9 million under the ELC grant, of which $9.1 million was provided to subrecipients;
-$14.7 million under the Public Health Emergency Response grant, of which $8.3 million was provided to subrecipients; and
-$7.9 million under the Health Disparities grant, of which $2.6 million was provided to subrecipients.
Under the SABG grant, DCF expended $2.9 million, that was provided to subrecipients. Under the SABG grant, UW-Madison expended $0.2 million that was provided to subrecipients.
We reviewed 20 subawards for the SABG grant, two subawards for the ELC grant, nine for the Public Health Emergency Response grant, and three subawards for the Health Disparities grant that were made by DHS during FY 2023-24. We interviewed DHS staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. To assess if the subawards were reported in an accurate and timely manner, we requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed. We further followed up on the status of our prior audit recommendations.
Questioned Costs:
None.
Effect:
DHS did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS. The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov.
Cause:
In report 24-3, we noted that there were issues with the queries used to obtain information for reporting and procedures did not include obtaining information related to subawards made by other state agencies. During FY 2023-24, queries to retrieve information were established in a new system. However, the procedures in place to review the data produced by the queries and to determine what to report in FSRS were insufficient to ensure accurate and timely reporting. In response to our prior audit finding, DHS reported that it updated its FFATA reporting procedures. However, since the updates were not implemented until late in FY 2023-24, issues continued to be identified in our current audit.
Recommendation:
We recommend the Wisconsin Department of Health Services continue its efforts to implement updated procedures and make future revisions to these procedures for Federal Funding Accountability and Transparency Act reporting to ensure reporting is accurate, complete, and submitted in a timely manner.
Finding 2024-309: Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
COVID-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response (Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response
(Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises
(Assistance Listing number 93.391)
Award Numbers Award Years
1 NH75OT000039-01-00 2021
6 NH75OT000039-01-03 2023
6 NH75OT000039-01-05 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
COVID-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Year
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)—Subrecipient Monitoring
Background:
The U.S. Department of Health and Human Services, Centers for Disease Control and Prevention (CDC) provides funding to DHS under the ELC grant. The ELC grant provides financial support and technical assistance to the State to detect, prevent, respond to, and control emerging infectious diseases.
To administer the award under the ELC grant, DHS contracted with a variety of subrecipients, including local and tribal public health agencies and nonprofit entities. DHS uses GEARS to process the reimbursement requests for the majority of subrecipients.
Criteria:
DHS administers federal programs that are subject to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Uniform Guidance includes the following requirements related to the monitoring of subrecipients:
-2 CFR s. 200.332 (b) requires DHS to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring; and
-2 CFR s. 200.332 (d) through (f) requires DHS to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
DHS established policies requiring grant administrators to conduct a risk assessment for every subaward of federal funds and to use the risk assessment to determine the frequency and extent of monitoring. DHS policies include a subrecipient risk assessment template to assist grant administrators in completing the risk assessment and determining the risk level of the subrecipient.
DHS policies also require grant administrators to monitor subrecipients based on the risk assessments. DHS policies indicate that monitoring may include providing subrecipient training and technical assistance; performing desk reviews of the subrecipient’s records; and performing on-site reviews of the subrecipient’s records and operations. Finally, DHS policies in the Division of Public Health Bureau of Operations Contract Management Manual suggest that when GEARS is used to process reimbursement requests, grant administrators should use enhanced expenditure reporting from subrecipients to ensure expenditures are allowable. These policies note that additional verification may be performed by reviewing subrecipient financial records through a desk review or an on-site visit.
Condition:
DHS did not complete subrecipient risk assessments for two tribal governments that were subrecipients of the ELC grant. In addition, DHS did not define the level of monitoring to be performed based on the completed risk assessments. There was no documentation to indicate the level of monitoring required for low-, moderate-, and high-risk subrecipients, such as when DHS would be required to review subrecipient invoices through a desk review or an on-site visit. Further, DHS did not develop procedures for assessing and documenting desk reviews of subrecipient invoices, for assessing and documenting the reliance that can be placed on review of subrecipient single audit reports, and for documenting management oversight of the monitoring plan.
Context:
DHS expended $46.9 million under the ELC grant during FY 2023-24, including $9.1 million that was provided to subrecipients. Of the $9.1 million provided to subrecipients, $4.8 million was processed through GEARS. In FY 2023-24 DHS provided funding to 73 subrecipients to administer the program, including six tribal governments. We interviewed DHS staff to gain an understanding of DHS policies and procedures for processing reimbursement requests from subrecipients, including its use of GEARS and DHS policies and procedures for monitoring subrecipients.
Questioned Costs:
None.
Effect:
Because its subrecipient monitoring procedures are insufficient, DHS is at increased risk of noncompliance with federal regulations for the ELC grant. There is also an increased risk of improper payments for the ELC grant.
Cause:
DHS staff noted that turnover in staff responsible for completion of risk assessments for tribal public health departments contributed to the risk assessments not being completed.
DHS Division of Public Health established an internal control checklist for subrecipient monitoring in order to help guide staff in completing subrecipient monitoring, including prompts for staff to establish monitoring steps required for low-, moderate-, and high-risk subrecipients. However, this checklist was not implemented until July 2024.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-develop a written monitoring plan for the Epidemiology and Laboratory Capacity for Infectious Diseases grant that includes a description of the subrecipient monitoring expected for low-, moderate-, and high-risk subrecipients; procedures for completing and documenting desk reviews of subrecipient invoices; and procedures for assessing and documenting the reliance that can be placed on review of subrecipient single audit reports;
-provide training on the monitoring plan to staff with responsibilities for subrecipient monitoring activities; and
-develop and implement management oversight procedures to ensure monitoring is being completed and documented.
Finding 2024-305: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)—Subrecipient Monitoring
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing number 93.323)
Award Number Award Years
NU50CK000534 2019-2024
Questioned Costs: None
COVID-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing number 93.323)
Award Number Award Years
NU50CK000534 2019-2024
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Background:
DHHS provides funding to DHS for SABG, the ELC grant, the Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response, which DHS refers to as the Public Health Emergency Response grant, and the Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises program, which DHS refers to as the Health Disparities grant. These grants have various health-related purposes. To fulfill the purpose of each grant, DHS subawards funds to various entities, including counties, tribal governments, and other nonprofit organizations. In addition, under the SABG grant, amounts are provided by DHS to DCF and the University of Wisconsin-Madison (UW-Madison), which further subgrant to various entities.
Under FFATA, a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
In our FY 2022-23 audit (report 24-3), we identified that DHS had not accurately reported information in FSRS for several grants. We recommended DHS improve its procedures to accurately report required award information in a timely manner, including the date the subaward agreement was signed, and develop procedures to identify and report subawards made by state agencies to which it had transferred federal funding (Finding 2023-304).
Criteria:
Under 2 CFR s. 170, and as the prime grant awardee for these grants, DHS has overall responsibility for FFATA reporting and is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2023, it must be reported no later than January 31, 2024. The information required to be reported in FSRS includes several key data elements such as information about the recipient, the amount of the award, the project description, and the date the subaward agreement was signed.
Condition:
We selected a total of 34 subawards made by DHS under these grants during FY 2023-24 for testing, and we identified that 28 of the 34 subawards were not reported in a timely manner. We found that 14 of the 20 SABG subawards were not reported in a timely manner. For example, under the SABG grant, ten subawards were reported in August 2024, which was between seven to ten months after the date of the subaward.
In addition, we identified the obligation date was not accurate to within 10 days of the date the subaward agreement was signed for two subawards made under the SABG grant. We also found that none of the ELC, Public Health Emergency Response, and Health Disparities subawards we tested were reported in a timely manner. In addition, we found the project description was not completed accurately for ten subawards, including three for SABG subawards, two for ELC subawards, two for Public Health Emergency Response subawards, and three for Health Disparities subawards. Finally, we found that DHS did not report in FSRS any of the seven subawards DCF made under the SABG grant. DHS also did not report in FSRS the one subaward UW-Madison made under the SABG grant.
Context:
During FY 2023-24, DHS expended:
-$35.1 million under the SABG grant, of which $31.1 million was provided to subrecipients;
-$46.9 million under the ELC grant, of which $9.1 million was provided to subrecipients;
-$14.7 million under the Public Health Emergency Response grant, of which $8.3 million was provided to subrecipients; and
-$7.9 million under the Health Disparities grant, of which $2.6 million was provided to subrecipients.
Under the SABG grant, DCF expended $2.9 million, that was provided to subrecipients. Under the SABG grant, UW-Madison expended $0.2 million that was provided to subrecipients.
We reviewed 20 subawards for the SABG grant, two subawards for the ELC grant, nine for the Public Health Emergency Response grant, and three subawards for the Health Disparities grant that were made by DHS during FY 2023-24. We interviewed DHS staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. To assess if the subawards were reported in an accurate and timely manner, we requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed. We further followed up on the status of our prior audit recommendations.
Questioned Costs:
None.
Effect:
DHS did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS. The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov.
Cause:
In report 24-3, we noted that there were issues with the queries used to obtain information for reporting and procedures did not include obtaining information related to subawards made by other state agencies. During FY 2023-24, queries to retrieve information were established in a new system. However, the procedures in place to review the data produced by the queries and to determine what to report in FSRS were insufficient to ensure accurate and timely reporting. In response to our prior audit finding, DHS reported that it updated its FFATA reporting procedures. However, since the updates were not implemented until late in FY 2023-24, issues continued to be identified in our current audit.
Recommendation:
We recommend the Wisconsin Department of Health Services continue its efforts to implement updated procedures and make future revisions to these procedures for Federal Funding Accountability and Transparency Act reporting to ensure reporting is accurate, complete, and submitted in a timely manner.
Finding 2024-309: Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
COVID-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response (Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response
(Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises
(Assistance Listing number 93.391)
Award Numbers Award Years
1 NH75OT000039-01-00 2021
6 NH75OT000039-01-03 2023
6 NH75OT000039-01-05 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
COVID-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Year
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)—Subrecipient Monitoring
Background:
The U.S. Department of Health and Human Services, Centers for Disease Control and Prevention (CDC) provides funding to DHS under the ELC grant. The ELC grant provides financial support and technical assistance to the State to detect, prevent, respond to, and control emerging infectious diseases.
To administer the award under the ELC grant, DHS contracted with a variety of subrecipients, including local and tribal public health agencies and nonprofit entities. DHS uses GEARS to process the reimbursement requests for the majority of subrecipients.
Criteria:
DHS administers federal programs that are subject to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Uniform Guidance includes the following requirements related to the monitoring of subrecipients:
-2 CFR s. 200.332 (b) requires DHS to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring; and
-2 CFR s. 200.332 (d) through (f) requires DHS to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
DHS established policies requiring grant administrators to conduct a risk assessment for every subaward of federal funds and to use the risk assessment to determine the frequency and extent of monitoring. DHS policies include a subrecipient risk assessment template to assist grant administrators in completing the risk assessment and determining the risk level of the subrecipient.
DHS policies also require grant administrators to monitor subrecipients based on the risk assessments. DHS policies indicate that monitoring may include providing subrecipient training and technical assistance; performing desk reviews of the subrecipient’s records; and performing on-site reviews of the subrecipient’s records and operations. Finally, DHS policies in the Division of Public Health Bureau of Operations Contract Management Manual suggest that when GEARS is used to process reimbursement requests, grant administrators should use enhanced expenditure reporting from subrecipients to ensure expenditures are allowable. These policies note that additional verification may be performed by reviewing subrecipient financial records through a desk review or an on-site visit.
Condition:
DHS did not complete subrecipient risk assessments for two tribal governments that were subrecipients of the ELC grant. In addition, DHS did not define the level of monitoring to be performed based on the completed risk assessments. There was no documentation to indicate the level of monitoring required for low-, moderate-, and high-risk subrecipients, such as when DHS would be required to review subrecipient invoices through a desk review or an on-site visit. Further, DHS did not develop procedures for assessing and documenting desk reviews of subrecipient invoices, for assessing and documenting the reliance that can be placed on review of subrecipient single audit reports, and for documenting management oversight of the monitoring plan.
Context:
DHS expended $46.9 million under the ELC grant during FY 2023-24, including $9.1 million that was provided to subrecipients. Of the $9.1 million provided to subrecipients, $4.8 million was processed through GEARS. In FY 2023-24 DHS provided funding to 73 subrecipients to administer the program, including six tribal governments. We interviewed DHS staff to gain an understanding of DHS policies and procedures for processing reimbursement requests from subrecipients, including its use of GEARS and DHS policies and procedures for monitoring subrecipients.
Questioned Costs:
None.
Effect:
Because its subrecipient monitoring procedures are insufficient, DHS is at increased risk of noncompliance with federal regulations for the ELC grant. There is also an increased risk of improper payments for the ELC grant.
Cause:
DHS staff noted that turnover in staff responsible for completion of risk assessments for tribal public health departments contributed to the risk assessments not being completed.
DHS Division of Public Health established an internal control checklist for subrecipient monitoring in order to help guide staff in completing subrecipient monitoring, including prompts for staff to establish monitoring steps required for low-, moderate-, and high-risk subrecipients. However, this checklist was not implemented until July 2024.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-develop a written monitoring plan for the Epidemiology and Laboratory Capacity for Infectious Diseases grant that includes a description of the subrecipient monitoring expected for low-, moderate-, and high-risk subrecipients; procedures for completing and documenting desk reviews of subrecipient invoices; and procedures for assessing and documenting the reliance that can be placed on review of subrecipient single audit reports;
-provide training on the monitoring plan to staff with responsibilities for subrecipient monitoring activities; and
-develop and implement management oversight procedures to ensure monitoring is being completed and documented.
Finding 2024-305: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)—Subrecipient Monitoring
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing number 93.323)
Award Number Award Years
NU50CK000534 2019-2024
Questioned Costs: None
COVID-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing number 93.323)
Award Number Award Years
NU50CK000534 2019-2024
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Background:
DHHS provides funding to DHS for SABG, the ELC grant, the Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response, which DHS refers to as the Public Health Emergency Response grant, and the Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises program, which DHS refers to as the Health Disparities grant. These grants have various health-related purposes. To fulfill the purpose of each grant, DHS subawards funds to various entities, including counties, tribal governments, and other nonprofit organizations. In addition, under the SABG grant, amounts are provided by DHS to DCF and the University of Wisconsin-Madison (UW-Madison), which further subgrant to various entities.
Under FFATA, a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
In our FY 2022-23 audit (report 24-3), we identified that DHS had not accurately reported information in FSRS for several grants. We recommended DHS improve its procedures to accurately report required award information in a timely manner, including the date the subaward agreement was signed, and develop procedures to identify and report subawards made by state agencies to which it had transferred federal funding (Finding 2023-304).
Criteria:
Under 2 CFR s. 170, and as the prime grant awardee for these grants, DHS has overall responsibility for FFATA reporting and is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2023, it must be reported no later than January 31, 2024. The information required to be reported in FSRS includes several key data elements such as information about the recipient, the amount of the award, the project description, and the date the subaward agreement was signed.
Condition:
We selected a total of 34 subawards made by DHS under these grants during FY 2023-24 for testing, and we identified that 28 of the 34 subawards were not reported in a timely manner. We found that 14 of the 20 SABG subawards were not reported in a timely manner. For example, under the SABG grant, ten subawards were reported in August 2024, which was between seven to ten months after the date of the subaward.
In addition, we identified the obligation date was not accurate to within 10 days of the date the subaward agreement was signed for two subawards made under the SABG grant. We also found that none of the ELC, Public Health Emergency Response, and Health Disparities subawards we tested were reported in a timely manner. In addition, we found the project description was not completed accurately for ten subawards, including three for SABG subawards, two for ELC subawards, two for Public Health Emergency Response subawards, and three for Health Disparities subawards. Finally, we found that DHS did not report in FSRS any of the seven subawards DCF made under the SABG grant. DHS also did not report in FSRS the one subaward UW-Madison made under the SABG grant.
Context:
During FY 2023-24, DHS expended:
-$35.1 million under the SABG grant, of which $31.1 million was provided to subrecipients;
-$46.9 million under the ELC grant, of which $9.1 million was provided to subrecipients;
-$14.7 million under the Public Health Emergency Response grant, of which $8.3 million was provided to subrecipients; and
-$7.9 million under the Health Disparities grant, of which $2.6 million was provided to subrecipients.
Under the SABG grant, DCF expended $2.9 million, that was provided to subrecipients. Under the SABG grant, UW-Madison expended $0.2 million that was provided to subrecipients.
We reviewed 20 subawards for the SABG grant, two subawards for the ELC grant, nine for the Public Health Emergency Response grant, and three subawards for the Health Disparities grant that were made by DHS during FY 2023-24. We interviewed DHS staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. To assess if the subawards were reported in an accurate and timely manner, we requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed. We further followed up on the status of our prior audit recommendations.
Questioned Costs:
None.
Effect:
DHS did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS. The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov.
Cause:
In report 24-3, we noted that there were issues with the queries used to obtain information for reporting and procedures did not include obtaining information related to subawards made by other state agencies. During FY 2023-24, queries to retrieve information were established in a new system. However, the procedures in place to review the data produced by the queries and to determine what to report in FSRS were insufficient to ensure accurate and timely reporting. In response to our prior audit finding, DHS reported that it updated its FFATA reporting procedures. However, since the updates were not implemented until late in FY 2023-24, issues continued to be identified in our current audit.
Recommendation:
We recommend the Wisconsin Department of Health Services continue its efforts to implement updated procedures and make future revisions to these procedures for Federal Funding Accountability and Transparency Act reporting to ensure reporting is accurate, complete, and submitted in a timely manner.
Finding 2024-309: Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
COVID-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response (Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response
(Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises
(Assistance Listing number 93.391)
Award Numbers Award Years
1 NH75OT000039-01-00 2021
6 NH75OT000039-01-03 2023
6 NH75OT000039-01-05 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
COVID-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Year
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response—Subrecipient Monitoring
Background:
The CDC provides funding to DHS under the Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response grant, which DHS refers to as the Public Health Emergency Response grant. The Public Health Emergency Response grant is intended to provide funding to rapidly respond to public health emergencies as identified by the CDC. DHS received three awards from the CDC to be funded by the Public Health Emergency Response grant: COVID Crisis Response, which ended during FY 2022-23; COVID Public Health Workforce; and Monkey Pox Crisis Response.
Under the COVID Public Health Workforce award, DHS contracted with subrecipients, including local and tribal public health agencies and cooperative educational service agencies (CESAs), to administer the award. DHS uses GEARS to process the reimbursement requests for the local and tribal public health agencies. Reimbursement requests for CESAs are processed directly through STAR, the State’s accounting system, based upon review and approval of detailed invoices. Under the Monkey Pox Crisis Response award, DHS contracted with a nonprofit organization and local public health agencies to administer the award, and used GEARS to process reimbursement requests from the subrecipients.
During our FY 2022-23 audit (report 24-3), we identified concerns with subrecipient monitoring for the Public Health Emergency Response grant and recommended DHS review the tracking spreadsheets and complete its assessment of progress and fiscal reports and consideration of unallowable costs, and return funding to the federal government for unallowable costs identified; develop a monitoring plan; develop a central location to maintain monitoring documentation; and provide sufficient training to staff administering the Public Health Emergency Response grant (Finding 2023-306). DHS agreed with our recommendations and noted specific steps in its corrective action plan to address the concerns.
Criteria:
DHS administers federal programs that are subject to Uniform Guidance, which includes the following requirements related to the monitoring of subrecipients:
-2 CFR s. 200.332 (b) requires DHS to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring; and
-2 CFR s. 200.332 (d) through (f) requires DHS to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
DHS established policies requiring grant administrators to conduct a risk assessment for every subaward of federal funds and to use the risk assessment to determine the frequency and extent of monitoring. DHS policies include a subrecipient risk assessment template to assist grant administrators in completing the risk assessment and determining the risk level of the subrecipient.
DHS policies also require grant administrators to monitor subrecipients based on the risk assessments. DHS policies indicate that monitoring may include providing subrecipient training and technical assistance; performing desk reviews of the subrecipient’s records; and performing on-site reviews of the subrecipient’s records and operations. Finally, DHS policies in the Division of Public Health Bureau of Operations Contract Management Manual suggest that when GEARS is used to process reimbursement requests, grant administrators should use enhanced expenditure reporting from subrecipients to ensure expenditures are allowable. These policies note that additional verification may be performed by reviewing subrecipient financial records through a desk review or an on-site visit.
Condition:
In response to our prior year recommendation, DHS developed an internal control checklist for subrecipient monitoring, established a central location for filing monitoring documentation, and provided training to remind staff of their responsibilities related to subrecipient monitoring. However, the internal control checklist was implemented through a DHS, Division of Health, Bureau of Operations policy in July 2024, and we continued to identify concerns with subrecipient monitoring during FY 2023-24. We found that DHS did not provide documentation that it completed subrecipient risk assessments for three local public health agencies and seven tribal public health agencies that were subrecipients under the Public Health Emergency Response grant and had a contract modification in FY 2023-24. Further, DHS staff indicated that subrecipient risk assessments were not completed for seven of the nine tribal public health agencies when they were first subgranted funding in FY 2021-22.
In addition, DHS did not define the level of monitoring to be performed based on the completed risk assessments. For example, there was no documentation to indicate the level of monitoring required for low-, moderate-, and high-risk subrecipients, such as when it would be required to review subrecipient invoices through a desk review or an on-site visit. Further, DHS did not develop procedures for assessing and documenting desk reviews of subrecipient invoices, for assessing and documenting the reliance that can be placed on review of subrecipient single audit reports, and for documenting management oversight of the monitoring plan. Finally, DHS did not address the prior year recommendation regarding incomplete information and the identification of potential unallowable costs on the FY 2022-23 tracking spreadsheets.
Context:
DHS expended $14.7 million under the Public Health Emergency Response grant during FY 2023-24, including $8.3 million that was provided to subrecipients. Of the $8.3 million provided to subrecipients, $3.5 million was processed through GEARS. We interviewed DHS staff to gain an understanding of DHS policies and procedures for processing reimbursement requests from subrecipients, including its use of GEARS; DHS policies and procedures for monitoring subrecipients; and the steps taken to address our prior year recommendations. For the COVID Public Health Workforce award, DHS contracted with 79 local and tribal public health agencies and 12 CESAs to administer the award. For the Monkey Pox Crisis Response award, DHS contracted with three subrecipients to administer the award.
Questioned Costs:
None.
Effect:
Because its subrecipient monitoring procedures are insufficient, DHS is at increased risk of noncompliance with federal regulations for the Public Health Emergency Response grant. There is also an increased risk of improper payments for the Public Health Emergency Response grant.
Cause:
Although DHS implemented some new subrecipient monitoring procedures and provided training to staff on subrecipient monitoring activities, it continued to have deficiencies in its procedures and monitoring of subrecipients for the Public Health Emergency Response grant during FY 2023-24. DHS indicated it continued to review and update its procedures in FY 2024-25.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-complete its review of the FY 2022-23 subrecipient tracking spreadsheets and complete the assessment of the progress and fiscal reports and consideration of unallowable costs, document the conclusion, and return funding to the federal government if costs were determined to be unallowable;
-complete risk assessments for the three local and seven tribal public health agencies receiving funding under the Public Health Emergency Response grant during FY 2023-24 and adjust subrecipient monitoring appropriately;
-continue to develop a written monitoring plan for the Public Health Emergency Response grant that includes a description of the subrecipient monitoring expected for low-, moderate-, and high-risk subrecipients; procedures for completing and documenting desk reviews of subrecipient invoices; and procedures for assessing and documenting the reliance that can be placed on review of subrecipient single audit reports;
-provide training on the monitoring plan to staff with responsibilities for subrecipient monitoring activities; and
-develop and implement management oversight procedures to ensure monitoring is being completed and documented.
Finding 2024-307: Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response—Subrecipient Monitoring
Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response (Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922227-01 2023
Questioned Costs: None
COVID-19—Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response
(Assistance Listing number 93.354)
Award Numbers Award Years
6 NU90TP922078-01 2020
6 NU90TP922132-01 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Background:
DHHS provides funding to DHS for SABG, the ELC grant, the Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response, which DHS refers to as the Public Health Emergency Response grant, and the Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises program, which DHS refers to as the Health Disparities grant. These grants have various health-related purposes. To fulfill the purpose of each grant, DHS subawards funds to various entities, including counties, tribal governments, and other nonprofit organizations. In addition, under the SABG grant, amounts are provided by DHS to DCF and the University of Wisconsin-Madison (UW-Madison), which further subgrant to various entities.
Under FFATA, a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
In our FY 2022-23 audit (report 24-3), we identified that DHS had not accurately reported information in FSRS for several grants. We recommended DHS improve its procedures to accurately report required award information in a timely manner, including the date the subaward agreement was signed, and develop procedures to identify and report subawards made by state agencies to which it had transferred federal funding (Finding 2023-304).
Criteria:
Under 2 CFR s. 170, and as the prime grant awardee for these grants, DHS has overall responsibility for FFATA reporting and is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2023, it must be reported no later than January 31, 2024. The information required to be reported in FSRS includes several key data elements such as information about the recipient, the amount of the award, the project description, and the date the subaward agreement was signed.
Condition:
We selected a total of 34 subawards made by DHS under these grants during FY 2023-24 for testing, and we identified that 28 of the 34 subawards were not reported in a timely manner. We found that 14 of the 20 SABG subawards were not reported in a timely manner. For example, under the SABG grant, ten subawards were reported in August 2024, which was between seven to ten months after the date of the subaward.
In addition, we identified the obligation date was not accurate to within 10 days of the date the subaward agreement was signed for two subawards made under the SABG grant. We also found that none of the ELC, Public Health Emergency Response, and Health Disparities subawards we tested were reported in a timely manner. In addition, we found the project description was not completed accurately for ten subawards, including three for SABG subawards, two for ELC subawards, two for Public Health Emergency Response subawards, and three for Health Disparities subawards. Finally, we found that DHS did not report in FSRS any of the seven subawards DCF made under the SABG grant. DHS also did not report in FSRS the one subaward UW-Madison made under the SABG grant.
Context:
During FY 2023-24, DHS expended:
-$35.1 million under the SABG grant, of which $31.1 million was provided to subrecipients;
-$46.9 million under the ELC grant, of which $9.1 million was provided to subrecipients;
-$14.7 million under the Public Health Emergency Response grant, of which $8.3 million was provided to subrecipients; and
-$7.9 million under the Health Disparities grant, of which $2.6 million was provided to subrecipients.
Under the SABG grant, DCF expended $2.9 million, that was provided to subrecipients. Under the SABG grant, UW-Madison expended $0.2 million that was provided to subrecipients.
We reviewed 20 subawards for the SABG grant, two subawards for the ELC grant, nine for the Public Health Emergency Response grant, and three subawards for the Health Disparities grant that were made by DHS during FY 2023-24. We interviewed DHS staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. To assess if the subawards were reported in an accurate and timely manner, we requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed. We further followed up on the status of our prior audit recommendations.
Questioned Costs:
None.
Effect:
DHS did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS. The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov.
Cause:
In report 24-3, we noted that there were issues with the queries used to obtain information for reporting and procedures did not include obtaining information related to subawards made by other state agencies. During FY 2023-24, queries to retrieve information were established in a new system. However, the procedures in place to review the data produced by the queries and to determine what to report in FSRS were insufficient to ensure accurate and timely reporting. In response to our prior audit finding, DHS reported that it updated its FFATA reporting procedures. However, since the updates were not implemented until late in FY 2023-24, issues continued to be identified in our current audit.
Recommendation:
We recommend the Wisconsin Department of Health Services continue its efforts to implement updated procedures and make future revisions to these procedures for Federal Funding Accountability and Transparency Act reporting to ensure reporting is accurate, complete, and submitted in a timely manner.
Finding 2024-309: Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
COVID-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response (Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response
(Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises
(Assistance Listing number 93.391)
Award Numbers Award Years
1 NH75OT000039-01-00 2021
6 NH75OT000039-01-03 2023
6 NH75OT000039-01-05 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
COVID-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Year
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response—Subrecipient Monitoring
Background:
The CDC provides funding to DHS under the Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response grant, which DHS refers to as the Public Health Emergency Response grant. The Public Health Emergency Response grant is intended to provide funding to rapidly respond to public health emergencies as identified by the CDC. DHS received three awards from the CDC to be funded by the Public Health Emergency Response grant: COVID Crisis Response, which ended during FY 2022-23; COVID Public Health Workforce; and Monkey Pox Crisis Response.
Under the COVID Public Health Workforce award, DHS contracted with subrecipients, including local and tribal public health agencies and cooperative educational service agencies (CESAs), to administer the award. DHS uses GEARS to process the reimbursement requests for the local and tribal public health agencies. Reimbursement requests for CESAs are processed directly through STAR, the State’s accounting system, based upon review and approval of detailed invoices. Under the Monkey Pox Crisis Response award, DHS contracted with a nonprofit organization and local public health agencies to administer the award, and used GEARS to process reimbursement requests from the subrecipients.
During our FY 2022-23 audit (report 24-3), we identified concerns with subrecipient monitoring for the Public Health Emergency Response grant and recommended DHS review the tracking spreadsheets and complete its assessment of progress and fiscal reports and consideration of unallowable costs, and return funding to the federal government for unallowable costs identified; develop a monitoring plan; develop a central location to maintain monitoring documentation; and provide sufficient training to staff administering the Public Health Emergency Response grant (Finding 2023-306). DHS agreed with our recommendations and noted specific steps in its corrective action plan to address the concerns.
Criteria:
DHS administers federal programs that are subject to Uniform Guidance, which includes the following requirements related to the monitoring of subrecipients:
-2 CFR s. 200.332 (b) requires DHS to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring; and
-2 CFR s. 200.332 (d) through (f) requires DHS to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
DHS established policies requiring grant administrators to conduct a risk assessment for every subaward of federal funds and to use the risk assessment to determine the frequency and extent of monitoring. DHS policies include a subrecipient risk assessment template to assist grant administrators in completing the risk assessment and determining the risk level of the subrecipient.
DHS policies also require grant administrators to monitor subrecipients based on the risk assessments. DHS policies indicate that monitoring may include providing subrecipient training and technical assistance; performing desk reviews of the subrecipient’s records; and performing on-site reviews of the subrecipient’s records and operations. Finally, DHS policies in the Division of Public Health Bureau of Operations Contract Management Manual suggest that when GEARS is used to process reimbursement requests, grant administrators should use enhanced expenditure reporting from subrecipients to ensure expenditures are allowable. These policies note that additional verification may be performed by reviewing subrecipient financial records through a desk review or an on-site visit.
Condition:
In response to our prior year recommendation, DHS developed an internal control checklist for subrecipient monitoring, established a central location for filing monitoring documentation, and provided training to remind staff of their responsibilities related to subrecipient monitoring. However, the internal control checklist was implemented through a DHS, Division of Health, Bureau of Operations policy in July 2024, and we continued to identify concerns with subrecipient monitoring during FY 2023-24. We found that DHS did not provide documentation that it completed subrecipient risk assessments for three local public health agencies and seven tribal public health agencies that were subrecipients under the Public Health Emergency Response grant and had a contract modification in FY 2023-24. Further, DHS staff indicated that subrecipient risk assessments were not completed for seven of the nine tribal public health agencies when they were first subgranted funding in FY 2021-22.
In addition, DHS did not define the level of monitoring to be performed based on the completed risk assessments. For example, there was no documentation to indicate the level of monitoring required for low-, moderate-, and high-risk subrecipients, such as when it would be required to review subrecipient invoices through a desk review or an on-site visit. Further, DHS did not develop procedures for assessing and documenting desk reviews of subrecipient invoices, for assessing and documenting the reliance that can be placed on review of subrecipient single audit reports, and for documenting management oversight of the monitoring plan. Finally, DHS did not address the prior year recommendation regarding incomplete information and the identification of potential unallowable costs on the FY 2022-23 tracking spreadsheets.
Context:
DHS expended $14.7 million under the Public Health Emergency Response grant during FY 2023-24, including $8.3 million that was provided to subrecipients. Of the $8.3 million provided to subrecipients, $3.5 million was processed through GEARS. We interviewed DHS staff to gain an understanding of DHS policies and procedures for processing reimbursement requests from subrecipients, including its use of GEARS; DHS policies and procedures for monitoring subrecipients; and the steps taken to address our prior year recommendations. For the COVID Public Health Workforce award, DHS contracted with 79 local and tribal public health agencies and 12 CESAs to administer the award. For the Monkey Pox Crisis Response award, DHS contracted with three subrecipients to administer the award.
Questioned Costs:
None.
Effect:
Because its subrecipient monitoring procedures are insufficient, DHS is at increased risk of noncompliance with federal regulations for the Public Health Emergency Response grant. There is also an increased risk of improper payments for the Public Health Emergency Response grant.
Cause:
Although DHS implemented some new subrecipient monitoring procedures and provided training to staff on subrecipient monitoring activities, it continued to have deficiencies in its procedures and monitoring of subrecipients for the Public Health Emergency Response grant during FY 2023-24. DHS indicated it continued to review and update its procedures in FY 2024-25.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-complete its review of the FY 2022-23 subrecipient tracking spreadsheets and complete the assessment of the progress and fiscal reports and consideration of unallowable costs, document the conclusion, and return funding to the federal government if costs were determined to be unallowable;
-complete risk assessments for the three local and seven tribal public health agencies receiving funding under the Public Health Emergency Response grant during FY 2023-24 and adjust subrecipient monitoring appropriately;
-continue to develop a written monitoring plan for the Public Health Emergency Response grant that includes a description of the subrecipient monitoring expected for low-, moderate-, and high-risk subrecipients; procedures for completing and documenting desk reviews of subrecipient invoices; and procedures for assessing and documenting the reliance that can be placed on review of subrecipient single audit reports;
-provide training on the monitoring plan to staff with responsibilities for subrecipient monitoring activities; and
-develop and implement management oversight procedures to ensure monitoring is being completed and documented.
Finding 2024-307: Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response—Subrecipient Monitoring
Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response (Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922227-01 2023
Questioned Costs: None
COVID-19—Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response
(Assistance Listing number 93.354)
Award Numbers Award Years
6 NU90TP922078-01 2020
6 NU90TP922132-01 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Background:
DHHS provides funding to DHS for SABG, the ELC grant, the Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response, which DHS refers to as the Public Health Emergency Response grant, and the Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises program, which DHS refers to as the Health Disparities grant. These grants have various health-related purposes. To fulfill the purpose of each grant, DHS subawards funds to various entities, including counties, tribal governments, and other nonprofit organizations. In addition, under the SABG grant, amounts are provided by DHS to DCF and the University of Wisconsin-Madison (UW-Madison), which further subgrant to various entities.
Under FFATA, a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
In our FY 2022-23 audit (report 24-3), we identified that DHS had not accurately reported information in FSRS for several grants. We recommended DHS improve its procedures to accurately report required award information in a timely manner, including the date the subaward agreement was signed, and develop procedures to identify and report subawards made by state agencies to which it had transferred federal funding (Finding 2023-304).
Criteria:
Under 2 CFR s. 170, and as the prime grant awardee for these grants, DHS has overall responsibility for FFATA reporting and is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2023, it must be reported no later than January 31, 2024. The information required to be reported in FSRS includes several key data elements such as information about the recipient, the amount of the award, the project description, and the date the subaward agreement was signed.
Condition:
We selected a total of 34 subawards made by DHS under these grants during FY 2023-24 for testing, and we identified that 28 of the 34 subawards were not reported in a timely manner. We found that 14 of the 20 SABG subawards were not reported in a timely manner. For example, under the SABG grant, ten subawards were reported in August 2024, which was between seven to ten months after the date of the subaward.
In addition, we identified the obligation date was not accurate to within 10 days of the date the subaward agreement was signed for two subawards made under the SABG grant. We also found that none of the ELC, Public Health Emergency Response, and Health Disparities subawards we tested were reported in a timely manner. In addition, we found the project description was not completed accurately for ten subawards, including three for SABG subawards, two for ELC subawards, two for Public Health Emergency Response subawards, and three for Health Disparities subawards. Finally, we found that DHS did not report in FSRS any of the seven subawards DCF made under the SABG grant. DHS also did not report in FSRS the one subaward UW-Madison made under the SABG grant.
Context:
During FY 2023-24, DHS expended:
-$35.1 million under the SABG grant, of which $31.1 million was provided to subrecipients;
-$46.9 million under the ELC grant, of which $9.1 million was provided to subrecipients;
-$14.7 million under the Public Health Emergency Response grant, of which $8.3 million was provided to subrecipients; and
-$7.9 million under the Health Disparities grant, of which $2.6 million was provided to subrecipients.
Under the SABG grant, DCF expended $2.9 million, that was provided to subrecipients. Under the SABG grant, UW-Madison expended $0.2 million that was provided to subrecipients.
We reviewed 20 subawards for the SABG grant, two subawards for the ELC grant, nine for the Public Health Emergency Response grant, and three subawards for the Health Disparities grant that were made by DHS during FY 2023-24. We interviewed DHS staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. To assess if the subawards were reported in an accurate and timely manner, we requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed. We further followed up on the status of our prior audit recommendations.
Questioned Costs:
None.
Effect:
DHS did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS. The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov.
Cause:
In report 24-3, we noted that there were issues with the queries used to obtain information for reporting and procedures did not include obtaining information related to subawards made by other state agencies. During FY 2023-24, queries to retrieve information were established in a new system. However, the procedures in place to review the data produced by the queries and to determine what to report in FSRS were insufficient to ensure accurate and timely reporting. In response to our prior audit finding, DHS reported that it updated its FFATA reporting procedures. However, since the updates were not implemented until late in FY 2023-24, issues continued to be identified in our current audit.
Recommendation:
We recommend the Wisconsin Department of Health Services continue its efforts to implement updated procedures and make future revisions to these procedures for Federal Funding Accountability and Transparency Act reporting to ensure reporting is accurate, complete, and submitted in a timely manner.
Finding 2024-309: Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
COVID-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response (Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response
(Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises
(Assistance Listing number 93.391)
Award Numbers Award Years
1 NH75OT000039-01-00 2021
6 NH75OT000039-01-03 2023
6 NH75OT000039-01-05 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
COVID-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Year
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises—Subrecipient Monitoring
Background:
The CDC provides funding to DHS under the Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises grant, which DHS refers to as the Health Disparities grant. The grant is intended to address health disparities for high-risk and underserved populations to address COVID-19 related health disparities and advance health equity.
To administer the award under the Health Disparities grant, DHS contracted with a variety of subrecipients, including local and tribal public health agencies and nonprofit entities. DHS uses GEARS to process the reimbursement requests for the majority of its subrecipients. During our FY 2022-23 audit (report 24-3), we identified concerns with subrecipient monitoring for the Health Disparities grant and recommended DHS develop a monitoring plan, develop a central location to maintain monitoring documentation, and provide sufficient training to staff administering the Health Disparities grant (Finding 2023-305). DHS agreed with our recommendation and noted specific steps in its corrective action plan to address the concerns.
Criteria:
DHS administers federal programs that are subject to Uniform Guidance, which includes the following requirements related to the monitoring of subrecipients:
-2 CFR s. 200.332 (b) requires DHS to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring; and
-2 CFR s. 200.332 (d) through (f) requires DHS to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
DHS established policies requiring grant administrators to conduct a risk assessment for every subaward of federal funds and to use the risk assessment to determine the frequency and extent of monitoring. DHS policies include a subrecipient risk assessment template to assist grant administrators in completing the risk assessment and determining the risk level of the subrecipient.
DHS policies also require grant administrators to monitor subrecipients based on the risk assessments. DHS policies indicate that monitoring may include providing subrecipient training and technical assistance; performing desk reviews of the subrecipient’s records; and performing on-site reviews of the subrecipient’s records and operations. Finally, DHS policies in the Division of Public Health Bureau of Operations Contract Management Manual suggest that when GEARS is used to process reimbursement requests, grant administrators should use enhanced expenditure reporting from subrecipients to ensure expenditures are allowable. These policies note that additional verification may be performed by reviewing subrecipient financial records through a desk review or an on-site visit.
Condition:
In response to our prior year recommendation, DHS developed an internal control checklist for subrecipient monitoring, established a central location for filing monitoring documentation, and provided training to remind staff of their responsibilities related to subrecipient monitoring. However, the internal control checklist was implemented through a DHS, Division of Public Health, Bureau of Operations policy in July 2024, and we continued to identify concerns with subrecipient monitoring during FY 2023-24. We found that DHS did not define the level of monitoring to be performed based on the completed risk assessments. For example, there was no documentation to indicate the level of monitoring required for low-, moderate-, and high-risk subrecipients, such as when it would be required to review subrecipient invoices through a desk review or an on-site visit. Further, DHS did not develop procedures for assessing and documenting desk reviews of subrecipient invoices, for assessing and documenting the reliance that can be placed on review of subrecipient single audit reports, and for documenting management oversight of the monitoring plan.
Context:
DHS expended $7.9 million under the Health Disparities grant during FY 2023-24, including $2.6 million that was provided to subrecipients. Of the $2.6 million provided to subrecipients, $2.4 million was processed through GEARS. DHS contracted with 87 subrecipients to administer the grant. We interviewed DHS staff to gain an understanding of DHS policies and procedures for processing reimbursement requests from subrecipients, including its use of GEARS; DHS policies and procedures for monitoring subrecipients; and the steps taken to address our prior year recommendations.
Questioned Costs:
None.
Effect:
Because its subrecipient monitoring procedures are insufficient, DHS is at increased risk of noncompliance with federal regulations for the Health Disparities grant. There is also an increased risk of improper payments for the Health Disparities grant.
Cause:
Although DHS implemented some new subrecipient monitoring procedures and provided training to staff on subrecipient monitoring activities, it continued to have deficiencies in its procedures and monitoring of subrecipients for the Health Disparities grant during FY 2023-24. DHS indicated it continued to review and update its procedures in FY 2024-25.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-continue to develop a written monitoring plan for the Health Disparities grant that includes a description of the subrecipient monitoring expected for low-, moderate-, and high-risk subrecipients; procedures for completing and documenting desk reviews of subrecipient invoices; and procedures for assessing and documenting the reliance that can be placed on review of subrecipient single audit reports;
-provide training on the monitoring plan to staff with responsibilities for subrecipient monitoring activities; and
-develop and implement management oversight procedures to ensure monitoring is being completed and documented.
Finding 2024-306: Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises—Subrecipient Monitoring
COVID-19—Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises
(Assistance Listing number 93.391)
Award Numbers Award Years
1 NH75OT000039-01-00 2021
6 NH75OT000039-01-03 2023
6 NH75OT000039-01-05 2024
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Background:
DHHS provides funding to DHS for SABG, the ELC grant, the Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response, which DHS refers to as the Public Health Emergency Response grant, and the Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises program, which DHS refers to as the Health Disparities grant. These grants have various health-related purposes. To fulfill the purpose of each grant, DHS subawards funds to various entities, including counties, tribal governments, and other nonprofit organizations. In addition, under the SABG grant, amounts are provided by DHS to DCF and the University of Wisconsin-Madison (UW-Madison), which further subgrant to various entities.
Under FFATA, a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
In our FY 2022-23 audit (report 24-3), we identified that DHS had not accurately reported information in FSRS for several grants. We recommended DHS improve its procedures to accurately report required award information in a timely manner, including the date the subaward agreement was signed, and develop procedures to identify and report subawards made by state agencies to which it had transferred federal funding (Finding 2023-304).
Criteria:
Under 2 CFR s. 170, and as the prime grant awardee for these grants, DHS has overall responsibility for FFATA reporting and is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2023, it must be reported no later than January 31, 2024. The information required to be reported in FSRS includes several key data elements such as information about the recipient, the amount of the award, the project description, and the date the subaward agreement was signed.
Condition:
We selected a total of 34 subawards made by DHS under these grants during FY 2023-24 for testing, and we identified that 28 of the 34 subawards were not reported in a timely manner. We found that 14 of the 20 SABG subawards were not reported in a timely manner. For example, under the SABG grant, ten subawards were reported in August 2024, which was between seven to ten months after the date of the subaward.
In addition, we identified the obligation date was not accurate to within 10 days of the date the subaward agreement was signed for two subawards made under the SABG grant. We also found that none of the ELC, Public Health Emergency Response, and Health Disparities subawards we tested were reported in a timely manner. In addition, we found the project description was not completed accurately for ten subawards, including three for SABG subawards, two for ELC subawards, two for Public Health Emergency Response subawards, and three for Health Disparities subawards. Finally, we found that DHS did not report in FSRS any of the seven subawards DCF made under the SABG grant. DHS also did not report in FSRS the one subaward UW-Madison made under the SABG grant.
Context:
During FY 2023-24, DHS expended:
-$35.1 million under the SABG grant, of which $31.1 million was provided to subrecipients;
-$46.9 million under the ELC grant, of which $9.1 million was provided to subrecipients;
-$14.7 million under the Public Health Emergency Response grant, of which $8.3 million was provided to subrecipients; and
-$7.9 million under the Health Disparities grant, of which $2.6 million was provided to subrecipients.
Under the SABG grant, DCF expended $2.9 million, that was provided to subrecipients. Under the SABG grant, UW-Madison expended $0.2 million that was provided to subrecipients.
We reviewed 20 subawards for the SABG grant, two subawards for the ELC grant, nine for the Public Health Emergency Response grant, and three subawards for the Health Disparities grant that were made by DHS during FY 2023-24. We interviewed DHS staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. To assess if the subawards were reported in an accurate and timely manner, we requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed. We further followed up on the status of our prior audit recommendations.
Questioned Costs:
None.
Effect:
DHS did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS. The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov.
Cause:
In report 24-3, we noted that there were issues with the queries used to obtain information for reporting and procedures did not include obtaining information related to subawards made by other state agencies. During FY 2023-24, queries to retrieve information were established in a new system. However, the procedures in place to review the data produced by the queries and to determine what to report in FSRS were insufficient to ensure accurate and timely reporting. In response to our prior audit finding, DHS reported that it updated its FFATA reporting procedures. However, since the updates were not implemented until late in FY 2023-24, issues continued to be identified in our current audit.
Recommendation:
We recommend the Wisconsin Department of Health Services continue its efforts to implement updated procedures and make future revisions to these procedures for Federal Funding Accountability and Transparency Act reporting to ensure reporting is accurate, complete, and submitted in a timely manner.
Finding 2024-309: Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
COVID-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response (Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response
(Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises
(Assistance Listing number 93.391)
Award Numbers Award Years
1 NH75OT000039-01-00 2021
6 NH75OT000039-01-03 2023
6 NH75OT000039-01-05 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
COVID-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Year
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Waivers for State Innovation for Section 1332 of the Patient Protection and Affordable Care Act—Financial Reporting
Background:
Section 1332 of the federal Patient Protection and Affordable Care Act of 2010 (Affordable Care Act) permits a state to apply for a waiver to pursue innovative strategies for providing residents with access to high quality, affordable health insurance while retaining the basic protections of the Affordable Care Act. 2017 Wisconsin Act 138 created the Wisconsin Healthcare Stability Plan (WIHSP), under which the State covers a portion of the financial risk of health insurers. Act 138 required OCI to implement WIHSP if Wisconsin’s waiver plan was approved by the federal government. OCI applied for a waiver, which was approved by the U.S. Department of Health and Human Services (DHHS) in July 2018. Under the approved waiver, a health insurance carrier in the healthcare insurance exchange may be reimbursed a portion of the claims it incurred in the prior calendar year.
In 2019, DHHS awarded OCI funding under the 1332 State Innovation Waivers program to administer WIHSP for the period January 1, 2019, through December 31, 2023. OCI received an extension of the federal funding in 2022, covering the period January 1, 2024, through December 31, 2028. From the inception of the program and through June 30, 2024, OCI expended $680.8 million under the 1332 State Innovation Waivers program. The federal funding is used, along with state appropriations, to reimburse insurance carriers participating in the healthcare insurance exchange for a portion of enrollee claims. Insurance carriers submit various attestations and enrollee claim information to OCI.
Criteria:
2 CFR s. 200.303 requires OCI to establish and maintain effective internal control over its federal programs and to provide reasonable assurance that the federal programs are administered in compliance with federal statutes, regulations, and the terms and conditions of its federal awards. Under the terms and conditions for the 1332 State Innovation Waivers grant award, OCI is required to report expenditures annually using the Standard Form 425 (SF-425) Federal Financial Report.
Condition:
We found OCI did not complete all required lines of the SF-425 Federal Financial Report filed for the year ended December 31, 2023. OCI reported zero expenditures in line 10e (federal share of expenditures) when OCI should have reported $680,759,297 in line 10e. As a result, line 10h, which is a calculated field, incorrectly indicated that OCI had an unobligated balance of federal funds of $894,224,285, when the unobligated balance should have been reported as $213,464,988.
Context:
OCI expended $208.3 million in federal funds under the 1332 State Innovations Waivers program in FY 2023-24. We reviewed OCI’s written procedures for federal reporting and interviewed the WIHSP Administrator and OCI finance staff to gain an understanding of the reporting procedures. We tested the SF-425 Federal Financial Report submitted by OCI for calendar year 2023 and compared the amounts reported to the accounting records.
Questioned Costs:
None.
Effect:
OCI reported inaccurate information in its federal financial report filed in FY 2023-24, which resulted in inaccurate information being provided to the federal awarding agency.
Cause:
OCI staff indicated they believed the prepopulated fields were not editable and that they only signed and certified the report. We also note OCI did not have procedures in place to require a secondary review and sign off on the report prior to submission.
Recommendation:
We recommend the Wisconsin Office of the Commissioner of Insurance:
-develop written procedures to require a secondary review of the annual Standard Form 425 Federal Financial Report that include steps for conducting and documenting the secondary review; and
-work with the U.S. Department of Health and Human Services to determine whether the Standard Form 425 Federal Financial Report for calendar year 2023 needs to be corrected and refiled.
Finding 2024-900: Waivers for State Innovation for Section 1332 of the Patient Protection and Affordable Care Act—Financial Reporting
Waivers for State Innovation for Section 1332 of the Patient Protection and Affordable Care Act (PPACA) (Assistance Listing number 93.423)
Award Numbers Award Years
SIWIW190008-03 2021
SIWIW190008-04 2022
SIWIW190008-05 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Office of the Commissioner of Insurance: The Wisconsin Office of the Commissioner of Insurance agrees with the audit finding and recommendations.
Waivers for State Innovation for Section 1332 of the Patient Protection and Affordable Care Act—Verification Audits
Background:
Section 1332 of the Affordable Care Act permits a state to apply for a waiver to pursue innovative strategies for providing residents with access to high quality, affordable health insurance while retaining the basic protections of the Affordable Care Act. 2017 Wisconsin Act 138 created WIHSP, under which the State covers a portion of the financial risk of health insurance carriers. Act 138 required OCI to implement WIHSP
if Wisconsin’s waiver plan was approved by the federal government. OCI applied for a waiver, which was approved by DHHS in July 2018. Under the approved waiver, a health insurance carrier in the healthcare insurance exchange may be reimbursed a portion of the claims it incurred in the prior calendar year.
In 2019, DHHS awarded OCI funding under the 1332 State Innovation Waivers program to administer WIHSP for the period January 1, 2019, through December 31, 2023. OCI received an extension of the federal funding in 2022, covering the period January 1, 2024, through December 31, 2028. From the inception of the program and through June 30, 2024, OCI expended $680.8 million under the 1332 State Innovation Waivers program. The federal funding is used, along with state appropriations, to reimburse insurance carriers participating in the healthcare insurance exchange for a portion of enrollee claims. Insurance carriers submit various attestations and enrollee claim information to OCI.
Criteria:
2 CFR s. 200.303 requires OCI to establish and maintain effective internal control over its federal programs and to provide reasonable assurance that the federal programs are administered in compliance with federal statutes, regulations, and the terms and conditions of its federal awards.
OCI is also responsible for ensuring costs charged to federal grant programs it administers are allowable under federal statutes, federal regulations, and the terms and conditions of the federal award. To ensure the attestations were completed, and to assess the validity of the enrollee claims submitted by the insurance carriers, the WIHSP Administrator and finance staff at OCI conducted a verification audit. OCI’s written procedures for conducting the verification audit required OCI to:
-test a random sample of at least 60 enrollees across all the participating insurance carriers for the phase I audit, including ensuring claims for these enrollees were incurred in the benefit year and paid prior to the established deadline of April 30 of the calendar year following the applicable benefit year;
-randomly sample and review proof of payment for two claims for each enrollee sampled during the phase I audit; and
-have a secondary reviewer review a portion of the audit documents and initial review results for the phase I and II audits.
Condition:
We identified two concerns with OCI’s administration of the verification audits it performed related to its 1332 State Innovation Waivers program. First, in the phase I audit conducted for benefit year 2022, OCI did not detect that one insurance carrier reported in the audit response spreadsheet that it had paid two claims for two enrollees after April 30, which was the established deadline for claims. This was not detected by OCI during either the initial or secondary review of the claims information in the audit response spreadsheet. After we identified this issue, OCI followed up with the insurance carrier and determined that the payment dates for these claims had been inaccurately reported and obtained documentation from the insurance carrier to support that the claims had been paid prior to the April 30 deadline.
Second, for the phase II audit conducted for benefit year 2022, the proof of payment for 9 of the 130 claims tested included the claim date but did not include documentation of the payment date. After we identified this issue, OCI followed up with the insurance carriers and obtained documentation to support that the claims were paid prior to the April 30 deadline.
Context:
OCI expended $208.3 million in federal funds under the 1332 State Innovations Waiver program in FY 2023-24. We reviewed OCI’s written procedures and interviewed the WIHSP Administrator and OCI finance staff to gain an understanding of the phase I and phase II verification audits. We reviewed the documentation related to the verification audits completed for benefit year 2022, which supported payments made to insurance carriers in FY 2023-24. For all 65 enrollees that OCI sampled for phase I of the verification audits, we tested whether documentation matched between the claims report and the amounts included in the insurance carriers audit response spreadsheet. For the 65 enrollees in phase II of the verification audit, we also tested the claims documentation provided by the insurance carriers. During our FY 2020-21 single
audit (report 22-5), we identified concerns with OCI’s audit process and made recommendations to OCI.
Questioned Costs:
None.
Effect:
OCI may not have identified claims that did not meet eligibility requirements or lacked appropriate supporting documentation, which could result in unallowable costs.
Cause:
OCI staff did not correctly follow the verification audit written procedures, which require the initial and secondary reviewer to verify that sampled claims were paid prior to the established deadline. Further, OCI’s audit response spreadsheet does not restrict insurance carriers from entering claims incurred or paid outside of the allowable periods.
OCI staff relied on the claim date in completing the phase II audit and did not request the payment date information from the insurance carriers. Further, the instructions OCI provided insurers for submitting proof of payment for the phase II audit did not explicitly direct insurance carriers to include the payment date on the documentation submitted to support the claims.
Recommendation:
We recommend the Wisconsin Office of the Commissioner of Insurance:
-review and update the audit response spreadsheet to restrict insurance carriers from entering claims service and payment dates outside of the allowable periods;
-update instructions and guidance provided to insurance carriers to clearly indicate that claims documentation submitted to the Office of the Commissioner of Insurance should include the claim payment date; and
-follow its written procedures for conducting verification audits, including reviewing to ensure the claims documentation supports that claims have been paid before the established deadline.
Finding 2024-901: Waivers for State Innovation for Section 1332 of the Patient Protection and Affordable Care Act—Verification Audits
Waivers for State Innovation for Section 1332 of the Patient Protection and Affordable Care Act (PPACA) (Assistance Listing number 93.423)
Award Numbers Award Years
SIWIW190008-03 2021
SIWIW190008-04 2022
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Office of the Commissioner of Insurance: The Wisconsin Office of the Commissioner of Insurance agrees with the audit finding and recommendations.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to Federal Funding Accountability and Transparency Act (FFATA) reporting for certain grant programs administered by the State. During FY 2023-24, DOA’s Division of Executive Budget and Finance was responsible for uploading required FFATA information into the FFATA Subaward Reporting System (FSRS) based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DOA also provided guidance and technical assistance to agencies on FFATA reporting requirements.
During our FY 2022-23 single audit (report 24-3), we identified concerns that DOA’s method of reporting modifications to subawards in FSRS resulted in an overstatement of the subaward information in FSRS and on USAspending.gov. In report 24-3, we recommended that DOA alter its approach and report only the amount of subaward modifications, update guidance to agencies, and provide training to state agencies on appropriate reporting (Finding 2023-106). We also recommended that DOA maintain its current approach of reporting cumulative amounts with subaward modifications only if it received specific guidance from the Office of Management and Budget (OMB) that its current reporting was appropriate. DOA agreed with our recommendations. Further, in January 2025 the U.S. Department of Health and Human Services sustained the audit finding and recommended that DOA revise and resubmit any reports that contained inaccurate data.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance on FSRS.gov indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Further, guidance posted on the U.S. General Services Administration (GSA) website in spring 2024 provided clarification that when a subaward is modified, the preparer should update the original entry in FSRS. The guidance also indicated that if information for a subaward changes, the preparer is to update the original report in FSRS.
Condition:
In response to our prior year recommendation, DOA contacted OMB for clarification on the FFATA reporting requirements. OMB’s response indicated that DOA should “use the total amount after adjusted,” in reporting subaward modifications in FSRS. DOA interpreted this guidance to mean it would continue its established process for reporting subaward modifications by reporting the cumulative amount of the subaward, not just the modification, in FSRS. Therefore, DOA did not alter its reporting of subaward modifications in FSRS for FY 2023-24. For example, in reviewing subaward information on USAspending.gov for a subaward related to the Temporary Assistance for Needy Families grant (Assistance Listing number 93.558), we found that the total subaward was overstated on USAspending.gov because DOA reported cumulative amounts for each modification.
Context:
DOA staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including the departments of Children and Families and Natural Resources. We discussed DOA’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov, and the updated guidance on the GSA website. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2023-24 for which FFATA reporting was subject to audit and for which DOA was responsible for FFATA reporting. We also followed up on the status of the prior year audit finding and the steps DOA took to address the finding.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USAspending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
In our prior audit, DOA indicated that it relied on guidance from an OMB official who indicated that cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. In our current audit, DOA relied on its March 2024 inquiries of OMB subsequent to our recommendations in March 2024, which DOA interpreted as a requirement to continue its current procedures.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report subaward modifications as an adjustment to the original subaward record in the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission in FSRS; and
-provide training to state agencies to ensure consistent reporting across state agencies.
Finding 2024-101: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02393 2018
00E02349 2018
00E02456 2019
00E02824 2020
00E03252 2022
00E03490 2023
Questioned Costs: None
Temporary Assistance for Needy Families (Assistance Listing number 93.558)
Award Number Award Year
2301WITANF 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Temporary Assistance for Needy Families—Work Verification Plan
Background:
DCF receives funding from the U.S. Department of Health and Human Services (DHHS) under the TANF grant, which is used to administer Wisconsin’s W-2 program.
Criteria:
Under 45 CFR s. 261.20, a state administering TANF must meet certain work participation rates and submit work participation data to DHHS that allows DHHS to measure the state’s success in requiring work-eligible individuals to participate in the 12 countable work activities specified in 45 CFR s. 261.30. Under 45 CFR s. 261.62, a state is required to implement procedures to ensure the accuracy of the data submitted to DHHS, including by developing a work verification plan for approval by DHHS. The work verification plan is required to include a description of the documentation used to monitor work participation and to ensure that the actual hours of participation are reported, and a description of the internal controls implemented by the state to ensure consistent measurement of work participation rates, including quality assurance and monitoring processes. If a state modifies its approved work verification procedures or internal controls, 45 CFR s. 261.63 requires the state to submit an amended work verification plan for approval.
Condition:
During our FY 2023-24 audit, we found that DCF did not complete the monitoring of local agencies that administer the W-2 program as described in its work verification plan, which was approved by DHHS in 2008. For example, the approved work verification plan indicated that on a monthly basis DCF staff would conduct case file reviews of 125 randomly selected W-2 cases. As described in the approved work verification plan, these case file reviews should include ensuring that the work activity recorded in DCF’s case management system is supported by documentation that is required to be maintained by the local agencies. Although DCF staff continued to perform case file reviews as part of quarterly monitoring of local agencies that administer the W-2 program, DCF staff indicated that these reviews no longer included reviewing attendance tracking documentation for all types of work activities. For two of the five participants for which we reviewed work participation data, we found that the work activity reported in DCF’s case management system was not supported by documentation maintained by the local agencies.
In addition, we found that DCF did not submit an amended work verification plan to DHHS for approval.
Context:
For FY 2023-24, DCF reported TANF expenditures of $203.6 million. We reviewed DCF’s work verification plan and interviewed DCF staff to gain an understanding of DCF’s procedures for complying with its work verification plan. We obtained and reviewed attendance tracking documentation for five participants for which work participation data was submitted to DHHS during FY 2023-24.
Questioned Costs:
None.
Effect:
DCF is not in compliance with the work verification plan approved by DHHS. Under 45 CFR s. 262.1 (a) (15), DHHS may penalize a state by an amount not less than 1.0 percent and not more than 5.0 percent of the basic TANF block grant allocated to the state for failure to establish or comply with work participation verification procedures.
Cause:
DCF staff indicated that they stopped performing case file reviews as described in the approved work verification plan in 2022 because they determined less monitoring was needed based on prior monitoring results and because of a reduction in the work participation rates that DCF was required to meet. In addition, DCF staff indicated that they were unaware that changes to work verification procedures and related internal controls required an amended work verification plan be submitted to DHHS for approval.
Recommendation:
We recommend the Wisconsin Department of Children and Families:
-review its approved work verification plan and determine if amendments are needed;
-submit the amended work verification plan to the U.S. Department of Health and Human services for approval; and
-complete and document monitoring of work participation information in accordance with the approved work verification plan.
Finding 2024-200: Temporary Assistance for Needy Families—Work Verification Plan
Temporary Assistance for Needy Families (Assistance Listing number 93.558)
Award Numbers Award Years
2101WITANF 2021
2201WITANF 2022
2301WITANF 2023
2401WITANF 2024
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Children and Families: The Wisconsin Department of Children and Families agrees with the audit finding and recommendations.
Temporary Assistance for Needy Families—Federal Funding Accountability and Transparency Act Reporting
Background:
DHHS provides funding to DCF under the TANF grant, which is used to administer Wisconsin’s W-2 program. DCF subawards TANF funds to various entities, including counties, tribes, and other organizations.
Under the Federal Funding Accountability and Transparency Act (FFATA), a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
As part of our FY 2022-23 audit (report 24-3), we identified that DCF did not report in a timely manner its subaward information in the FFATA Subaward Reporting System (FSRS) for two grants. We recommended DCF review the query used to determine subawards and review and make adjustments to its procedures to ensure all original subaward agreements and amendments are input and updated in a timely manner. (Finding 2023-202).
Criteria:
Under 2 CFR s. 170, DCF is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2023, it must be reported no later than January 31, 2024. Several key data elements are required to be reported in FSRS, including information about the recipient, the amount of the award, the project description, and the date the subaward agreement was signed.
Condition:
We found that 18 of 33 TANF subawards, including new subawards and amendments to existing subawards, made by DCF during FY 2023-24 were not reported in a timely manner. Of these 18 subawards, four were not reported at all. In addition, we identified four subawards for which the amount of the award was not reported accurately.
Context:
During FY 2023-24, DCF expended $203.6 million under the TANF grant, of which $34.8 million was provided to subrecipients. We reviewed 33 new and amended subawards for the TANF grant that were made by DCF during FY 2023-24. We interviewed DCF staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. To assess if the subaward was reported in an accurate and timely manner, we requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed. We further followed up on the status of our prior audit recommendation.
Questioned Costs:
None.
Effect:
DCF did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS. The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov for the TANF grant.
Cause:
In report 24-3, we noted that there were issues with the queries used to obtain information for reporting and that DCF staff did not consistently input the subawards into the subaward tracking system within the same month the subaward was signed. During FY 2023-24, DCF implemented procedures to address our prior audit concerns. However, since the updates were not implemented until late in FY 2023-24, issues continued to be identified during our current audit.
Recommendation:
We recommend the Wisconsin Department of Children and Families continue its efforts to implement updated procedures and consider whether further updates are needed for Federal Funding Accountability and Transparency Act reporting to ensure this reporting is accurate, complete, and submitted in a timely manner.
Finding 2024-201: Temporary Assistance for Needy Families—Federal Funding Accountability and Transparency Act Reporting
Temporary Assistance for Needy Families (Assistance Listing number 93.558)
Award Numbers Award Years
2201WITANF 2022
2301WITANF 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Children and Families: The Wisconsin Department of Children and Families agrees with the audit finding and recommendation.
Social Services Block Grant—Subrecipient Contracts
Background:
DHHS provides funding to DHS for SSBG. This program provides flexible financial assistance to states that allows them to tailor social services programs to the needs of their populations. In addition, a state may transfer funds received under the Temporary Assistance for Needy Families (TANF) program (Assistance Listing number 93.558) to the SSBG program for use under this program. During FY 2023-24, $14.7 million was transferred from the TANF program to the SSBG program. DHS uses the SSBG funding, including the amounts transferred from the TANF program and general purpose revenue, to provide funding for the community aids program, and more specifically, amounts designated within this program as the “basic county allocation” that can be used by counties to support any eligible service.
DHS contracts with each county for the administration of the community aids program. Because DHS provides funding to counties to carry out the purpose of a federal program, DHS is considered a pass-through entity, and the counties are considered subrecipients. DHS uses its Grant Enrollment, Application and Reporting System (GEARS) and establishes GEARS profiles to designate the program, the purpose of the program, the types of costs that will be reimbursed, and the federal programs that are used in funding the amount of the contract. The information provided to the counties for a GEARS profile will include the federal assistance listing number, as appropriate, and other required information. The counties use the GEARS profile established for the basic county allocation when determining the costs that can be funded and in requesting reimbursement for costs incurred.
As part of our FY 2022-23 audit (report 24-3), we reported that DHS identified both the SSBG and TANF programs as providing funding for the basic county allocation. Because the TANF funds transferred to SSBG are subject to the SSBG requirements, the information DHS provided to the counties inaccurately identified the TANF program as a funding source for the basic county allocation. We recommended DHS update its procedures for contract development to ensure the information provided in its subrecipient contracts identified SSBG as the federal funding source for the basic county allocation of the community aids program related to the transferred TANF funds (Finding 2023-301).
Criteria:
Under 2 CFR s. 200.332, the pass-through entity is required to clearly identify to the subrecipient certain information that allows the subrecipient to understand the federal requirements related to the funding provided. This information includes providing the federal assistance listing number and the amount being provided under the assistance listing number. Under 42 USC s. 604, the transfer of funds from the TANF program to the SSBG program is allowed. Once transferred, the funding is no longer considered TANF funding and is subject to the SSBG requirements. The expenditures incurred with the transferred TANF funds would be considered an expenditure of SSBG.
Condition:
For calendar year 2024 contracts with each county for the administration of the community aids program, DHS identified that both the SSBG and TANF programs were being used to provide funding for the basic county allocation. Although the TANF funds transferred to SSBG are subject to the SSBG requirements, the information DHS provided to the counties, which included the assistance listing number, inaccurately identified the TANF program as a funding source for the basic county allocation.
Because the contracts for calendar year 2024 were entered into prior to the communication of our finding for FY 2022-23 (Finding 2023-301), it was not unexpected to find contracts that continued to identify the incorrect assistance listing number.
Context:
During FY 2023-24, DHS expended $33.3 million in SSBG funds, which included transferred TANF funds, and subawarded $32.3 million. We reviewed 8 of the 72 county contracts that were executed during FY 2023-24 and discussed with DHS staff the steps taken in response to our finding for FY 2022-23 (Finding 2023-301).
Questioned Costs:
None.
Effect:
Because the contracts with the counties did not accurately identify the transferred TANF funds as those from the SSBG program, the counties were not aware of the full amount of SSBG funds received and, as a result, may not be aware of the federal requirements related to this funding. This could result in the counties not complying with federal requirements related to the SSBG funding.
Cause:
In contract development, DHS separately identified the SSBG and transferred TANF funds used in funding the basic county allocation. This separation resulted in the error in identifying TANF as a funding source in the contracts with the counties for the basic county allocation. DHS indicated it has implemented our recommendation from FY 2022-23 (Finding 2023-301) and has updated procedures for contract development to ensure information provided in its subrecipient contracts identify SSBG as the federal funding source for the basic county allocation of the community aids program related to the transferred TANF funds. However, DHS did not complete contract amendments for the calendar year 2024 contracts.
Recommendation:
We recommend the Wisconsin Department of Health Services implement its updated procedures for contract development to ensure information provided in its subrecipient contracts correctly identifies the Social Services Block Grant as the federal funding source for the basic county allocation of the community aids program related to the transferred Temporary Assistance for Needy Families funds.
Finding 2024-302: Social Services Block Grant—Subrecipient Contracts
Social Services Block Grant (Assistance Listing number 93.667)
Award Numbers Award Years
2401WISOSR 2024
2301WISOSR 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Social Services Block Grant—Federal Funding Accountability and Transparency Act Reporting
Background:
DHHS provides funding to DHS for SSBG. This program provides flexible financial assistance to states that allows states to tailor social services programs to the needs of their populations. In addition to general purpose revenue, DHS uses the SSBG funds for the basic county allocation of the community aids program, and it subawards amounts to each county for the administration of this program. DHS also transfers SSBG funds to the Wisconsin Department of Children and Families (DCF). DCF uses the SSBG funds, in addition to other federal funds and general purpose revenue, for the children and family aids program, and it subawards amounts to each county for the administration of this program.
Under the Federal Funding Accountability and Transparency Act (FFATA), a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
As part of our FY 2022-23 audit (report 24-3) we identified that no SSBG-funded subawards had been reported by DHS in the FFATA Subaward Reporting System (FSRS). We recommended that DHS revise its procedures to ensure that all subawards funded by federal grants were included in reports used to identify subawards for reporting, and develop procedures to identify and report subawards made by state agencies to which it had transferred federal funding (Finding 2023-302).
Criteria:
Under 2 CFR s. 170, and as the prime grant awardee for the SSBG program, DHS has overall responsibility for FFATA reporting and is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2023, it must be reported no later than January 31, 2024.
Condition:
During FY 2023-24, both DHS and DCF made subawards of $30,000 or more in SSBG funds to counties. DHS did not report any SSBG-funded subawards in FSRS.
Context:
During FY 2023-24, DHS expended $33.3 million in SSBG funds of which $32.3 million was provided to subrecipients. During FY 2023-24, DCF expended $9.5 million in SSBG funds, of which $7.3 million was provided to subrecipients. We interviewed DHS staff to gain an understanding of the SSBG program, the use of the funds, procedures for compiling and reviewing subaward information, and procedures for submitting this information in FSRS. We further followed up on the status of our prior audit recommendations.
Questioned Costs:
None.
Effect:
As DHS did not comply with FFATA requirements for the reporting of subawards in FSRS for the SSBG program, the State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov for the SSBG program.
Cause:
In report 24-3, we noted that for the subgrants provided under the basic county allocation of the community aids program, DHS initially recorded payments of the amounts it subawarded to counties to a general purpose revenue appropriation. As a result, these subawards were not identified in the reports DHS used to determine FFATA reporting. In addition, DHS did not have procedures in place to obtain information related to the subgrants provided by DCF or to determine whether responsibility for FFATA reporting could be delegated to DCF. In response to our prior audit findings, DHS indicated it updated its procedures related to FFATA reporting. However, reporting of SSBG subawards in FSRS made by both DHS and DCF was not completed in FY 2023-24.
Recommendation:
We recommend the Wisconsin Department of Health Services continue its effort to implement its updated procedures for Federal Funding Accountability and Transparency Act reporting to ensure all Social Services Block Grant subawards are identified and reported.
Finding 2024-303: Social Services Block Grant—Federal Funding Accountability and Transparency Act Reporting
Social Services Block Grant (Assistance Listing number 93.667)
Award Numbers Award Years
2401WISOSR 2024
2301WISOSR 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Rebuttal from the Wisconsin Legislative Audit Bureau: In its corrective action plan on page 349, the Department of Health Services noted that it had adjusted its prior year corrective action plan and successfully submitted all the FY 2023-24 Social Services Block Grant (SSBG) awards to the federal website in July 2024. To assist the reader in understanding the corrective action plan, we offer the following clarification: The July 2024 submission was not timely for amounts awarded under SSBG that were obligated through agreements signed in fall 2023.
Eligibility for the Children’s Health Insurance Program
Background:
The U.S. Department of Health and Human Services (DHHS) provides funding to DHS for CHIP. Funding under this program provides financial assistance to states in maintaining and expanding healthcare coverage to children residing in low-income families. CHIP is funded by both the state and federal government, with the federal portion determined by the enhanced Federal Medical Assistance Percentage (FMAP) rate. Under CHIP, Wisconsin has a separate CHIP program (SCHIP) that provides health insurance to uninsured low-income children as well as certain pregnant women through a postpartum period. Also under CHIP, Wisconsin has a Medicaid expansion program (MCHIP) that expands the State’s MA program and provides enhanced federal participation for targeted low-income children.
DHS partners with local agency caseworkers who are responsible for verifying that CHIP participants meet program eligibility requirements. Caseworkers perform eligibility determination functions, such as obtaining information from the parents or guardians of children applying for health care benefits that is then recorded into the Client Assistance for Reemployment and Economic Support (CARES) system. DHS relies on the CARES system to manage CHIP cases to ensure only eligible participants receive CHIP benefits. Information from the CARES system related to eligible participants is then used by the Medicaid Management Information System (MMIS) to process payments to providers and managed care organizations. During the public health emergency, the federal government required a continuous eligibility period for MA participants.
As part of our FY 2022-23 audit (report 24-3) we identified that DHS maintained continuous eligibility for SCHIP participants who were over age 19, which was not in compliance with federal requirements for this program. We recommended that DHS work with the federal government to resolve these improper payments, including the determination of the total amount of improper payments, and return these amounts to the federal government, as appropriate (Finding 2023-300).
Criteria:
Title XXI of the Social Security Act permits states to establish certain eligibility criteria for CHIP. Per 42 CFR s. 457.320, and following guidelines set forth in 42 USC s. 1397bb (b), DHS established age criteria that permits children under 19 years of age to participate in SCHIP. As a condition of receiving a temporary increase to federal participation under the Families First Coronavirus Response Act, states were required to maintain enrollment of nearly all eligible MA participants. Although this requirement applied to participants determined eligible for MCHIP, it did not apply to SCHIP participants. In guidance issued in January 2021, the Centers for Medicare and Medicaid Services (CMS) further specified that states should not continue to provide coverage under a SCHIP program to participants who did not meet age requirements. At the time a participant reaches age 19, the guidance specifies that states should transition the participant from SCHIP coverage to MA coverage, if eligible.
In response to the public health emergency, DHS also received approval from CMS on August 19, 2020, for an amendment to SCHIP that allowed the State to delay acting on certain changes, beginning March 1, 2020. However, the amendment further stated that changes in circumstances described in 42 CFR s. 457.342 (a) and cross-referenced to 42 CFR s. 935.926 (d) should continue to be acted on, including the circumstance of a child attaining the age of 19.
Condition:
During the public health emergency, and in conflict with federal requirements and the approved state plan, DHS maintained continuous eligibility for SCHIP participants who were over age 19.
The unwinding period, which began on April 1, 2023, is the period after the expiration of the continuous enrollment condition authorized by the Families First Coronavirus Response Act, and includes the process of resuming to normal operations, including restarting full MA and CHIP eligibility renewals and terminations of coverage for ineligible individuals. Throughout FY 2023-24, DHS implemented its unwinding plan and performed redeterminations of eligibility for MA and CHIP participants, including those that exceeded the age requirement for the SCHIP program. The unwinding period ended in June 2024 and DHS resumed normal operations.
Given the number of SCHIP participants identified in the prior audit as exceeding the age requirement, and because the unwinding process was ongoing throughout FY 2023-24, we anticipated that we would continue to identify SCHIP participants who were age 19 and older during FY 2023-24 and that continued to be eligible to receive benefits. During our audit, we identified 4,510 SCHIP participants in the CARES system who were age 19 prior to July 1, 2023. In reviewing ten participants, we note that redeterminations were performed in July or August 2023 for nine of these participants. In each case, eligibility for SCHIP ended. The remaining participant’s eligibility was removed in March 2024. Further, we identified 3,499 participants who turned age 19 between July 1, 2023, and May 31, 2024. We reviewed ten of these participants. For six of the ten reviewed, we found that a timely redetermination was completed and that eligibility was appropriately ended at the end of the month that the participant turned age 19. For the remaining four participants, a redetermination was not completed in a timely manner and eligibility was not removed until a time period after the end of the month that the participant turned age 19.
Context:
During FY 2023-24, DHS expended $224.3 million in federal funds under CHIP, including approximately $121.5 million in federal funds expended to provide benefits to participants under SCHIP.
DHS provided a listing of 102,678 participants identified in the CARES system as an open case in SCHIP between July 1, 2023, and June 30, 2024. Using the birthdate DHS provided, we calculated each participant’s age as of July 1, 2023, and identified a population of those participants who were age 19 prior to FY 2023-24. We further identified a population of participants who turned age 19 during FY 2023-24. We randomly selected ten participants from each population and reviewed CARES information to identify the redetermination date and the date eligibility for SCHIP ended.
Questioned Costs:
Undetermined.
In response to Finding 2023-300, CMS communicated to DHS that CMS can only pursue recovery of costs for eligibility errors when identified under CMS’ Payment Error Rate Measurement program. Therefore, CMS would not pursue recovery associated with the questioned costs we identified for the FY 2022-23 audit finding. Given this response from CMS, we did not calculate questioned costs for the ineligible SCHIP participants for FY 2023-24.
Effect:
DHS maintained eligibility for participants that were not eligible for the SCHIP program, which resulted in improper payments and federal reimbursement for participants who were ineligible.
Cause:
To comply with continuous eligibility requirements, DHS indicated that various changes were made to the CARES system at the start of the public health emergency to ensure that changes in circumstances did not result in terminations unless the member passed away, moved out of state, or voluntarily requested disenrollment. These changes were applied to all MA programs, including programs funded through CHIP. DHS indicated that it chose to maintain continuous eligibility for participants in SCHIP to prioritize and protect the health and safety of the children covered by the program from the loss of access to coverage. DHS indicated that further changes to the CARES system were not pursued in response to the January 2021 CMS guidance.
DHS indicated that as the public health emergency continued, it focused on preparing for the end of the public health emergency. In addition, DHS informed us that discussions with CMS in May 2022 related to concerns with compliance and system limitations did not result in further follow-up from CMS and did not result in system changes to CARES.
During FY 2023-24, DHS performed redeterminations of MA and CHIP participants as part of its unwinding plan. DHS reported that participants who did not meet the age requirements were prioritized in this process.
Recommendation:
We recommend the Wisconsin Department of Health Services continue with efforts to perform redeterminations of eligibility and remove eligibility for Children’s Health Insurance Program participants who exceed the age requirement.
Finding 2024-300: Eligibility for the Children’s Health Insurance Program
Children’s Health Insurance Program (Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: Undetermined
COVID-19—Children’s Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: Undetermined
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the activities allowed or unallowed, allowable costs/cost principles, and eligibility compliance requirements.
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Eligibility for the Children’s Health Insurance Program
Background:
The U.S. Department of Health and Human Services (DHHS) provides funding to DHS for CHIP. Funding under this program provides financial assistance to states in maintaining and expanding healthcare coverage to children residing in low-income families. CHIP is funded by both the state and federal government, with the federal portion determined by the enhanced Federal Medical Assistance Percentage (FMAP) rate. Under CHIP, Wisconsin has a separate CHIP program (SCHIP) that provides health insurance to uninsured low-income children as well as certain pregnant women through a postpartum period. Also under CHIP, Wisconsin has a Medicaid expansion program (MCHIP) that expands the State’s MA program and provides enhanced federal participation for targeted low-income children.
DHS partners with local agency caseworkers who are responsible for verifying that CHIP participants meet program eligibility requirements. Caseworkers perform eligibility determination functions, such as obtaining information from the parents or guardians of children applying for health care benefits that is then recorded into the Client Assistance for Reemployment and Economic Support (CARES) system. DHS relies on the CARES system to manage CHIP cases to ensure only eligible participants receive CHIP benefits. Information from the CARES system related to eligible participants is then used by the Medicaid Management Information System (MMIS) to process payments to providers and managed care organizations. During the public health emergency, the federal government required a continuous eligibility period for MA participants.
As part of our FY 2022-23 audit (report 24-3) we identified that DHS maintained continuous eligibility for SCHIP participants who were over age 19, which was not in compliance with federal requirements for this program. We recommended that DHS work with the federal government to resolve these improper payments, including the determination of the total amount of improper payments, and return these amounts to the federal government, as appropriate (Finding 2023-300).
Criteria:
Title XXI of the Social Security Act permits states to establish certain eligibility criteria for CHIP. Per 42 CFR s. 457.320, and following guidelines set forth in 42 USC s. 1397bb (b), DHS established age criteria that permits children under 19 years of age to participate in SCHIP. As a condition of receiving a temporary increase to federal participation under the Families First Coronavirus Response Act, states were required to maintain enrollment of nearly all eligible MA participants. Although this requirement applied to participants determined eligible for MCHIP, it did not apply to SCHIP participants. In guidance issued in January 2021, the Centers for Medicare and Medicaid Services (CMS) further specified that states should not continue to provide coverage under a SCHIP program to participants who did not meet age requirements. At the time a participant reaches age 19, the guidance specifies that states should transition the participant from SCHIP coverage to MA coverage, if eligible.
In response to the public health emergency, DHS also received approval from CMS on August 19, 2020, for an amendment to SCHIP that allowed the State to delay acting on certain changes, beginning March 1, 2020. However, the amendment further stated that changes in circumstances described in 42 CFR s. 457.342 (a) and cross-referenced to 42 CFR s. 935.926 (d) should continue to be acted on, including the circumstance of a child attaining the age of 19.
Condition:
During the public health emergency, and in conflict with federal requirements and the approved state plan, DHS maintained continuous eligibility for SCHIP participants who were over age 19.
The unwinding period, which began on April 1, 2023, is the period after the expiration of the continuous enrollment condition authorized by the Families First Coronavirus Response Act, and includes the process of resuming to normal operations, including restarting full MA and CHIP eligibility renewals and terminations of coverage for ineligible individuals. Throughout FY 2023-24, DHS implemented its unwinding plan and performed redeterminations of eligibility for MA and CHIP participants, including those that exceeded the age requirement for the SCHIP program. The unwinding period ended in June 2024 and DHS resumed normal operations.
Given the number of SCHIP participants identified in the prior audit as exceeding the age requirement, and because the unwinding process was ongoing throughout FY 2023-24, we anticipated that we would continue to identify SCHIP participants who were age 19 and older during FY 2023-24 and that continued to be eligible to receive benefits. During our audit, we identified 4,510 SCHIP participants in the CARES system who were age 19 prior to July 1, 2023. In reviewing ten participants, we note that redeterminations were performed in July or August 2023 for nine of these participants. In each case, eligibility for SCHIP ended. The remaining participant’s eligibility was removed in March 2024. Further, we identified 3,499 participants who turned age 19 between July 1, 2023, and May 31, 2024. We reviewed ten of these participants. For six of the ten reviewed, we found that a timely redetermination was completed and that eligibility was appropriately ended at the end of the month that the participant turned age 19. For the remaining four participants, a redetermination was not completed in a timely manner and eligibility was not removed until a time period after the end of the month that the participant turned age 19.
Context:
During FY 2023-24, DHS expended $224.3 million in federal funds under CHIP, including approximately $121.5 million in federal funds expended to provide benefits to participants under SCHIP.
DHS provided a listing of 102,678 participants identified in the CARES system as an open case in SCHIP between July 1, 2023, and June 30, 2024. Using the birthdate DHS provided, we calculated each participant’s age as of July 1, 2023, and identified a population of those participants who were age 19 prior to FY 2023-24. We further identified a population of participants who turned age 19 during FY 2023-24. We randomly selected ten participants from each population and reviewed CARES information to identify the redetermination date and the date eligibility for SCHIP ended.
Questioned Costs:
Undetermined.
In response to Finding 2023-300, CMS communicated to DHS that CMS can only pursue recovery of costs for eligibility errors when identified under CMS’ Payment Error Rate Measurement program. Therefore, CMS would not pursue recovery associated with the questioned costs we identified for the FY 2022-23 audit finding. Given this response from CMS, we did not calculate questioned costs for the ineligible SCHIP participants for FY 2023-24.
Effect:
DHS maintained eligibility for participants that were not eligible for the SCHIP program, which resulted in improper payments and federal reimbursement for participants who were ineligible.
Cause:
To comply with continuous eligibility requirements, DHS indicated that various changes were made to the CARES system at the start of the public health emergency to ensure that changes in circumstances did not result in terminations unless the member passed away, moved out of state, or voluntarily requested disenrollment. These changes were applied to all MA programs, including programs funded through CHIP. DHS indicated that it chose to maintain continuous eligibility for participants in SCHIP to prioritize and protect the health and safety of the children covered by the program from the loss of access to coverage. DHS indicated that further changes to the CARES system were not pursued in response to the January 2021 CMS guidance.
DHS indicated that as the public health emergency continued, it focused on preparing for the end of the public health emergency. In addition, DHS informed us that discussions with CMS in May 2022 related to concerns with compliance and system limitations did not result in further follow-up from CMS and did not result in system changes to CARES.
During FY 2023-24, DHS performed redeterminations of MA and CHIP participants as part of its unwinding plan. DHS reported that participants who did not meet the age requirements were prioritized in this process.
Recommendation:
We recommend the Wisconsin Department of Health Services continue with efforts to perform redeterminations of eligibility and remove eligibility for Children’s Health Insurance Program participants who exceed the age requirement.
Finding 2024-300: Eligibility for the Children’s Health Insurance Program
Children’s Health Insurance Program (Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: Undetermined
COVID-19—Children’s Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: Undetermined
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the activities allowed or unallowed, allowable costs/cost principles, and eligibility compliance requirements.
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Background:
DHHS provides funding to DHS for SABG, the ELC grant, the Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response, which DHS refers to as the Public Health Emergency Response grant, and the Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises program, which DHS refers to as the Health Disparities grant. These grants have various health-related purposes. To fulfill the purpose of each grant, DHS subawards funds to various entities, including counties, tribal governments, and other nonprofit organizations. In addition, under the SABG grant, amounts are provided by DHS to DCF and the University of Wisconsin-Madison (UW-Madison), which further subgrant to various entities.
Under FFATA, a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
In our FY 2022-23 audit (report 24-3), we identified that DHS had not accurately reported information in FSRS for several grants. We recommended DHS improve its procedures to accurately report required award information in a timely manner, including the date the subaward agreement was signed, and develop procedures to identify and report subawards made by state agencies to which it had transferred federal funding (Finding 2023-304).
Criteria:
Under 2 CFR s. 170, and as the prime grant awardee for these grants, DHS has overall responsibility for FFATA reporting and is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2023, it must be reported no later than January 31, 2024. The information required to be reported in FSRS includes several key data elements such as information about the recipient, the amount of the award, the project description, and the date the subaward agreement was signed.
Condition:
We selected a total of 34 subawards made by DHS under these grants during FY 2023-24 for testing, and we identified that 28 of the 34 subawards were not reported in a timely manner. We found that 14 of the 20 SABG subawards were not reported in a timely manner. For example, under the SABG grant, ten subawards were reported in August 2024, which was between seven to ten months after the date of the subaward.
In addition, we identified the obligation date was not accurate to within 10 days of the date the subaward agreement was signed for two subawards made under the SABG grant. We also found that none of the ELC, Public Health Emergency Response, and Health Disparities subawards we tested were reported in a timely manner. In addition, we found the project description was not completed accurately for ten subawards, including three for SABG subawards, two for ELC subawards, two for Public Health Emergency Response subawards, and three for Health Disparities subawards. Finally, we found that DHS did not report in FSRS any of the seven subawards DCF made under the SABG grant. DHS also did not report in FSRS the one subaward UW-Madison made under the SABG grant.
Context:
During FY 2023-24, DHS expended:
-$35.1 million under the SABG grant, of which $31.1 million was provided to subrecipients;
-$46.9 million under the ELC grant, of which $9.1 million was provided to subrecipients;
-$14.7 million under the Public Health Emergency Response grant, of which $8.3 million was provided to subrecipients; and
-$7.9 million under the Health Disparities grant, of which $2.6 million was provided to subrecipients.
Under the SABG grant, DCF expended $2.9 million, that was provided to subrecipients. Under the SABG grant, UW-Madison expended $0.2 million that was provided to subrecipients.
We reviewed 20 subawards for the SABG grant, two subawards for the ELC grant, nine for the Public Health Emergency Response grant, and three subawards for the Health Disparities grant that were made by DHS during FY 2023-24. We interviewed DHS staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. To assess if the subawards were reported in an accurate and timely manner, we requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed. We further followed up on the status of our prior audit recommendations.
Questioned Costs:
None.
Effect:
DHS did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS. The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov.
Cause:
In report 24-3, we noted that there were issues with the queries used to obtain information for reporting and procedures did not include obtaining information related to subawards made by other state agencies. During FY 2023-24, queries to retrieve information were established in a new system. However, the procedures in place to review the data produced by the queries and to determine what to report in FSRS were insufficient to ensure accurate and timely reporting. In response to our prior audit finding, DHS reported that it updated its FFATA reporting procedures. However, since the updates were not implemented until late in FY 2023-24, issues continued to be identified in our current audit.
Recommendation:
We recommend the Wisconsin Department of Health Services continue its efforts to implement updated procedures and make future revisions to these procedures for Federal Funding Accountability and Transparency Act reporting to ensure reporting is accurate, complete, and submitted in a timely manner.
Finding 2024-309: Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
COVID-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response (Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response
(Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises
(Assistance Listing number 93.391)
Award Numbers Award Years
1 NH75OT000039-01-00 2021
6 NH75OT000039-01-03 2023
6 NH75OT000039-01-05 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
COVID-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Year
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Background:
DHHS provides funding to DHS for SABG, the ELC grant, the Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response, which DHS refers to as the Public Health Emergency Response grant, and the Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises program, which DHS refers to as the Health Disparities grant. These grants have various health-related purposes. To fulfill the purpose of each grant, DHS subawards funds to various entities, including counties, tribal governments, and other nonprofit organizations. In addition, under the SABG grant, amounts are provided by DHS to DCF and the University of Wisconsin-Madison (UW-Madison), which further subgrant to various entities.
Under FFATA, a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
In our FY 2022-23 audit (report 24-3), we identified that DHS had not accurately reported information in FSRS for several grants. We recommended DHS improve its procedures to accurately report required award information in a timely manner, including the date the subaward agreement was signed, and develop procedures to identify and report subawards made by state agencies to which it had transferred federal funding (Finding 2023-304).
Criteria:
Under 2 CFR s. 170, and as the prime grant awardee for these grants, DHS has overall responsibility for FFATA reporting and is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2023, it must be reported no later than January 31, 2024. The information required to be reported in FSRS includes several key data elements such as information about the recipient, the amount of the award, the project description, and the date the subaward agreement was signed.
Condition:
We selected a total of 34 subawards made by DHS under these grants during FY 2023-24 for testing, and we identified that 28 of the 34 subawards were not reported in a timely manner. We found that 14 of the 20 SABG subawards were not reported in a timely manner. For example, under the SABG grant, ten subawards were reported in August 2024, which was between seven to ten months after the date of the subaward.
In addition, we identified the obligation date was not accurate to within 10 days of the date the subaward agreement was signed for two subawards made under the SABG grant. We also found that none of the ELC, Public Health Emergency Response, and Health Disparities subawards we tested were reported in a timely manner. In addition, we found the project description was not completed accurately for ten subawards, including three for SABG subawards, two for ELC subawards, two for Public Health Emergency Response subawards, and three for Health Disparities subawards. Finally, we found that DHS did not report in FSRS any of the seven subawards DCF made under the SABG grant. DHS also did not report in FSRS the one subaward UW-Madison made under the SABG grant.
Context:
During FY 2023-24, DHS expended:
-$35.1 million under the SABG grant, of which $31.1 million was provided to subrecipients;
-$46.9 million under the ELC grant, of which $9.1 million was provided to subrecipients;
-$14.7 million under the Public Health Emergency Response grant, of which $8.3 million was provided to subrecipients; and
-$7.9 million under the Health Disparities grant, of which $2.6 million was provided to subrecipients.
Under the SABG grant, DCF expended $2.9 million, that was provided to subrecipients. Under the SABG grant, UW-Madison expended $0.2 million that was provided to subrecipients.
We reviewed 20 subawards for the SABG grant, two subawards for the ELC grant, nine for the Public Health Emergency Response grant, and three subawards for the Health Disparities grant that were made by DHS during FY 2023-24. We interviewed DHS staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. To assess if the subawards were reported in an accurate and timely manner, we requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed. We further followed up on the status of our prior audit recommendations.
Questioned Costs:
None.
Effect:
DHS did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS. The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov.
Cause:
In report 24-3, we noted that there were issues with the queries used to obtain information for reporting and procedures did not include obtaining information related to subawards made by other state agencies. During FY 2023-24, queries to retrieve information were established in a new system. However, the procedures in place to review the data produced by the queries and to determine what to report in FSRS were insufficient to ensure accurate and timely reporting. In response to our prior audit finding, DHS reported that it updated its FFATA reporting procedures. However, since the updates were not implemented until late in FY 2023-24, issues continued to be identified in our current audit.
Recommendation:
We recommend the Wisconsin Department of Health Services continue its efforts to implement updated procedures and make future revisions to these procedures for Federal Funding Accountability and Transparency Act reporting to ensure reporting is accurate, complete, and submitted in a timely manner.
Finding 2024-309: Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
COVID-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response (Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response
(Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises
(Assistance Listing number 93.391)
Award Numbers Award Years
1 NH75OT000039-01-00 2021
6 NH75OT000039-01-03 2023
6 NH75OT000039-01-05 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
COVID-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Year
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Geographic Programs - Great Lakes Restoration Initiative—Federal Financial Reporting
Background:
The DNR receives federal funding from the U.S. Environmental Protection Agency (EPA) for the GLRI program. The objective of the GLRI program is to advance protection and restoration of the Great Lakes Basin Ecosystem through the funding of various projects.
Criteria:
Under 2 CFR s. 200.328, and at least annually, DNR must submit the Federal Financial Report (FFR) to the EPA for each project of the GLRI program. DNR is required to submit annual FFRs no later than 90 calendar days after the project’s reporting period and final FFRs no later than 120 calendar days after the conclusion of the project’s period of performance. The EPA may grant extension of reporting due dates when requested and justified by the recipient.
Condition:
DNR did not submit FFRs in a timely manner for six of the nine annual FFR reports we tested for the GLRI program, and DNR did not request an extension of reporting due dates from the EPA. The six annual FFRs we tested were completed between 17 and 219 calendar days past the due date. For example, four FFRs we tested had a reporting period end date of March 31, 2024, and a report due date of June 29, 2024. DNR filed the annual FFRs on November 1, 2024, which was 125 days past the due date. For five of the six annual FFRs we tested that were late, we noted that DNR submitted the FFRs after our inquiry and request to review the FFRs. For each of the six FFRs, we found that DNR retained documentation to support the amounts included in the reports and the information in the FFRs was accurate.
Context:
During FY 2023-24, DNR expended $15.5 million under the GLRI program. We interviewed DNR staff to gain an understanding of its procedures for preparing FFRs for GLRI projects. During FY 2023-24, DNR was required to submit 20 annual FFRs and 2 final FFRs for GLRI projects to the EPA. We reviewed nine of the annual FFRs and the 2 final FFRs. We requested DNR’s documentation to support the information reported in the FFRs.
Questioned Costs:
None.
Effect:
The EPA did not have timely financial reports to assess DNR’s management of GLRI projects.
Cause:
DNR did not have sufficient procedures in place to track when annual FFRs were required to be submitted for GLRI projects. Although DNR’s procedures require the GLRI program’s grant accountant to monitor FFR due dates, that position was vacant during FY 2023-24 and filled in FY 2024-25. DNR indicated that other grant accountants completed some reporting for the GLRI program, but not all reporting was completed until after we made inquiries of DNR staff in October 2024. DNR staff indicated that they began to implement changes in October 2024 to more effectively track FFR due dates by having DNR’s Management and Grant Accounting Section Chief monitor the FFR reporting schedule.
Recommendation:
We recommend the Wisconsin Department of Natural Resources develop and implement policies and procedures for tracking and submitting timely federal financial reports for the Geographic Programs - Great Lakes Restoration Initiative program.
Finding 2024-800: Geographic Programs - Great Lakes Restoration Initiative—Federal Financial Reporting
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02393 2018
00E02456 2019
00E02487 2019
00E02824 2020
00E02979 2021
00E02975 2021
00E03010 2021
00E03068 2021
03E00712 2022
01E03010 2022
00E03149 2022
00E03187 2022
00E03188 2022
00E03250 2022
00E03252 2022
00E03589 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Natural Resources: The Wisconsin Department of Natural Resources agrees with the audit finding and recommendation.
Geographic Programs - Great Lakes Restoration Initiative—Subrecipient Monitoring
Background:
DNR receives federal funding from the EPA for the GLRI program. The objective of the GLRI program is to advance protection and restoration of the Great Lakes Basin Ecosystem through the funding of various projects. To administer the GLRI program, DNR contracts with subrecipients located around the State, including counties, cities, and sewage districts.
During our FY 2022-23 single audit (report 24-3), we identified that DNR did not perform subrecipient risk assessments or have a plan to monitor subrecipients for the GLRI program based on the risk assessments. Further, DNR did not have sufficient procedures in place to ensure all GLRI subrecipient single audit reports were being obtained and reviewed. We recommended that DNR develop a written monitoring plan for the GLRI program that includes policies and procedures for:
-completing risk assessments for each subrecipient;
-the specific monitoring steps that are required based on the level of subrecipient risk identified in a risk assessment;
-independently identifying and reviewing subrecipient single audit reports, if applicable; and
-maintaining documentation of all subrecipient monitoring activities (Finding 2023-800).
During FY 2023-24, and in response to our recommendations, DNR developed policies and procedures for monitoring and performing risk assessments of the GLRI subrecipients. In addition, DNR developed procedures to ensure GLRI subrecipient single audit reports were being obtained and reviewed. DNR completed its review of these reports in May 2024.
Criteria:
DNR administers federal programs that are subject to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Uniform Guidance includes three requirements related to the monitoring of subrecipients. First, 2 CFR s. 200.332 (a) (1) requires DNR to communicate certain award information to subrecipients at the time of the subaward. Second, 2 CFR s. 200.332 (b) requires DNR to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring. Finally, 2 CFR s. 200.332 (d) through (f) requires DNR to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
An EPA subaward policy further clarifies that the Uniform Guidance provisions are applicable to its grant programs, including a requirement for DNR to establish and follow a system for evaluating the risks of subrecipient noncompliance with laws, regulations, and the terms and conditions of the subaward, as required by 2 CFR ss. 200.332 (b) and (d). This policy also requires DNR to document its evaluations. In addition, EPA’s policy requires that DNR establish and follow a process for deciding whether to impose additional requirements on subrecipients based on the risk assessments.
Condition:
In response to our FY 2023-24 recommendation, in June 2024 DNR developed policies and procedures for monitoring GLRI subrecipients, including procedures for completing a risk assessment for each GLRI subrecipient and ranking each subrecipient based on the risk assessment to determine the level of monitoring needed. However, DNR did not complete risk assessments for any of its GLRI subrecipients during FY 2023-24.
Context:
DNR expended $15.5 million under the GLRI program during FY 2023-24, including $4.0 million that it provided to 21 subrecipients. We interviewed DNR staff to gain an understanding of its procedures for monitoring subrecipients. We reviewed the agreements between DNR and the subrecipients to identify whether DNR had communicated the required award information to them. We also reviewed monitoring activities DNR performed for the GLRI program, including DNR’s process to review subrecipient single audit reports and DNR’s monitoring of subrecipients through progress reporting and reimbursement requests. Finally, we reviewed and discussed with DNR staff the new procedures for completing subrecipient risk assessments.
Questioned Costs:
None.
Effect:
Because DNR did not comply with all subrecipient monitoring compliance requirements for the GLRI program, there is a higher risk that DNR and its GLRI subrecipients are not in compliance with all federal requirements.
Cause:
Although DNR developed policies and procedures for monitoring and performing risk assessments for the GLRI subrecipients, it did not complete risk assessments for the GLRI subrecipients during FY 2023-24. DNR indicated it would implement its policies and procedures for monitoring and performing risk assessments for the GLRI subrecipients as new subawards are created in FY 2024-25. However, DNR should also perform risk assessments for existing GLRI subrecipients to ensure its monitoring of the activities for ongoing GLRI projects is appropriate.
Recommendation:
We recommend the Wisconsin Department of Natural Resources implement its new monitoring policies and procedures for completing risk assessments for each subrecipient of the Geographic Programs - Great Lakes Restoration Initiative program, including for all its existing subrecipients for ongoing projects.
Finding 2024-801: Geographic Programs - Great Lakes Restoration Initiative—Subrecipient Monitoring
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02393 2018
00E02456 2019
00E02490 2019
00E02824 2020
00E02975 2021
00E02979 2021
00E03010 2021
03E00712 2022
01E03010 2022
00E03149 2022
00E03250 2022
00E03252 2022
00E03490 2023
00E03486 2023
00E03589 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Natural Resources: The Wisconsin Department of Natural Resources agrees with the audit finding and recommendation.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Monthly Reconciliations
Background:
UW institutions receive funding for several grant and loan programs, such as Federal Direct Student Loans (Assistance Listing number 84.268) and the Federal Pell Grant Program (Assistance Listing number 84.063), from the U.S. Department of Education that are administered under the SFA Cluster. UW Oshkosh is required to comply with U.S. Department of Education requirements for disbursing funds to students under the Direct Student Loans and Pell Grant programs. This includes reporting disbursement activity in a U.S. Department of Education system in a timely manner. For FY 2023-24, UW-Oshkosh reported federal financial assistance of $29.7 million in Direct Student Loans and $10.3 million in Pell Grants.
Criteria:
Pursuant to 34 CFR s. 685.300 (b) (5), UW-Oshkosh is required to perform monthly reconciliations between U.S. Department of Education systems and its financial and business systems for all Direct Student Loans activity. The monthly reconciliations include two components:
-an external review between UW Oshkosh’s disbursements in its student information system compared to data in a U.S. Department of Education reporting system; and
-an internal reconciliation between UW Oshkosh’s student information system and its accounting system.
In addition, U.S. Department of Education guidance included in Volume 4, Chapter 5, of the Federal Student Aid Handbook, recommends that UW Oshkosh similarly complete monthly reconciliations for Pell Grant activity.
Condition:
Although UW-Oshkosh provided documentation for the external component of reconciliations it completed for the two months we selected to review for the Direct Student Loans and Pell Grant reconciliations during FY 2023 24, it did not provide documentation for the internal component of these reconciliations.
Context:
We reviewed and discussed UW Oshkosh’s procedures for performing monthly reconciliations for Direct Student Loans and Pell Grant disbursements. We selected two monthly Direct Student Loans and Pell Grant reconciliations and reviewed the internal and external reconciliation components for each month.
Questioned Costs:
None.
Effect:
Without documentation, UW-Oshkosh cannot be assured that it accurately completed the required reconciliations to identify whether Direct Student Loans or Pell Grant disbursements were properly reported to the U.S. Department of Education and other federal requirements were being met.
Cause:
UW-Oshkosh indicated that it was unable to locate documentation for the internal component of the reconciliation for the months we requested because the documentation was not retained in a shared folder. In addition, UW Oshkosh indicated that there had been staff turnover in the position that completed the reconciliations.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-ensure all required monthly reconciliations are completed in a timely manner; and
-retain documentation to support all monthly reconciliations it completes.
Finding 2024-700: Student Financial Assistance Cluster—UW-Oshkosh Monthly Reconciliations
Federal Pell Grant Program (Assistance Listing number 84.063)
Award Numbers Award Years
Various Various
Questioned Costs: None
Federal Direct Student Loans (Assistance Listing number 84.268)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-Madison must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. For students that begin attending classes, but who later withdraw from enrollment, 34 CFR s. 668.22 requires that UW-Madison must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In order not to consider a student to have withdrawn from enrollment under certain circumstances, which permits a student to retain federal financial assistance that otherwise would need to be returned to the federal government, 34 CFR s. 668.22 (a) (2) (ii) provides certain exemptions to students.
Condition:
For four students, we found that UW-Madison did not accurately determine the amount of federal financial assistance it disbursed that should have been returned to the U.S. Department of Education. First, we found that UW-Madison did not return all federal financial assistance it disbursed to two students that did not begin attendance and to one student who only attended one day during FY 2023-24. For these three students, UW-Madison determined it failed to return $16,403 in federal financial assistance it disbursed during FY 2023-24. Second, we found that UW-Madison did not accurately determine the federal financial assistance that should be returned after a student withdrew from enrollment during the summer 2023 term. For this student, UW-Madison incorrectly applied an exemption, which led to UW-Madison failing to return $584 in federal financial assistance to the U.S. Department of Education.
Context:
UW-Madison uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Madison staff its process for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Madison to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. When reviewing the data UW-Madison provided, we noted potential errors in the amount of aid returned for students identified as never attending.
Separately, as part of a UW systemwide sample of 60 students, we selected 6 students who had received federal financial assistance and who withdrew from enrollment from UW-Madison to determine the amount of federal financial assistance those students earned and the related amounts UW-Madison returned to the U.S. Department of Education.
Questioned Costs:
$16,987, Plus an Undetermined Amount
Effect:
UW-Madison did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Madison identified that the errors in determining the amount of the federal financial assistance that should have been returned to the federal government for the four students we identified were manual errors in the withdrawal procedures and calculations completed during and at the end of each term. These errors were not detected by any other review procedures. Although UW-Madison correctly identified the status of the two students who never attended and the need to return all disbursed federal financial assistance, it did not follow through on the actual repayment.
For the student who had an exemption applied, the exemption was incorrectly selected when UW-Madison completed a determination, and the error was not detected in UW-Madison’s review process. UW-Madison indicated that its automated review processes conducted at the end of each term did not specifically address the matters we identified for the four students.
After we identified these errors in the determination of the amount of federal financial assistance to return to the federal government, UW-Madison returned in fall 2024 the unearned federal financial assistance for the three students who never attended or withdrew from enrollment after attending one day. In addition, UW Madison returned the additional $584 in February 2025 for the student who withdrew from enrollment and did not meet the criteria for a withdrawal exemption.
Recommendation:
We recommend the University of Wisconsin-Madison review, update, and implement its procedures to improve the accuracy and follow-through for making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including thoroughly reviewing applied exemptions, and returning federal financial assistance in a timely manner to the federal government.
Finding 2024-703: Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,987, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Background:
UW-River Falls receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-River Falls reported a total of $23.6 million in federal financial assistance under the SFA Cluster. UW-River Falls is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-River Falls must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. Under Volume 5, Chapter 1 of the Federal Student Aid Handbook, when a student begins attendance in at least one course but does not begin attendance in all courses the student was scheduled to attend, the school must determine if it is necessary to recalculate the student’s eligibility for the Pell Grant based on a revised enrollment status and the cost of education pursuant to 34 CFR s. 690.80. If the student withdraws, this recalculation must be performed before determining whether to return federal financial assistance pursuant to 34 CFR s. 668.22.
Condition:
We found that UW-River Falls did not return $16,010 in federal financial assistance for four students that did not begin attendance in all enrolled courses during FY 2023-24. This included two students who never began attendance in any enrolled courses for whom all disbursed federal financial assistance was required to be returned. This also included two students who began at least one course but not all courses for which the students had enrolled. UW-River Falls did not perform the required recalculation of Pell Grant eligibility or an assessment of federal financial assistance it had disbursed that these students had not earned.
Context:
UW-River Falls uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-River Falls the process used for identifying students who did not begin attending all enrolled courses or withdrew from enrollment, and we requested a list of such students during FY 2023-24. UW-River Falls did not have a complete list readily available of students who did not begin attending all enrolled courses.
Questioned Costs:
$16,010, Plus an Undetermined Amount
Effect:
UW-River Falls did not comply with all requirements to return federal financial assistance for students who never attended or did not begin attending all enrolled courses during FY 2023-24.
Cause:
UW-River Falls did not have procedures to identify from its student information system, or other sources, those students for whom it disbursed federal financial assistance, yet the students did not attend at least one course during the term or begin all courses enrolled. Depending on whether a student dropped any of their courses, UW-River Falls indicated that the procedures to evaluate attendance may not have identified all students who would ultimately be determined as never attending for the academic term.
After we requested a list of students who did not begin attending all enrolled courses, UW-River Falls identified two students who did not begin at least one course but for whom it had disbursed federal financial assistance. For the other two students who began at least one course, UW-River Falls completed the required Pell Grant recalculation for the students. UW-River Falls also determined the amount of federal financial assistance to return for all four students, as applicable, to the U.S. Department of Education in September 2024.
Recommendation:
We recommend the University of Wisconsin-River Falls review, update, and implement procedures to:
-identify students after the start of each academic term for whom it disbursed federal financial assistance and the students did not begin all enrolled courses;
-complete required recalculations for Pell Grant eligibility and a determination of federal financial assistance that was not earned by the students, as applicable; and
-return amounts to the federal government in a timely manner.
Finding 2024-704: Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,010, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-River Falls: The University of Wisconsin-River Falls agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Background:
UW-Parkside receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Parkside reported a total of $21.3 million in federal financial assistance under the SFA Cluster. UW-Parkside is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22, requires that UW-Parkside must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW Parkside should be returned to the U.S. Department of Education unless certain conditions are met. In determining whether federal financial assistance was earned by a student, the Federal Student Aid Handbook provides guidance on how to calculate applicable institution charges and academic days under different circumstances.
Condition:
For two of three students we reviewed who withdrew from enrollment during FY 2023-24, UW-Parkside inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Parkside incorrectly accounted for a disbursement that occurred after the student’s withdrawal from enrollment as an amount that was earned by the student for the fall 2023 term. As a result, UW Parkside returned $548 less than what should have been returned to the U.S. Department of Education. For the second student, UW-Parkside incorrectly identified the end date of the spring 2024 term and did not include the correct institutional charges in its determination. As a result, UW-Parkside returned $1,190 less than should have been returned to the U.S. Department of Education.
Context:
UW-Parkside uses a student information system to track activity for students that withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Parkside staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from
UW-Parkside to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 3 students who had received federal financial assistance and withdrew from UW-Parkside to determine the amount of federal financial assistance those students earned and the related amounts UW-Parkside returned to the U.S. Department of Education.
Questioned Costs:
$1,738, Plus an Undetermined Amount
Effect:
UW-Parkside did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Parkside did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal assistance to return. Although UW-Parkside disbursed federal financial assistance later than is typical to one student, the disbursement was not correctly categorized within the calculations completed by UW-Parkside to determine that the entire amount of the federal financial assistance was required to be returned to the federal government.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the students we identified.
Finding 2024-705: Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $1,738, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Background:
UW-Platteville receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Platteville reported a total of $29.1 million in federal financial assistance under the SFA Cluster. UW-Platteville is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Under 34 CFR s. 668.21, UW-Platteville must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. In addition, when a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Platteville must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In determining whether federal financial assistance was earned by a student, Volume 5, Chapter 2 of the Federal Student Aid Handbook specifies how to calculate academic days.
Condition:
For two of the five students we reviewed who never began attendance or who withdrew from enrollment during FY 2023-24, UW-Platteville inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Platteville incorrectly determined the student began attendance because the student attended one day of the fall 2023 term. As a result, UW-Platteville failed to return $24 in federal financial assistance to the U.S. Department of Education. For the second student, UW-Platteville did not exclude a five-day break from its determination of the federal financial assistance amount the student had earned during the fall 2023 term. Although this student had earned all of the federal financial assistance prior to the student’s withdrawal from enrollment, UW-Platteville incorrectly returned $1,226. Because UW-Platteville used the same calculation for all determinations for the fall 2023 term, there may be further errors in the federal financial assistance amounts UW-Platteville determined.
Context:
UW-Platteville uses a student information system to track activity for students who withdraw from enrollment in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Platteville staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Platteville to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 5 students who had received federal financial assistance and who withdrew from UW-Platteville to determine the amount of federal financial assistance those students earned and the related amounts UW-Platteville returned to the U.S. Department of Education.
Questioned Costs:
$24, Plus an Undetermined Amount
Effect:
UW-Platteville did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Platteville did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal financial assistance to return to the federal government. After we identified the error for the student who attended only one day, UW-Platteville returned the additional $24 to the federal government in November 2024. For the fall 2023 term, UW-Platteville changed its fall break from four to five days, which required a change in the number of academic days used in the calculation of federal financial assistance earned when a student withdraws from enrollment. UW-Platteville did not have a process to review the academic calendar for purposes of its return procedures.
Recommendation:
We recommend the University of Wisconsin-Platteville review, update, and implement its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including annually reviewing the academic days used in its determinations.
Finding 2024-706: Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $24, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Platteville: The University of Wisconsin-Platteville agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Background:
UW-Whitewater receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Whitewater reported a total of $58.4 million in federal financial assistance under the SFA Cluster. UW-Whitewater is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Whitewater must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook, the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW-Whitewater is required to be returned to the U.S. Department of Education unless certain conditions are met.
Condition:
UW-Whitewater inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education for one of seven students we reviewed who withdrew from enrollment during FY 2023 24. UW-Whitewater incorrectly accounted for a disbursement to the student that occurred after the date for which UW-Whitewater later identified the student had withdrawn from enrollment as an amount that was earned by the student. As a result, UW-Whitewater failed to return $400 in federal financial assistance to the U.S. Department of Education for the spring 2024 term.
Context:
In order to determine the federal financial assistance a student earned and the amount that must be returned to the U.S. Department of Education for amounts a student did not earn, UW-Whitewater uses a student information system to track activity for students who withdraw. We discussed with UW-Whitewater staff the process used for identifying students who withdrew from enrollment. We also requested information from UW-Whitewater to identify students who withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 7 students who had received federal financial assistance and who withdrew from UW-Whitewater to determine the amount of federal financial assistance those students earned and the related amounts UW-Whitewater returned to the U.S. Department of Education.
Questioned Costs:
$400, Plus an Undetermined Amount
Effect:
UW-Whitewater did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Whitewater did not have adequate procedures to review and ensure its determination of the amount of federal assistance to return was accurate. Although UW-Whitewater disbursed federal financial assistance later than is typical to the student, the disbursement was not correctly categorized within the calculations completed by UW-Whitewater nor was the categorization error detected by other
UW-Whitewater procedures.
Recommendation:
We recommend the University of Wisconsin-Whitewater:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the student we identified.
Finding 2024-707: Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $400, Plus an Undetermined Amount
Type of Finding: Noncompliance
Response from the University of Wisconsin-Whitewater: The University of Wisconsin-Whitewater agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Madison is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to the National Student Loan Data System (NSLDS). Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Madison is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time;
-report the same effective date for a student who withdraws from enrollment as the date used in its determination of whether any federal financial assistance must be returned in accordance with
34 CFR s. 668.22;
-report a student who has completed a program with a status of “graduated” rather than “withdrawn”;
-maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed; and
-maintain the program begin date, which is the date the student first began attending the program being reported, if a student’s program of study has not changed.
Condition:
UW-Madison uses the National Student Clearinghouse (NSC) to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Madison that identify potential errors in UW-Madison’s reporting of student activities. It is the responsibility of UW-Madison to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Madison did not report to NSLDS accurate information for 12 of the 17 students we reviewed. First, UW-Madison did not accurately report a student who withdrew from enrollment without notification in a timely manner. Second, UW-Madison incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment. Third, UW-Madison incorrectly reported the program-level enrollment status effective date for two students. Fourth, UW-Madison incorrectly reported the program begin date for six students. In addition, UW Madison incorrectly reported both the program-level enrollment status effective date and program begin date for two students.
Context:
We discussed with UW-Madison staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Madison relies on data from its student information system to compile information to transmit to NSC. UW-Madison also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student that withdrew from UW-Madison and six students who graduated from UW-Madison. In addition, we selected ten additional UW-Madison students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Madison did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Madison did not report to NSLDS who had withdrawn from enrollment without notification, we found UW-Madison’s enrollment reporting procedures did not assign responsibility for communicating certain information to those staff in the registrar’s office who are responsible for NSLDS reporting. As a result, those students the financial aid office determined had withdrawn from enrollment without notification, and for which it had completed a determination of federal financial assistance the students did not earn, were not known to staff in the registrar’s office for purposes of NSLDS reporting. In addition, UW-Madison indicated that withdrawals from enrollment without notification are identified after the term ends and its student information system did not have a dedicated effective date field in order to automatically identify such student records for the required NSLDS reporting.
Second, for the student UW-Madison did not accurately report as graduated within NSLDS, we found UW‑Madison relied on a NSC process that is intended to simultaneously update a student’s enrollment status in NSLDS when UW-Madison separately updates a student’s degree as completed. UW-Madison did not complete a separate report to ensure the enrollment status for graduated students was accurately reflected in NSLDS. However, in 2022 NSC had published information that indicated reliance solely on NSC’s process may result in the incorrect status being reported under certain circumstances. Although NSC error reports identified that such errors were present, UW-Madison indicated that it did not review these errors until fall 2024 when it began implementing new U.S. Department of Education reporting requirements.
At that time, UW-Madison stated that it identified that it did not consistently and accurately report in NSLDS those students who had graduated. UW-Madison stated that it then began to work with NSC to identify the extent of the reporting inaccuracies.
Third, in 2021 NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW-Madison’s data from its student information system and had communicated error or warning codes to UW-Madison in these areas. However, UW-Madison did not sufficiently review whether the records identified by NSC as potential errors resulted in inaccurate reporting. For example, NSC used warning codes for potential errors in the program-level enrollment status effective dates. As warning codes do not prohibit submission of reporting, UW-Madison did not review the warnings.
Fourth, in 2021 NSC similarly published information on accurately reporting student program begin dates in NSLDS and NSC had also identified instances of potential inaccurate reporting in UW Madison’s data from its student information system. Although NSC had communicated error or warning codes to UW-Madison in these areas, UW-Madison had not sufficiently reviewed whether the records identified by NSC as potential errors resulted in inaccurate reporting until 2023. At that time, UW-Madison indicated that, after reviewing other NSC warnings, it identified that it did not accurately report program begin dates for students. UW-Madison indicated it then began to work to update its student information system data extraction process to identify the correct program begin date for its submissions to NSC. However, it did not implement these changes until after the audit period.
In addition, UW-Madison indicated that it had turnover in staff responsible for NSLDS reporting in 2021, which may have caused UW-Madison to have missed the NSC publications regarding reporting graduated students accurately, new warning codes, and the importance of reviewing certain warning codes to accurately complete NSLDS reporting.
Recommendation:
We recommend the University of Wisconsin-Madison:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as updating its student information system to allow for an automated identification process to communicate those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated and implement separate reporting to the National Student Clearinghouse to accurately report students who graduate;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program-level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program begin dates and update its student information system extraction process to accurately report program begin dates; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-708: Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Background:
UW-Milwaukee receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Milwaukee reported a total of $133.1 million in federal financial assistance under the SFA Cluster. UW-Milwaukee records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Milwaukee is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Milwaukee is required to maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed.
Condition:
UW-Milwaukee uses NSC to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Milwaukee that identify potential errors in UW-Milwaukee’s reporting of student activities through NSC. These errors are the responsibility of UW-Milwaukee to resolve to ensure its submissions to NSLDS are accurate and complete.
UW-Milwaukee did not report to NSLDS accurate information for the program level enrollment status effective date for five students we reviewed. In addition, based on how information from its student information system is extracted for student reporting to NSLDS, we found that the reporting inaccuracy extended to other UW-Milwaukee students.
Context:
We discussed with UW-Milwaukee staff its procedures for identifying student enrollment status changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Milwaukee relies on data from its student information system to compile information to transmit to NSC. UW-Milwaukee also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included two students who withdrew from UW-Milwaukee and four students who graduated from UW- Milwaukee. In addition, we selected ten additional UW-Milwaukee students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Milwaukee did not comply with requirements to accurately report certain student enrollment status changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
In 2021, NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW- Milwaukee’s data from its student information system and had communicated error or warning codes to UW-Milwaukee in these areas. UW-Milwaukee staff indicated that they were aware that NSC error reports included warnings to identify potential inaccurate reporting of program level enrollment status effective dates and that the errors were a known issue for Peoplesoft-based student information systems. However, UW-Milwaukee chose not to use an all-record update feature that was available to correct the program-level enrollment status effective dates for all student records simultaneously due to the risk that other reporting inaccuracies could result from the action. Further, UW-Milwaukee staff indicated that they were not aware that specific guidance on the program-level enrollment status effective date had been updated to reflect that corrections should be made to fully comply with NSLDS reporting requirements.
Recommendation:
We recommend the University of Wisconsin-Milwaukee:
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates; and
-report changes in student enrollment accurately, completely, and in a timely manner for all student changes that require reporting.
Finding 2024-709: Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Milwaukee: The University of Wisconsin-Milwaukee agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Background:
UW-Oshkosh receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Oshkosh reported a total of $45.3 million in federal financial assistance under the SFA Cluster. UW-Oshkosh records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Oshkosh is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Oshkosh is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time; and
-report a student who has completed a program with a status of “graduated” rather than “withdrawn.”
Condition:
UW-Oshkosh uses NSC to facilitate the enrollment reporting in NSLDS. NSC provides error reports to UW-Oshkosh that identify potential errors in UW Oshkosh’s reporting of student activities. It is the responsibility of UW-Oshkosh to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Oshkosh did not report to NSLDS accurate information for two of the three students we reviewed.
First, UW-Oshkosh did not report in a timely manner one student who withdrew from enrollment without notification. Second, UW-Oshkosh incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment.
Context:
We discussed with UW-Oshkosh staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and UW Oshkosh’s procedures for monitoring the reporting performed by NSC. UW-Oshkosh relies on data from its student information system to compile information to transmit to NSC. UW-Oshkosh also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve. To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023 24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student who withdrew from UW-Oshkosh and two students who graduated from UW‑Oshkosh.
Questioned Costs:
None.
Effect:
UW-Oshkosh did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Oshkosh did not report to NSLDS in a timely manner who had withdrawn from enrollment without notification, we found that UW-Oshkosh indicated that it believed it needed to report to NSLDS only when students withdrew from enrollment and had notified UW-Oshkosh of the withdrawal. As a result, students detected by UW Oshkosh through procedures completed by the financial aid office at the end of each term were not communicated to those staff in the registrar’s office who were responsible for NSLDS reporting.
Second, for the student UW-Oshkosh did not accurately report as graduated within NSLDS, we found that inaccuracies in the reporting of students who had graduated were noted on NSC error reports. However, UW-Oshkosh’s registrar’s office staff did sufficiently review the errors to correct the status in NSLDS.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as communicating those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-710: Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Background:
UW Parkside operates in a highly computerized environment and is responsible for maintaining confidential and sensitive information, such as student data. UW Parkside maintains its own student information system to administer federal student financial assistance programs under the SFA Cluster.
Criteria:
To ensure data processed and stored by UW-Parkside is protected from accidental or intentional misuse or destruction, and to provide proper internal control, information technology (IT) security policies and procedures are necessary. In addition, IT controls should be established to prevent inappropriate or inadvertent access to data. UW-Parkside is responsible for following specific requirements under the Gramm-Leach-Bliley Act (GLBA), which requires entities that administer student financial assistance programs to develop, implement, and maintain safeguards to protect the security, integrity, and confidentiality of student data.
Under GLBA, UW-Parkside is required to authenticate and permit access only to authorized users. Further, UW Board of Regents Policy 25-5 requires that UW-Parkside follow the National Institute of Standards and Technology (NIST) in establishing IT controls. NIST Special Publication (SP) 800-53, Security and Privacy Controls for Information Systems and Organizations, recommends best practices in IT controls related to user access. These best practices include developing a provisioning and deprovisioning process focused on limiting access in a manner that provides the least access based on business need; retaining documentation of provisioning and deprovisioning activities, including records of when such access was added or removed; and performing periodic reviews of access to ensure it remains appropriate.
Condition:
We found UW-Parkside did not have adequate IT controls in place during FY 2023-24 to provision, deprovision, and manage access to its student information system. First, UW-Parkside did not have a formal documented process to provision or deprovision user access to its student information system. Second, UW-Parkside did not maintain a list of provisioned users with access and was unable to generate a report of users provisioned or deprovisioned during FY 2023-24. Third, UW-Parkside did not complete a periodic review of access, which assists in ensuring its provisioning and deprovisioning processes are working as intended. Although failure in any one IT control may be detected by complementary IT controls, UW‑Parkside did not have effective IT controls in any of the three areas. As a result, UW-Parkside was at a higher risk of granting unauthorized access to its student information system.
Context:
We reviewed GLBA requirements, UW System Board of Regents policies, and NIST 800-53 guidance to identify policies and procedures for UW-Parkside’s monitoring of access granted to its student information system. We requested documentation from UW-Parkside to assess compliance with these policies.
Questioned Costs:
None.
Effect:
Ineffective general IT controls may permit controls over systems to operate improperly and may allow noncompliance to occur and not be detected. Weaknesses in IT security policies, procedures, and controls increase the risk that unauthorized or erroneous transactions could be processed or changes made to student data. In addition, failure to provide an appropriate level of protection for its student information system and data increased the risk that personally identifiable information could be accidentally or maliciously exposed.
Cause:
UW-Parkside did not have a formal policy or procedures in place to provision, deprovision, and review access to its student information system. UW-Parkside staff indicated the process for provisioning and deprovisioning access had been informally operated, such as through electronic mail and direct communication and it did not consistently retain documentation of these communications. For example,
UW-Parkside indicated access requests were accepted from a variety of UW-Parkside employees. As a result, UW-Parkside had not assessed whether a user’s access was necessary or otherwise limited the access only to specific information needed or to a specified time period. Finally, UW-Parkside also indicated that prior efforts to improve its provisioning and deprovisioning of user access were not fully completed or implemented, in part, due to staff turnover.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-develop and implement written procedures for provisioning and deprovisioning user access to its student information system, including specifying those who are authorized to request user access and assigning responsibility to staff to assess access requests to restrict the access only to data needed for a specified period of time;
-retain consistent documentation of its provisioning and deprovisioning activities;
-develop and implement written procedures for a review at least annually of access granted to its student information system; and
-complete an assessment of users who currently have access to its student information system and remove those users who no longer require the access.
Finding 2024-711: Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-Madison must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. For students that begin attending classes, but who later withdraw from enrollment, 34 CFR s. 668.22 requires that UW-Madison must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In order not to consider a student to have withdrawn from enrollment under certain circumstances, which permits a student to retain federal financial assistance that otherwise would need to be returned to the federal government, 34 CFR s. 668.22 (a) (2) (ii) provides certain exemptions to students.
Condition:
For four students, we found that UW-Madison did not accurately determine the amount of federal financial assistance it disbursed that should have been returned to the U.S. Department of Education. First, we found that UW-Madison did not return all federal financial assistance it disbursed to two students that did not begin attendance and to one student who only attended one day during FY 2023-24. For these three students, UW-Madison determined it failed to return $16,403 in federal financial assistance it disbursed during FY 2023-24. Second, we found that UW-Madison did not accurately determine the federal financial assistance that should be returned after a student withdrew from enrollment during the summer 2023 term. For this student, UW-Madison incorrectly applied an exemption, which led to UW-Madison failing to return $584 in federal financial assistance to the U.S. Department of Education.
Context:
UW-Madison uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Madison staff its process for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Madison to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. When reviewing the data UW-Madison provided, we noted potential errors in the amount of aid returned for students identified as never attending.
Separately, as part of a UW systemwide sample of 60 students, we selected 6 students who had received federal financial assistance and who withdrew from enrollment from UW-Madison to determine the amount of federal financial assistance those students earned and the related amounts UW-Madison returned to the U.S. Department of Education.
Questioned Costs:
$16,987, Plus an Undetermined Amount
Effect:
UW-Madison did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Madison identified that the errors in determining the amount of the federal financial assistance that should have been returned to the federal government for the four students we identified were manual errors in the withdrawal procedures and calculations completed during and at the end of each term. These errors were not detected by any other review procedures. Although UW-Madison correctly identified the status of the two students who never attended and the need to return all disbursed federal financial assistance, it did not follow through on the actual repayment.
For the student who had an exemption applied, the exemption was incorrectly selected when UW-Madison completed a determination, and the error was not detected in UW-Madison’s review process. UW-Madison indicated that its automated review processes conducted at the end of each term did not specifically address the matters we identified for the four students.
After we identified these errors in the determination of the amount of federal financial assistance to return to the federal government, UW-Madison returned in fall 2024 the unearned federal financial assistance for the three students who never attended or withdrew from enrollment after attending one day. In addition, UW Madison returned the additional $584 in February 2025 for the student who withdrew from enrollment and did not meet the criteria for a withdrawal exemption.
Recommendation:
We recommend the University of Wisconsin-Madison review, update, and implement its procedures to improve the accuracy and follow-through for making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including thoroughly reviewing applied exemptions, and returning federal financial assistance in a timely manner to the federal government.
Finding 2024-703: Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,987, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Background:
UW-River Falls receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-River Falls reported a total of $23.6 million in federal financial assistance under the SFA Cluster. UW-River Falls is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-River Falls must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. Under Volume 5, Chapter 1 of the Federal Student Aid Handbook, when a student begins attendance in at least one course but does not begin attendance in all courses the student was scheduled to attend, the school must determine if it is necessary to recalculate the student’s eligibility for the Pell Grant based on a revised enrollment status and the cost of education pursuant to 34 CFR s. 690.80. If the student withdraws, this recalculation must be performed before determining whether to return federal financial assistance pursuant to 34 CFR s. 668.22.
Condition:
We found that UW-River Falls did not return $16,010 in federal financial assistance for four students that did not begin attendance in all enrolled courses during FY 2023-24. This included two students who never began attendance in any enrolled courses for whom all disbursed federal financial assistance was required to be returned. This also included two students who began at least one course but not all courses for which the students had enrolled. UW-River Falls did not perform the required recalculation of Pell Grant eligibility or an assessment of federal financial assistance it had disbursed that these students had not earned.
Context:
UW-River Falls uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-River Falls the process used for identifying students who did not begin attending all enrolled courses or withdrew from enrollment, and we requested a list of such students during FY 2023-24. UW-River Falls did not have a complete list readily available of students who did not begin attending all enrolled courses.
Questioned Costs:
$16,010, Plus an Undetermined Amount
Effect:
UW-River Falls did not comply with all requirements to return federal financial assistance for students who never attended or did not begin attending all enrolled courses during FY 2023-24.
Cause:
UW-River Falls did not have procedures to identify from its student information system, or other sources, those students for whom it disbursed federal financial assistance, yet the students did not attend at least one course during the term or begin all courses enrolled. Depending on whether a student dropped any of their courses, UW-River Falls indicated that the procedures to evaluate attendance may not have identified all students who would ultimately be determined as never attending for the academic term.
After we requested a list of students who did not begin attending all enrolled courses, UW-River Falls identified two students who did not begin at least one course but for whom it had disbursed federal financial assistance. For the other two students who began at least one course, UW-River Falls completed the required Pell Grant recalculation for the students. UW-River Falls also determined the amount of federal financial assistance to return for all four students, as applicable, to the U.S. Department of Education in September 2024.
Recommendation:
We recommend the University of Wisconsin-River Falls review, update, and implement procedures to:
-identify students after the start of each academic term for whom it disbursed federal financial assistance and the students did not begin all enrolled courses;
-complete required recalculations for Pell Grant eligibility and a determination of federal financial assistance that was not earned by the students, as applicable; and
-return amounts to the federal government in a timely manner.
Finding 2024-704: Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,010, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-River Falls: The University of Wisconsin-River Falls agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Background:
UW-Parkside receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Parkside reported a total of $21.3 million in federal financial assistance under the SFA Cluster. UW-Parkside is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22, requires that UW-Parkside must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW Parkside should be returned to the U.S. Department of Education unless certain conditions are met. In determining whether federal financial assistance was earned by a student, the Federal Student Aid Handbook provides guidance on how to calculate applicable institution charges and academic days under different circumstances.
Condition:
For two of three students we reviewed who withdrew from enrollment during FY 2023-24, UW-Parkside inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Parkside incorrectly accounted for a disbursement that occurred after the student’s withdrawal from enrollment as an amount that was earned by the student for the fall 2023 term. As a result, UW Parkside returned $548 less than what should have been returned to the U.S. Department of Education. For the second student, UW-Parkside incorrectly identified the end date of the spring 2024 term and did not include the correct institutional charges in its determination. As a result, UW-Parkside returned $1,190 less than should have been returned to the U.S. Department of Education.
Context:
UW-Parkside uses a student information system to track activity for students that withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Parkside staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from
UW-Parkside to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 3 students who had received federal financial assistance and withdrew from UW-Parkside to determine the amount of federal financial assistance those students earned and the related amounts UW-Parkside returned to the U.S. Department of Education.
Questioned Costs:
$1,738, Plus an Undetermined Amount
Effect:
UW-Parkside did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Parkside did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal assistance to return. Although UW-Parkside disbursed federal financial assistance later than is typical to one student, the disbursement was not correctly categorized within the calculations completed by UW-Parkside to determine that the entire amount of the federal financial assistance was required to be returned to the federal government.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the students we identified.
Finding 2024-705: Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $1,738, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Background:
UW-Platteville receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Platteville reported a total of $29.1 million in federal financial assistance under the SFA Cluster. UW-Platteville is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Under 34 CFR s. 668.21, UW-Platteville must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. In addition, when a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Platteville must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In determining whether federal financial assistance was earned by a student, Volume 5, Chapter 2 of the Federal Student Aid Handbook specifies how to calculate academic days.
Condition:
For two of the five students we reviewed who never began attendance or who withdrew from enrollment during FY 2023-24, UW-Platteville inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Platteville incorrectly determined the student began attendance because the student attended one day of the fall 2023 term. As a result, UW-Platteville failed to return $24 in federal financial assistance to the U.S. Department of Education. For the second student, UW-Platteville did not exclude a five-day break from its determination of the federal financial assistance amount the student had earned during the fall 2023 term. Although this student had earned all of the federal financial assistance prior to the student’s withdrawal from enrollment, UW-Platteville incorrectly returned $1,226. Because UW-Platteville used the same calculation for all determinations for the fall 2023 term, there may be further errors in the federal financial assistance amounts UW-Platteville determined.
Context:
UW-Platteville uses a student information system to track activity for students who withdraw from enrollment in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Platteville staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Platteville to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 5 students who had received federal financial assistance and who withdrew from UW-Platteville to determine the amount of federal financial assistance those students earned and the related amounts UW-Platteville returned to the U.S. Department of Education.
Questioned Costs:
$24, Plus an Undetermined Amount
Effect:
UW-Platteville did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Platteville did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal financial assistance to return to the federal government. After we identified the error for the student who attended only one day, UW-Platteville returned the additional $24 to the federal government in November 2024. For the fall 2023 term, UW-Platteville changed its fall break from four to five days, which required a change in the number of academic days used in the calculation of federal financial assistance earned when a student withdraws from enrollment. UW-Platteville did not have a process to review the academic calendar for purposes of its return procedures.
Recommendation:
We recommend the University of Wisconsin-Platteville review, update, and implement its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including annually reviewing the academic days used in its determinations.
Finding 2024-706: Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $24, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Platteville: The University of Wisconsin-Platteville agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Background:
UW-Whitewater receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Whitewater reported a total of $58.4 million in federal financial assistance under the SFA Cluster. UW-Whitewater is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Whitewater must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook, the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW-Whitewater is required to be returned to the U.S. Department of Education unless certain conditions are met.
Condition:
UW-Whitewater inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education for one of seven students we reviewed who withdrew from enrollment during FY 2023 24. UW-Whitewater incorrectly accounted for a disbursement to the student that occurred after the date for which UW-Whitewater later identified the student had withdrawn from enrollment as an amount that was earned by the student. As a result, UW-Whitewater failed to return $400 in federal financial assistance to the U.S. Department of Education for the spring 2024 term.
Context:
In order to determine the federal financial assistance a student earned and the amount that must be returned to the U.S. Department of Education for amounts a student did not earn, UW-Whitewater uses a student information system to track activity for students who withdraw. We discussed with UW-Whitewater staff the process used for identifying students who withdrew from enrollment. We also requested information from UW-Whitewater to identify students who withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 7 students who had received federal financial assistance and who withdrew from UW-Whitewater to determine the amount of federal financial assistance those students earned and the related amounts UW-Whitewater returned to the U.S. Department of Education.
Questioned Costs:
$400, Plus an Undetermined Amount
Effect:
UW-Whitewater did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Whitewater did not have adequate procedures to review and ensure its determination of the amount of federal assistance to return was accurate. Although UW-Whitewater disbursed federal financial assistance later than is typical to the student, the disbursement was not correctly categorized within the calculations completed by UW-Whitewater nor was the categorization error detected by other
UW-Whitewater procedures.
Recommendation:
We recommend the University of Wisconsin-Whitewater:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the student we identified.
Finding 2024-707: Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $400, Plus an Undetermined Amount
Type of Finding: Noncompliance
Response from the University of Wisconsin-Whitewater: The University of Wisconsin-Whitewater agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Madison is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to the National Student Loan Data System (NSLDS). Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Madison is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time;
-report the same effective date for a student who withdraws from enrollment as the date used in its determination of whether any federal financial assistance must be returned in accordance with
34 CFR s. 668.22;
-report a student who has completed a program with a status of “graduated” rather than “withdrawn”;
-maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed; and
-maintain the program begin date, which is the date the student first began attending the program being reported, if a student’s program of study has not changed.
Condition:
UW-Madison uses the National Student Clearinghouse (NSC) to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Madison that identify potential errors in UW-Madison’s reporting of student activities. It is the responsibility of UW-Madison to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Madison did not report to NSLDS accurate information for 12 of the 17 students we reviewed. First, UW-Madison did not accurately report a student who withdrew from enrollment without notification in a timely manner. Second, UW-Madison incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment. Third, UW-Madison incorrectly reported the program-level enrollment status effective date for two students. Fourth, UW-Madison incorrectly reported the program begin date for six students. In addition, UW Madison incorrectly reported both the program-level enrollment status effective date and program begin date for two students.
Context:
We discussed with UW-Madison staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Madison relies on data from its student information system to compile information to transmit to NSC. UW-Madison also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student that withdrew from UW-Madison and six students who graduated from UW-Madison. In addition, we selected ten additional UW-Madison students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Madison did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Madison did not report to NSLDS who had withdrawn from enrollment without notification, we found UW-Madison’s enrollment reporting procedures did not assign responsibility for communicating certain information to those staff in the registrar’s office who are responsible for NSLDS reporting. As a result, those students the financial aid office determined had withdrawn from enrollment without notification, and for which it had completed a determination of federal financial assistance the students did not earn, were not known to staff in the registrar’s office for purposes of NSLDS reporting. In addition, UW-Madison indicated that withdrawals from enrollment without notification are identified after the term ends and its student information system did not have a dedicated effective date field in order to automatically identify such student records for the required NSLDS reporting.
Second, for the student UW-Madison did not accurately report as graduated within NSLDS, we found UW‑Madison relied on a NSC process that is intended to simultaneously update a student’s enrollment status in NSLDS when UW-Madison separately updates a student’s degree as completed. UW-Madison did not complete a separate report to ensure the enrollment status for graduated students was accurately reflected in NSLDS. However, in 2022 NSC had published information that indicated reliance solely on NSC’s process may result in the incorrect status being reported under certain circumstances. Although NSC error reports identified that such errors were present, UW-Madison indicated that it did not review these errors until fall 2024 when it began implementing new U.S. Department of Education reporting requirements.
At that time, UW-Madison stated that it identified that it did not consistently and accurately report in NSLDS those students who had graduated. UW-Madison stated that it then began to work with NSC to identify the extent of the reporting inaccuracies.
Third, in 2021 NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW-Madison’s data from its student information system and had communicated error or warning codes to UW-Madison in these areas. However, UW-Madison did not sufficiently review whether the records identified by NSC as potential errors resulted in inaccurate reporting. For example, NSC used warning codes for potential errors in the program-level enrollment status effective dates. As warning codes do not prohibit submission of reporting, UW-Madison did not review the warnings.
Fourth, in 2021 NSC similarly published information on accurately reporting student program begin dates in NSLDS and NSC had also identified instances of potential inaccurate reporting in UW Madison’s data from its student information system. Although NSC had communicated error or warning codes to UW-Madison in these areas, UW-Madison had not sufficiently reviewed whether the records identified by NSC as potential errors resulted in inaccurate reporting until 2023. At that time, UW-Madison indicated that, after reviewing other NSC warnings, it identified that it did not accurately report program begin dates for students. UW-Madison indicated it then began to work to update its student information system data extraction process to identify the correct program begin date for its submissions to NSC. However, it did not implement these changes until after the audit period.
In addition, UW-Madison indicated that it had turnover in staff responsible for NSLDS reporting in 2021, which may have caused UW-Madison to have missed the NSC publications regarding reporting graduated students accurately, new warning codes, and the importance of reviewing certain warning codes to accurately complete NSLDS reporting.
Recommendation:
We recommend the University of Wisconsin-Madison:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as updating its student information system to allow for an automated identification process to communicate those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated and implement separate reporting to the National Student Clearinghouse to accurately report students who graduate;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program-level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program begin dates and update its student information system extraction process to accurately report program begin dates; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-708: Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Background:
UW-Milwaukee receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Milwaukee reported a total of $133.1 million in federal financial assistance under the SFA Cluster. UW-Milwaukee records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Milwaukee is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Milwaukee is required to maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed.
Condition:
UW-Milwaukee uses NSC to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Milwaukee that identify potential errors in UW-Milwaukee’s reporting of student activities through NSC. These errors are the responsibility of UW-Milwaukee to resolve to ensure its submissions to NSLDS are accurate and complete.
UW-Milwaukee did not report to NSLDS accurate information for the program level enrollment status effective date for five students we reviewed. In addition, based on how information from its student information system is extracted for student reporting to NSLDS, we found that the reporting inaccuracy extended to other UW-Milwaukee students.
Context:
We discussed with UW-Milwaukee staff its procedures for identifying student enrollment status changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Milwaukee relies on data from its student information system to compile information to transmit to NSC. UW-Milwaukee also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included two students who withdrew from UW-Milwaukee and four students who graduated from UW- Milwaukee. In addition, we selected ten additional UW-Milwaukee students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Milwaukee did not comply with requirements to accurately report certain student enrollment status changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
In 2021, NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW- Milwaukee’s data from its student information system and had communicated error or warning codes to UW-Milwaukee in these areas. UW-Milwaukee staff indicated that they were aware that NSC error reports included warnings to identify potential inaccurate reporting of program level enrollment status effective dates and that the errors were a known issue for Peoplesoft-based student information systems. However, UW-Milwaukee chose not to use an all-record update feature that was available to correct the program-level enrollment status effective dates for all student records simultaneously due to the risk that other reporting inaccuracies could result from the action. Further, UW-Milwaukee staff indicated that they were not aware that specific guidance on the program-level enrollment status effective date had been updated to reflect that corrections should be made to fully comply with NSLDS reporting requirements.
Recommendation:
We recommend the University of Wisconsin-Milwaukee:
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates; and
-report changes in student enrollment accurately, completely, and in a timely manner for all student changes that require reporting.
Finding 2024-709: Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Milwaukee: The University of Wisconsin-Milwaukee agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Background:
UW-Oshkosh receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Oshkosh reported a total of $45.3 million in federal financial assistance under the SFA Cluster. UW-Oshkosh records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Oshkosh is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Oshkosh is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time; and
-report a student who has completed a program with a status of “graduated” rather than “withdrawn.”
Condition:
UW-Oshkosh uses NSC to facilitate the enrollment reporting in NSLDS. NSC provides error reports to UW-Oshkosh that identify potential errors in UW Oshkosh’s reporting of student activities. It is the responsibility of UW-Oshkosh to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Oshkosh did not report to NSLDS accurate information for two of the three students we reviewed.
First, UW-Oshkosh did not report in a timely manner one student who withdrew from enrollment without notification. Second, UW-Oshkosh incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment.
Context:
We discussed with UW-Oshkosh staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and UW Oshkosh’s procedures for monitoring the reporting performed by NSC. UW-Oshkosh relies on data from its student information system to compile information to transmit to NSC. UW-Oshkosh also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve. To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023 24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student who withdrew from UW-Oshkosh and two students who graduated from UW‑Oshkosh.
Questioned Costs:
None.
Effect:
UW-Oshkosh did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Oshkosh did not report to NSLDS in a timely manner who had withdrawn from enrollment without notification, we found that UW-Oshkosh indicated that it believed it needed to report to NSLDS only when students withdrew from enrollment and had notified UW-Oshkosh of the withdrawal. As a result, students detected by UW Oshkosh through procedures completed by the financial aid office at the end of each term were not communicated to those staff in the registrar’s office who were responsible for NSLDS reporting.
Second, for the student UW-Oshkosh did not accurately report as graduated within NSLDS, we found that inaccuracies in the reporting of students who had graduated were noted on NSC error reports. However, UW-Oshkosh’s registrar’s office staff did sufficiently review the errors to correct the status in NSLDS.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as communicating those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-710: Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Background:
UW Parkside operates in a highly computerized environment and is responsible for maintaining confidential and sensitive information, such as student data. UW Parkside maintains its own student information system to administer federal student financial assistance programs under the SFA Cluster.
Criteria:
To ensure data processed and stored by UW-Parkside is protected from accidental or intentional misuse or destruction, and to provide proper internal control, information technology (IT) security policies and procedures are necessary. In addition, IT controls should be established to prevent inappropriate or inadvertent access to data. UW-Parkside is responsible for following specific requirements under the Gramm-Leach-Bliley Act (GLBA), which requires entities that administer student financial assistance programs to develop, implement, and maintain safeguards to protect the security, integrity, and confidentiality of student data.
Under GLBA, UW-Parkside is required to authenticate and permit access only to authorized users. Further, UW Board of Regents Policy 25-5 requires that UW-Parkside follow the National Institute of Standards and Technology (NIST) in establishing IT controls. NIST Special Publication (SP) 800-53, Security and Privacy Controls for Information Systems and Organizations, recommends best practices in IT controls related to user access. These best practices include developing a provisioning and deprovisioning process focused on limiting access in a manner that provides the least access based on business need; retaining documentation of provisioning and deprovisioning activities, including records of when such access was added or removed; and performing periodic reviews of access to ensure it remains appropriate.
Condition:
We found UW-Parkside did not have adequate IT controls in place during FY 2023-24 to provision, deprovision, and manage access to its student information system. First, UW-Parkside did not have a formal documented process to provision or deprovision user access to its student information system. Second, UW-Parkside did not maintain a list of provisioned users with access and was unable to generate a report of users provisioned or deprovisioned during FY 2023-24. Third, UW-Parkside did not complete a periodic review of access, which assists in ensuring its provisioning and deprovisioning processes are working as intended. Although failure in any one IT control may be detected by complementary IT controls, UW‑Parkside did not have effective IT controls in any of the three areas. As a result, UW-Parkside was at a higher risk of granting unauthorized access to its student information system.
Context:
We reviewed GLBA requirements, UW System Board of Regents policies, and NIST 800-53 guidance to identify policies and procedures for UW-Parkside’s monitoring of access granted to its student information system. We requested documentation from UW-Parkside to assess compliance with these policies.
Questioned Costs:
None.
Effect:
Ineffective general IT controls may permit controls over systems to operate improperly and may allow noncompliance to occur and not be detected. Weaknesses in IT security policies, procedures, and controls increase the risk that unauthorized or erroneous transactions could be processed or changes made to student data. In addition, failure to provide an appropriate level of protection for its student information system and data increased the risk that personally identifiable information could be accidentally or maliciously exposed.
Cause:
UW-Parkside did not have a formal policy or procedures in place to provision, deprovision, and review access to its student information system. UW-Parkside staff indicated the process for provisioning and deprovisioning access had been informally operated, such as through electronic mail and direct communication and it did not consistently retain documentation of these communications. For example,
UW-Parkside indicated access requests were accepted from a variety of UW-Parkside employees. As a result, UW-Parkside had not assessed whether a user’s access was necessary or otherwise limited the access only to specific information needed or to a specified time period. Finally, UW-Parkside also indicated that prior efforts to improve its provisioning and deprovisioning of user access were not fully completed or implemented, in part, due to staff turnover.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-develop and implement written procedures for provisioning and deprovisioning user access to its student information system, including specifying those who are authorized to request user access and assigning responsibility to staff to assess access requests to restrict the access only to data needed for a specified period of time;
-retain consistent documentation of its provisioning and deprovisioning activities;
-develop and implement written procedures for a review at least annually of access granted to its student information system; and
-complete an assessment of users who currently have access to its student information system and remove those users who no longer require the access.
Finding 2024-711: Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-Madison must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. For students that begin attending classes, but who later withdraw from enrollment, 34 CFR s. 668.22 requires that UW-Madison must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In order not to consider a student to have withdrawn from enrollment under certain circumstances, which permits a student to retain federal financial assistance that otherwise would need to be returned to the federal government, 34 CFR s. 668.22 (a) (2) (ii) provides certain exemptions to students.
Condition:
For four students, we found that UW-Madison did not accurately determine the amount of federal financial assistance it disbursed that should have been returned to the U.S. Department of Education. First, we found that UW-Madison did not return all federal financial assistance it disbursed to two students that did not begin attendance and to one student who only attended one day during FY 2023-24. For these three students, UW-Madison determined it failed to return $16,403 in federal financial assistance it disbursed during FY 2023-24. Second, we found that UW-Madison did not accurately determine the federal financial assistance that should be returned after a student withdrew from enrollment during the summer 2023 term. For this student, UW-Madison incorrectly applied an exemption, which led to UW-Madison failing to return $584 in federal financial assistance to the U.S. Department of Education.
Context:
UW-Madison uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Madison staff its process for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Madison to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. When reviewing the data UW-Madison provided, we noted potential errors in the amount of aid returned for students identified as never attending.
Separately, as part of a UW systemwide sample of 60 students, we selected 6 students who had received federal financial assistance and who withdrew from enrollment from UW-Madison to determine the amount of federal financial assistance those students earned and the related amounts UW-Madison returned to the U.S. Department of Education.
Questioned Costs:
$16,987, Plus an Undetermined Amount
Effect:
UW-Madison did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Madison identified that the errors in determining the amount of the federal financial assistance that should have been returned to the federal government for the four students we identified were manual errors in the withdrawal procedures and calculations completed during and at the end of each term. These errors were not detected by any other review procedures. Although UW-Madison correctly identified the status of the two students who never attended and the need to return all disbursed federal financial assistance, it did not follow through on the actual repayment.
For the student who had an exemption applied, the exemption was incorrectly selected when UW-Madison completed a determination, and the error was not detected in UW-Madison’s review process. UW-Madison indicated that its automated review processes conducted at the end of each term did not specifically address the matters we identified for the four students.
After we identified these errors in the determination of the amount of federal financial assistance to return to the federal government, UW-Madison returned in fall 2024 the unearned federal financial assistance for the three students who never attended or withdrew from enrollment after attending one day. In addition, UW Madison returned the additional $584 in February 2025 for the student who withdrew from enrollment and did not meet the criteria for a withdrawal exemption.
Recommendation:
We recommend the University of Wisconsin-Madison review, update, and implement its procedures to improve the accuracy and follow-through for making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including thoroughly reviewing applied exemptions, and returning federal financial assistance in a timely manner to the federal government.
Finding 2024-703: Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,987, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Background:
UW-River Falls receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-River Falls reported a total of $23.6 million in federal financial assistance under the SFA Cluster. UW-River Falls is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-River Falls must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. Under Volume 5, Chapter 1 of the Federal Student Aid Handbook, when a student begins attendance in at least one course but does not begin attendance in all courses the student was scheduled to attend, the school must determine if it is necessary to recalculate the student’s eligibility for the Pell Grant based on a revised enrollment status and the cost of education pursuant to 34 CFR s. 690.80. If the student withdraws, this recalculation must be performed before determining whether to return federal financial assistance pursuant to 34 CFR s. 668.22.
Condition:
We found that UW-River Falls did not return $16,010 in federal financial assistance for four students that did not begin attendance in all enrolled courses during FY 2023-24. This included two students who never began attendance in any enrolled courses for whom all disbursed federal financial assistance was required to be returned. This also included two students who began at least one course but not all courses for which the students had enrolled. UW-River Falls did not perform the required recalculation of Pell Grant eligibility or an assessment of federal financial assistance it had disbursed that these students had not earned.
Context:
UW-River Falls uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-River Falls the process used for identifying students who did not begin attending all enrolled courses or withdrew from enrollment, and we requested a list of such students during FY 2023-24. UW-River Falls did not have a complete list readily available of students who did not begin attending all enrolled courses.
Questioned Costs:
$16,010, Plus an Undetermined Amount
Effect:
UW-River Falls did not comply with all requirements to return federal financial assistance for students who never attended or did not begin attending all enrolled courses during FY 2023-24.
Cause:
UW-River Falls did not have procedures to identify from its student information system, or other sources, those students for whom it disbursed federal financial assistance, yet the students did not attend at least one course during the term or begin all courses enrolled. Depending on whether a student dropped any of their courses, UW-River Falls indicated that the procedures to evaluate attendance may not have identified all students who would ultimately be determined as never attending for the academic term.
After we requested a list of students who did not begin attending all enrolled courses, UW-River Falls identified two students who did not begin at least one course but for whom it had disbursed federal financial assistance. For the other two students who began at least one course, UW-River Falls completed the required Pell Grant recalculation for the students. UW-River Falls also determined the amount of federal financial assistance to return for all four students, as applicable, to the U.S. Department of Education in September 2024.
Recommendation:
We recommend the University of Wisconsin-River Falls review, update, and implement procedures to:
-identify students after the start of each academic term for whom it disbursed federal financial assistance and the students did not begin all enrolled courses;
-complete required recalculations for Pell Grant eligibility and a determination of federal financial assistance that was not earned by the students, as applicable; and
-return amounts to the federal government in a timely manner.
Finding 2024-704: Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,010, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-River Falls: The University of Wisconsin-River Falls agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Background:
UW-Parkside receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Parkside reported a total of $21.3 million in federal financial assistance under the SFA Cluster. UW-Parkside is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22, requires that UW-Parkside must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW Parkside should be returned to the U.S. Department of Education unless certain conditions are met. In determining whether federal financial assistance was earned by a student, the Federal Student Aid Handbook provides guidance on how to calculate applicable institution charges and academic days under different circumstances.
Condition:
For two of three students we reviewed who withdrew from enrollment during FY 2023-24, UW-Parkside inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Parkside incorrectly accounted for a disbursement that occurred after the student’s withdrawal from enrollment as an amount that was earned by the student for the fall 2023 term. As a result, UW Parkside returned $548 less than what should have been returned to the U.S. Department of Education. For the second student, UW-Parkside incorrectly identified the end date of the spring 2024 term and did not include the correct institutional charges in its determination. As a result, UW-Parkside returned $1,190 less than should have been returned to the U.S. Department of Education.
Context:
UW-Parkside uses a student information system to track activity for students that withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Parkside staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from
UW-Parkside to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 3 students who had received federal financial assistance and withdrew from UW-Parkside to determine the amount of federal financial assistance those students earned and the related amounts UW-Parkside returned to the U.S. Department of Education.
Questioned Costs:
$1,738, Plus an Undetermined Amount
Effect:
UW-Parkside did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Parkside did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal assistance to return. Although UW-Parkside disbursed federal financial assistance later than is typical to one student, the disbursement was not correctly categorized within the calculations completed by UW-Parkside to determine that the entire amount of the federal financial assistance was required to be returned to the federal government.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the students we identified.
Finding 2024-705: Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $1,738, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Background:
UW-Platteville receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Platteville reported a total of $29.1 million in federal financial assistance under the SFA Cluster. UW-Platteville is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Under 34 CFR s. 668.21, UW-Platteville must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. In addition, when a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Platteville must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In determining whether federal financial assistance was earned by a student, Volume 5, Chapter 2 of the Federal Student Aid Handbook specifies how to calculate academic days.
Condition:
For two of the five students we reviewed who never began attendance or who withdrew from enrollment during FY 2023-24, UW-Platteville inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Platteville incorrectly determined the student began attendance because the student attended one day of the fall 2023 term. As a result, UW-Platteville failed to return $24 in federal financial assistance to the U.S. Department of Education. For the second student, UW-Platteville did not exclude a five-day break from its determination of the federal financial assistance amount the student had earned during the fall 2023 term. Although this student had earned all of the federal financial assistance prior to the student’s withdrawal from enrollment, UW-Platteville incorrectly returned $1,226. Because UW-Platteville used the same calculation for all determinations for the fall 2023 term, there may be further errors in the federal financial assistance amounts UW-Platteville determined.
Context:
UW-Platteville uses a student information system to track activity for students who withdraw from enrollment in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Platteville staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Platteville to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 5 students who had received federal financial assistance and who withdrew from UW-Platteville to determine the amount of federal financial assistance those students earned and the related amounts UW-Platteville returned to the U.S. Department of Education.
Questioned Costs:
$24, Plus an Undetermined Amount
Effect:
UW-Platteville did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Platteville did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal financial assistance to return to the federal government. After we identified the error for the student who attended only one day, UW-Platteville returned the additional $24 to the federal government in November 2024. For the fall 2023 term, UW-Platteville changed its fall break from four to five days, which required a change in the number of academic days used in the calculation of federal financial assistance earned when a student withdraws from enrollment. UW-Platteville did not have a process to review the academic calendar for purposes of its return procedures.
Recommendation:
We recommend the University of Wisconsin-Platteville review, update, and implement its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including annually reviewing the academic days used in its determinations.
Finding 2024-706: Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $24, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Platteville: The University of Wisconsin-Platteville agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Background:
UW-Whitewater receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Whitewater reported a total of $58.4 million in federal financial assistance under the SFA Cluster. UW-Whitewater is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Whitewater must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook, the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW-Whitewater is required to be returned to the U.S. Department of Education unless certain conditions are met.
Condition:
UW-Whitewater inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education for one of seven students we reviewed who withdrew from enrollment during FY 2023 24. UW-Whitewater incorrectly accounted for a disbursement to the student that occurred after the date for which UW-Whitewater later identified the student had withdrawn from enrollment as an amount that was earned by the student. As a result, UW-Whitewater failed to return $400 in federal financial assistance to the U.S. Department of Education for the spring 2024 term.
Context:
In order to determine the federal financial assistance a student earned and the amount that must be returned to the U.S. Department of Education for amounts a student did not earn, UW-Whitewater uses a student information system to track activity for students who withdraw. We discussed with UW-Whitewater staff the process used for identifying students who withdrew from enrollment. We also requested information from UW-Whitewater to identify students who withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 7 students who had received federal financial assistance and who withdrew from UW-Whitewater to determine the amount of federal financial assistance those students earned and the related amounts UW-Whitewater returned to the U.S. Department of Education.
Questioned Costs:
$400, Plus an Undetermined Amount
Effect:
UW-Whitewater did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Whitewater did not have adequate procedures to review and ensure its determination of the amount of federal assistance to return was accurate. Although UW-Whitewater disbursed federal financial assistance later than is typical to the student, the disbursement was not correctly categorized within the calculations completed by UW-Whitewater nor was the categorization error detected by other
UW-Whitewater procedures.
Recommendation:
We recommend the University of Wisconsin-Whitewater:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the student we identified.
Finding 2024-707: Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $400, Plus an Undetermined Amount
Type of Finding: Noncompliance
Response from the University of Wisconsin-Whitewater: The University of Wisconsin-Whitewater agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Madison is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to the National Student Loan Data System (NSLDS). Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Madison is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time;
-report the same effective date for a student who withdraws from enrollment as the date used in its determination of whether any federal financial assistance must be returned in accordance with
34 CFR s. 668.22;
-report a student who has completed a program with a status of “graduated” rather than “withdrawn”;
-maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed; and
-maintain the program begin date, which is the date the student first began attending the program being reported, if a student’s program of study has not changed.
Condition:
UW-Madison uses the National Student Clearinghouse (NSC) to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Madison that identify potential errors in UW-Madison’s reporting of student activities. It is the responsibility of UW-Madison to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Madison did not report to NSLDS accurate information for 12 of the 17 students we reviewed. First, UW-Madison did not accurately report a student who withdrew from enrollment without notification in a timely manner. Second, UW-Madison incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment. Third, UW-Madison incorrectly reported the program-level enrollment status effective date for two students. Fourth, UW-Madison incorrectly reported the program begin date for six students. In addition, UW Madison incorrectly reported both the program-level enrollment status effective date and program begin date for two students.
Context:
We discussed with UW-Madison staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Madison relies on data from its student information system to compile information to transmit to NSC. UW-Madison also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student that withdrew from UW-Madison and six students who graduated from UW-Madison. In addition, we selected ten additional UW-Madison students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Madison did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Madison did not report to NSLDS who had withdrawn from enrollment without notification, we found UW-Madison’s enrollment reporting procedures did not assign responsibility for communicating certain information to those staff in the registrar’s office who are responsible for NSLDS reporting. As a result, those students the financial aid office determined had withdrawn from enrollment without notification, and for which it had completed a determination of federal financial assistance the students did not earn, were not known to staff in the registrar’s office for purposes of NSLDS reporting. In addition, UW-Madison indicated that withdrawals from enrollment without notification are identified after the term ends and its student information system did not have a dedicated effective date field in order to automatically identify such student records for the required NSLDS reporting.
Second, for the student UW-Madison did not accurately report as graduated within NSLDS, we found UW‑Madison relied on a NSC process that is intended to simultaneously update a student’s enrollment status in NSLDS when UW-Madison separately updates a student’s degree as completed. UW-Madison did not complete a separate report to ensure the enrollment status for graduated students was accurately reflected in NSLDS. However, in 2022 NSC had published information that indicated reliance solely on NSC’s process may result in the incorrect status being reported under certain circumstances. Although NSC error reports identified that such errors were present, UW-Madison indicated that it did not review these errors until fall 2024 when it began implementing new U.S. Department of Education reporting requirements.
At that time, UW-Madison stated that it identified that it did not consistently and accurately report in NSLDS those students who had graduated. UW-Madison stated that it then began to work with NSC to identify the extent of the reporting inaccuracies.
Third, in 2021 NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW-Madison’s data from its student information system and had communicated error or warning codes to UW-Madison in these areas. However, UW-Madison did not sufficiently review whether the records identified by NSC as potential errors resulted in inaccurate reporting. For example, NSC used warning codes for potential errors in the program-level enrollment status effective dates. As warning codes do not prohibit submission of reporting, UW-Madison did not review the warnings.
Fourth, in 2021 NSC similarly published information on accurately reporting student program begin dates in NSLDS and NSC had also identified instances of potential inaccurate reporting in UW Madison’s data from its student information system. Although NSC had communicated error or warning codes to UW-Madison in these areas, UW-Madison had not sufficiently reviewed whether the records identified by NSC as potential errors resulted in inaccurate reporting until 2023. At that time, UW-Madison indicated that, after reviewing other NSC warnings, it identified that it did not accurately report program begin dates for students. UW-Madison indicated it then began to work to update its student information system data extraction process to identify the correct program begin date for its submissions to NSC. However, it did not implement these changes until after the audit period.
In addition, UW-Madison indicated that it had turnover in staff responsible for NSLDS reporting in 2021, which may have caused UW-Madison to have missed the NSC publications regarding reporting graduated students accurately, new warning codes, and the importance of reviewing certain warning codes to accurately complete NSLDS reporting.
Recommendation:
We recommend the University of Wisconsin-Madison:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as updating its student information system to allow for an automated identification process to communicate those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated and implement separate reporting to the National Student Clearinghouse to accurately report students who graduate;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program-level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program begin dates and update its student information system extraction process to accurately report program begin dates; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-708: Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Background:
UW-Milwaukee receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Milwaukee reported a total of $133.1 million in federal financial assistance under the SFA Cluster. UW-Milwaukee records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Milwaukee is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Milwaukee is required to maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed.
Condition:
UW-Milwaukee uses NSC to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Milwaukee that identify potential errors in UW-Milwaukee’s reporting of student activities through NSC. These errors are the responsibility of UW-Milwaukee to resolve to ensure its submissions to NSLDS are accurate and complete.
UW-Milwaukee did not report to NSLDS accurate information for the program level enrollment status effective date for five students we reviewed. In addition, based on how information from its student information system is extracted for student reporting to NSLDS, we found that the reporting inaccuracy extended to other UW-Milwaukee students.
Context:
We discussed with UW-Milwaukee staff its procedures for identifying student enrollment status changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Milwaukee relies on data from its student information system to compile information to transmit to NSC. UW-Milwaukee also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included two students who withdrew from UW-Milwaukee and four students who graduated from UW- Milwaukee. In addition, we selected ten additional UW-Milwaukee students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Milwaukee did not comply with requirements to accurately report certain student enrollment status changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
In 2021, NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW- Milwaukee’s data from its student information system and had communicated error or warning codes to UW-Milwaukee in these areas. UW-Milwaukee staff indicated that they were aware that NSC error reports included warnings to identify potential inaccurate reporting of program level enrollment status effective dates and that the errors were a known issue for Peoplesoft-based student information systems. However, UW-Milwaukee chose not to use an all-record update feature that was available to correct the program-level enrollment status effective dates for all student records simultaneously due to the risk that other reporting inaccuracies could result from the action. Further, UW-Milwaukee staff indicated that they were not aware that specific guidance on the program-level enrollment status effective date had been updated to reflect that corrections should be made to fully comply with NSLDS reporting requirements.
Recommendation:
We recommend the University of Wisconsin-Milwaukee:
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates; and
-report changes in student enrollment accurately, completely, and in a timely manner for all student changes that require reporting.
Finding 2024-709: Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Milwaukee: The University of Wisconsin-Milwaukee agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Background:
UW-Oshkosh receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Oshkosh reported a total of $45.3 million in federal financial assistance under the SFA Cluster. UW-Oshkosh records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Oshkosh is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Oshkosh is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time; and
-report a student who has completed a program with a status of “graduated” rather than “withdrawn.”
Condition:
UW-Oshkosh uses NSC to facilitate the enrollment reporting in NSLDS. NSC provides error reports to UW-Oshkosh that identify potential errors in UW Oshkosh’s reporting of student activities. It is the responsibility of UW-Oshkosh to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Oshkosh did not report to NSLDS accurate information for two of the three students we reviewed.
First, UW-Oshkosh did not report in a timely manner one student who withdrew from enrollment without notification. Second, UW-Oshkosh incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment.
Context:
We discussed with UW-Oshkosh staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and UW Oshkosh’s procedures for monitoring the reporting performed by NSC. UW-Oshkosh relies on data from its student information system to compile information to transmit to NSC. UW-Oshkosh also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve. To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023 24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student who withdrew from UW-Oshkosh and two students who graduated from UW‑Oshkosh.
Questioned Costs:
None.
Effect:
UW-Oshkosh did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Oshkosh did not report to NSLDS in a timely manner who had withdrawn from enrollment without notification, we found that UW-Oshkosh indicated that it believed it needed to report to NSLDS only when students withdrew from enrollment and had notified UW-Oshkosh of the withdrawal. As a result, students detected by UW Oshkosh through procedures completed by the financial aid office at the end of each term were not communicated to those staff in the registrar’s office who were responsible for NSLDS reporting.
Second, for the student UW-Oshkosh did not accurately report as graduated within NSLDS, we found that inaccuracies in the reporting of students who had graduated were noted on NSC error reports. However, UW-Oshkosh’s registrar’s office staff did sufficiently review the errors to correct the status in NSLDS.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as communicating those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-710: Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Background:
UW Parkside operates in a highly computerized environment and is responsible for maintaining confidential and sensitive information, such as student data. UW Parkside maintains its own student information system to administer federal student financial assistance programs under the SFA Cluster.
Criteria:
To ensure data processed and stored by UW-Parkside is protected from accidental or intentional misuse or destruction, and to provide proper internal control, information technology (IT) security policies and procedures are necessary. In addition, IT controls should be established to prevent inappropriate or inadvertent access to data. UW-Parkside is responsible for following specific requirements under the Gramm-Leach-Bliley Act (GLBA), which requires entities that administer student financial assistance programs to develop, implement, and maintain safeguards to protect the security, integrity, and confidentiality of student data.
Under GLBA, UW-Parkside is required to authenticate and permit access only to authorized users. Further, UW Board of Regents Policy 25-5 requires that UW-Parkside follow the National Institute of Standards and Technology (NIST) in establishing IT controls. NIST Special Publication (SP) 800-53, Security and Privacy Controls for Information Systems and Organizations, recommends best practices in IT controls related to user access. These best practices include developing a provisioning and deprovisioning process focused on limiting access in a manner that provides the least access based on business need; retaining documentation of provisioning and deprovisioning activities, including records of when such access was added or removed; and performing periodic reviews of access to ensure it remains appropriate.
Condition:
We found UW-Parkside did not have adequate IT controls in place during FY 2023-24 to provision, deprovision, and manage access to its student information system. First, UW-Parkside did not have a formal documented process to provision or deprovision user access to its student information system. Second, UW-Parkside did not maintain a list of provisioned users with access and was unable to generate a report of users provisioned or deprovisioned during FY 2023-24. Third, UW-Parkside did not complete a periodic review of access, which assists in ensuring its provisioning and deprovisioning processes are working as intended. Although failure in any one IT control may be detected by complementary IT controls, UW‑Parkside did not have effective IT controls in any of the three areas. As a result, UW-Parkside was at a higher risk of granting unauthorized access to its student information system.
Context:
We reviewed GLBA requirements, UW System Board of Regents policies, and NIST 800-53 guidance to identify policies and procedures for UW-Parkside’s monitoring of access granted to its student information system. We requested documentation from UW-Parkside to assess compliance with these policies.
Questioned Costs:
None.
Effect:
Ineffective general IT controls may permit controls over systems to operate improperly and may allow noncompliance to occur and not be detected. Weaknesses in IT security policies, procedures, and controls increase the risk that unauthorized or erroneous transactions could be processed or changes made to student data. In addition, failure to provide an appropriate level of protection for its student information system and data increased the risk that personally identifiable information could be accidentally or maliciously exposed.
Cause:
UW-Parkside did not have a formal policy or procedures in place to provision, deprovision, and review access to its student information system. UW-Parkside staff indicated the process for provisioning and deprovisioning access had been informally operated, such as through electronic mail and direct communication and it did not consistently retain documentation of these communications. For example,
UW-Parkside indicated access requests were accepted from a variety of UW-Parkside employees. As a result, UW-Parkside had not assessed whether a user’s access was necessary or otherwise limited the access only to specific information needed or to a specified time period. Finally, UW-Parkside also indicated that prior efforts to improve its provisioning and deprovisioning of user access were not fully completed or implemented, in part, due to staff turnover.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-develop and implement written procedures for provisioning and deprovisioning user access to its student information system, including specifying those who are authorized to request user access and assigning responsibility to staff to assess access requests to restrict the access only to data needed for a specified period of time;
-retain consistent documentation of its provisioning and deprovisioning activities;
-develop and implement written procedures for a review at least annually of access granted to its student information system; and
-complete an assessment of users who currently have access to its student information system and remove those users who no longer require the access.
Finding 2024-711: Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-Madison must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. For students that begin attending classes, but who later withdraw from enrollment, 34 CFR s. 668.22 requires that UW-Madison must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In order not to consider a student to have withdrawn from enrollment under certain circumstances, which permits a student to retain federal financial assistance that otherwise would need to be returned to the federal government, 34 CFR s. 668.22 (a) (2) (ii) provides certain exemptions to students.
Condition:
For four students, we found that UW-Madison did not accurately determine the amount of federal financial assistance it disbursed that should have been returned to the U.S. Department of Education. First, we found that UW-Madison did not return all federal financial assistance it disbursed to two students that did not begin attendance and to one student who only attended one day during FY 2023-24. For these three students, UW-Madison determined it failed to return $16,403 in federal financial assistance it disbursed during FY 2023-24. Second, we found that UW-Madison did not accurately determine the federal financial assistance that should be returned after a student withdrew from enrollment during the summer 2023 term. For this student, UW-Madison incorrectly applied an exemption, which led to UW-Madison failing to return $584 in federal financial assistance to the U.S. Department of Education.
Context:
UW-Madison uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Madison staff its process for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Madison to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. When reviewing the data UW-Madison provided, we noted potential errors in the amount of aid returned for students identified as never attending.
Separately, as part of a UW systemwide sample of 60 students, we selected 6 students who had received federal financial assistance and who withdrew from enrollment from UW-Madison to determine the amount of federal financial assistance those students earned and the related amounts UW-Madison returned to the U.S. Department of Education.
Questioned Costs:
$16,987, Plus an Undetermined Amount
Effect:
UW-Madison did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Madison identified that the errors in determining the amount of the federal financial assistance that should have been returned to the federal government for the four students we identified were manual errors in the withdrawal procedures and calculations completed during and at the end of each term. These errors were not detected by any other review procedures. Although UW-Madison correctly identified the status of the two students who never attended and the need to return all disbursed federal financial assistance, it did not follow through on the actual repayment.
For the student who had an exemption applied, the exemption was incorrectly selected when UW-Madison completed a determination, and the error was not detected in UW-Madison’s review process. UW-Madison indicated that its automated review processes conducted at the end of each term did not specifically address the matters we identified for the four students.
After we identified these errors in the determination of the amount of federal financial assistance to return to the federal government, UW-Madison returned in fall 2024 the unearned federal financial assistance for the three students who never attended or withdrew from enrollment after attending one day. In addition, UW Madison returned the additional $584 in February 2025 for the student who withdrew from enrollment and did not meet the criteria for a withdrawal exemption.
Recommendation:
We recommend the University of Wisconsin-Madison review, update, and implement its procedures to improve the accuracy and follow-through for making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including thoroughly reviewing applied exemptions, and returning federal financial assistance in a timely manner to the federal government.
Finding 2024-703: Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,987, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Background:
UW-River Falls receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-River Falls reported a total of $23.6 million in federal financial assistance under the SFA Cluster. UW-River Falls is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-River Falls must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. Under Volume 5, Chapter 1 of the Federal Student Aid Handbook, when a student begins attendance in at least one course but does not begin attendance in all courses the student was scheduled to attend, the school must determine if it is necessary to recalculate the student’s eligibility for the Pell Grant based on a revised enrollment status and the cost of education pursuant to 34 CFR s. 690.80. If the student withdraws, this recalculation must be performed before determining whether to return federal financial assistance pursuant to 34 CFR s. 668.22.
Condition:
We found that UW-River Falls did not return $16,010 in federal financial assistance for four students that did not begin attendance in all enrolled courses during FY 2023-24. This included two students who never began attendance in any enrolled courses for whom all disbursed federal financial assistance was required to be returned. This also included two students who began at least one course but not all courses for which the students had enrolled. UW-River Falls did not perform the required recalculation of Pell Grant eligibility or an assessment of federal financial assistance it had disbursed that these students had not earned.
Context:
UW-River Falls uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-River Falls the process used for identifying students who did not begin attending all enrolled courses or withdrew from enrollment, and we requested a list of such students during FY 2023-24. UW-River Falls did not have a complete list readily available of students who did not begin attending all enrolled courses.
Questioned Costs:
$16,010, Plus an Undetermined Amount
Effect:
UW-River Falls did not comply with all requirements to return federal financial assistance for students who never attended or did not begin attending all enrolled courses during FY 2023-24.
Cause:
UW-River Falls did not have procedures to identify from its student information system, or other sources, those students for whom it disbursed federal financial assistance, yet the students did not attend at least one course during the term or begin all courses enrolled. Depending on whether a student dropped any of their courses, UW-River Falls indicated that the procedures to evaluate attendance may not have identified all students who would ultimately be determined as never attending for the academic term.
After we requested a list of students who did not begin attending all enrolled courses, UW-River Falls identified two students who did not begin at least one course but for whom it had disbursed federal financial assistance. For the other two students who began at least one course, UW-River Falls completed the required Pell Grant recalculation for the students. UW-River Falls also determined the amount of federal financial assistance to return for all four students, as applicable, to the U.S. Department of Education in September 2024.
Recommendation:
We recommend the University of Wisconsin-River Falls review, update, and implement procedures to:
-identify students after the start of each academic term for whom it disbursed federal financial assistance and the students did not begin all enrolled courses;
-complete required recalculations for Pell Grant eligibility and a determination of federal financial assistance that was not earned by the students, as applicable; and
-return amounts to the federal government in a timely manner.
Finding 2024-704: Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,010, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-River Falls: The University of Wisconsin-River Falls agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Background:
UW-Parkside receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Parkside reported a total of $21.3 million in federal financial assistance under the SFA Cluster. UW-Parkside is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22, requires that UW-Parkside must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW Parkside should be returned to the U.S. Department of Education unless certain conditions are met. In determining whether federal financial assistance was earned by a student, the Federal Student Aid Handbook provides guidance on how to calculate applicable institution charges and academic days under different circumstances.
Condition:
For two of three students we reviewed who withdrew from enrollment during FY 2023-24, UW-Parkside inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Parkside incorrectly accounted for a disbursement that occurred after the student’s withdrawal from enrollment as an amount that was earned by the student for the fall 2023 term. As a result, UW Parkside returned $548 less than what should have been returned to the U.S. Department of Education. For the second student, UW-Parkside incorrectly identified the end date of the spring 2024 term and did not include the correct institutional charges in its determination. As a result, UW-Parkside returned $1,190 less than should have been returned to the U.S. Department of Education.
Context:
UW-Parkside uses a student information system to track activity for students that withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Parkside staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from
UW-Parkside to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 3 students who had received federal financial assistance and withdrew from UW-Parkside to determine the amount of federal financial assistance those students earned and the related amounts UW-Parkside returned to the U.S. Department of Education.
Questioned Costs:
$1,738, Plus an Undetermined Amount
Effect:
UW-Parkside did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Parkside did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal assistance to return. Although UW-Parkside disbursed federal financial assistance later than is typical to one student, the disbursement was not correctly categorized within the calculations completed by UW-Parkside to determine that the entire amount of the federal financial assistance was required to be returned to the federal government.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the students we identified.
Finding 2024-705: Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $1,738, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Background:
UW-Platteville receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Platteville reported a total of $29.1 million in federal financial assistance under the SFA Cluster. UW-Platteville is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Under 34 CFR s. 668.21, UW-Platteville must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. In addition, when a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Platteville must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In determining whether federal financial assistance was earned by a student, Volume 5, Chapter 2 of the Federal Student Aid Handbook specifies how to calculate academic days.
Condition:
For two of the five students we reviewed who never began attendance or who withdrew from enrollment during FY 2023-24, UW-Platteville inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Platteville incorrectly determined the student began attendance because the student attended one day of the fall 2023 term. As a result, UW-Platteville failed to return $24 in federal financial assistance to the U.S. Department of Education. For the second student, UW-Platteville did not exclude a five-day break from its determination of the federal financial assistance amount the student had earned during the fall 2023 term. Although this student had earned all of the federal financial assistance prior to the student’s withdrawal from enrollment, UW-Platteville incorrectly returned $1,226. Because UW-Platteville used the same calculation for all determinations for the fall 2023 term, there may be further errors in the federal financial assistance amounts UW-Platteville determined.
Context:
UW-Platteville uses a student information system to track activity for students who withdraw from enrollment in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Platteville staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Platteville to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 5 students who had received federal financial assistance and who withdrew from UW-Platteville to determine the amount of federal financial assistance those students earned and the related amounts UW-Platteville returned to the U.S. Department of Education.
Questioned Costs:
$24, Plus an Undetermined Amount
Effect:
UW-Platteville did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Platteville did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal financial assistance to return to the federal government. After we identified the error for the student who attended only one day, UW-Platteville returned the additional $24 to the federal government in November 2024. For the fall 2023 term, UW-Platteville changed its fall break from four to five days, which required a change in the number of academic days used in the calculation of federal financial assistance earned when a student withdraws from enrollment. UW-Platteville did not have a process to review the academic calendar for purposes of its return procedures.
Recommendation:
We recommend the University of Wisconsin-Platteville review, update, and implement its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including annually reviewing the academic days used in its determinations.
Finding 2024-706: Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $24, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Platteville: The University of Wisconsin-Platteville agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Background:
UW-Whitewater receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Whitewater reported a total of $58.4 million in federal financial assistance under the SFA Cluster. UW-Whitewater is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Whitewater must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook, the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW-Whitewater is required to be returned to the U.S. Department of Education unless certain conditions are met.
Condition:
UW-Whitewater inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education for one of seven students we reviewed who withdrew from enrollment during FY 2023 24. UW-Whitewater incorrectly accounted for a disbursement to the student that occurred after the date for which UW-Whitewater later identified the student had withdrawn from enrollment as an amount that was earned by the student. As a result, UW-Whitewater failed to return $400 in federal financial assistance to the U.S. Department of Education for the spring 2024 term.
Context:
In order to determine the federal financial assistance a student earned and the amount that must be returned to the U.S. Department of Education for amounts a student did not earn, UW-Whitewater uses a student information system to track activity for students who withdraw. We discussed with UW-Whitewater staff the process used for identifying students who withdrew from enrollment. We also requested information from UW-Whitewater to identify students who withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 7 students who had received federal financial assistance and who withdrew from UW-Whitewater to determine the amount of federal financial assistance those students earned and the related amounts UW-Whitewater returned to the U.S. Department of Education.
Questioned Costs:
$400, Plus an Undetermined Amount
Effect:
UW-Whitewater did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Whitewater did not have adequate procedures to review and ensure its determination of the amount of federal assistance to return was accurate. Although UW-Whitewater disbursed federal financial assistance later than is typical to the student, the disbursement was not correctly categorized within the calculations completed by UW-Whitewater nor was the categorization error detected by other
UW-Whitewater procedures.
Recommendation:
We recommend the University of Wisconsin-Whitewater:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the student we identified.
Finding 2024-707: Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $400, Plus an Undetermined Amount
Type of Finding: Noncompliance
Response from the University of Wisconsin-Whitewater: The University of Wisconsin-Whitewater agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Madison is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to the National Student Loan Data System (NSLDS). Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Madison is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time;
-report the same effective date for a student who withdraws from enrollment as the date used in its determination of whether any federal financial assistance must be returned in accordance with
34 CFR s. 668.22;
-report a student who has completed a program with a status of “graduated” rather than “withdrawn”;
-maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed; and
-maintain the program begin date, which is the date the student first began attending the program being reported, if a student’s program of study has not changed.
Condition:
UW-Madison uses the National Student Clearinghouse (NSC) to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Madison that identify potential errors in UW-Madison’s reporting of student activities. It is the responsibility of UW-Madison to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Madison did not report to NSLDS accurate information for 12 of the 17 students we reviewed. First, UW-Madison did not accurately report a student who withdrew from enrollment without notification in a timely manner. Second, UW-Madison incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment. Third, UW-Madison incorrectly reported the program-level enrollment status effective date for two students. Fourth, UW-Madison incorrectly reported the program begin date for six students. In addition, UW Madison incorrectly reported both the program-level enrollment status effective date and program begin date for two students.
Context:
We discussed with UW-Madison staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Madison relies on data from its student information system to compile information to transmit to NSC. UW-Madison also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student that withdrew from UW-Madison and six students who graduated from UW-Madison. In addition, we selected ten additional UW-Madison students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Madison did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Madison did not report to NSLDS who had withdrawn from enrollment without notification, we found UW-Madison’s enrollment reporting procedures did not assign responsibility for communicating certain information to those staff in the registrar’s office who are responsible for NSLDS reporting. As a result, those students the financial aid office determined had withdrawn from enrollment without notification, and for which it had completed a determination of federal financial assistance the students did not earn, were not known to staff in the registrar’s office for purposes of NSLDS reporting. In addition, UW-Madison indicated that withdrawals from enrollment without notification are identified after the term ends and its student information system did not have a dedicated effective date field in order to automatically identify such student records for the required NSLDS reporting.
Second, for the student UW-Madison did not accurately report as graduated within NSLDS, we found UW‑Madison relied on a NSC process that is intended to simultaneously update a student’s enrollment status in NSLDS when UW-Madison separately updates a student’s degree as completed. UW-Madison did not complete a separate report to ensure the enrollment status for graduated students was accurately reflected in NSLDS. However, in 2022 NSC had published information that indicated reliance solely on NSC’s process may result in the incorrect status being reported under certain circumstances. Although NSC error reports identified that such errors were present, UW-Madison indicated that it did not review these errors until fall 2024 when it began implementing new U.S. Department of Education reporting requirements.
At that time, UW-Madison stated that it identified that it did not consistently and accurately report in NSLDS those students who had graduated. UW-Madison stated that it then began to work with NSC to identify the extent of the reporting inaccuracies.
Third, in 2021 NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW-Madison’s data from its student information system and had communicated error or warning codes to UW-Madison in these areas. However, UW-Madison did not sufficiently review whether the records identified by NSC as potential errors resulted in inaccurate reporting. For example, NSC used warning codes for potential errors in the program-level enrollment status effective dates. As warning codes do not prohibit submission of reporting, UW-Madison did not review the warnings.
Fourth, in 2021 NSC similarly published information on accurately reporting student program begin dates in NSLDS and NSC had also identified instances of potential inaccurate reporting in UW Madison’s data from its student information system. Although NSC had communicated error or warning codes to UW-Madison in these areas, UW-Madison had not sufficiently reviewed whether the records identified by NSC as potential errors resulted in inaccurate reporting until 2023. At that time, UW-Madison indicated that, after reviewing other NSC warnings, it identified that it did not accurately report program begin dates for students. UW-Madison indicated it then began to work to update its student information system data extraction process to identify the correct program begin date for its submissions to NSC. However, it did not implement these changes until after the audit period.
In addition, UW-Madison indicated that it had turnover in staff responsible for NSLDS reporting in 2021, which may have caused UW-Madison to have missed the NSC publications regarding reporting graduated students accurately, new warning codes, and the importance of reviewing certain warning codes to accurately complete NSLDS reporting.
Recommendation:
We recommend the University of Wisconsin-Madison:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as updating its student information system to allow for an automated identification process to communicate those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated and implement separate reporting to the National Student Clearinghouse to accurately report students who graduate;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program-level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program begin dates and update its student information system extraction process to accurately report program begin dates; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-708: Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Background:
UW-Milwaukee receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Milwaukee reported a total of $133.1 million in federal financial assistance under the SFA Cluster. UW-Milwaukee records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Milwaukee is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Milwaukee is required to maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed.
Condition:
UW-Milwaukee uses NSC to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Milwaukee that identify potential errors in UW-Milwaukee’s reporting of student activities through NSC. These errors are the responsibility of UW-Milwaukee to resolve to ensure its submissions to NSLDS are accurate and complete.
UW-Milwaukee did not report to NSLDS accurate information for the program level enrollment status effective date for five students we reviewed. In addition, based on how information from its student information system is extracted for student reporting to NSLDS, we found that the reporting inaccuracy extended to other UW-Milwaukee students.
Context:
We discussed with UW-Milwaukee staff its procedures for identifying student enrollment status changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Milwaukee relies on data from its student information system to compile information to transmit to NSC. UW-Milwaukee also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included two students who withdrew from UW-Milwaukee and four students who graduated from UW- Milwaukee. In addition, we selected ten additional UW-Milwaukee students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Milwaukee did not comply with requirements to accurately report certain student enrollment status changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
In 2021, NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW- Milwaukee’s data from its student information system and had communicated error or warning codes to UW-Milwaukee in these areas. UW-Milwaukee staff indicated that they were aware that NSC error reports included warnings to identify potential inaccurate reporting of program level enrollment status effective dates and that the errors were a known issue for Peoplesoft-based student information systems. However, UW-Milwaukee chose not to use an all-record update feature that was available to correct the program-level enrollment status effective dates for all student records simultaneously due to the risk that other reporting inaccuracies could result from the action. Further, UW-Milwaukee staff indicated that they were not aware that specific guidance on the program-level enrollment status effective date had been updated to reflect that corrections should be made to fully comply with NSLDS reporting requirements.
Recommendation:
We recommend the University of Wisconsin-Milwaukee:
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates; and
-report changes in student enrollment accurately, completely, and in a timely manner for all student changes that require reporting.
Finding 2024-709: Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Milwaukee: The University of Wisconsin-Milwaukee agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Background:
UW-Oshkosh receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Oshkosh reported a total of $45.3 million in federal financial assistance under the SFA Cluster. UW-Oshkosh records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Oshkosh is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Oshkosh is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time; and
-report a student who has completed a program with a status of “graduated” rather than “withdrawn.”
Condition:
UW-Oshkosh uses NSC to facilitate the enrollment reporting in NSLDS. NSC provides error reports to UW-Oshkosh that identify potential errors in UW Oshkosh’s reporting of student activities. It is the responsibility of UW-Oshkosh to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Oshkosh did not report to NSLDS accurate information for two of the three students we reviewed.
First, UW-Oshkosh did not report in a timely manner one student who withdrew from enrollment without notification. Second, UW-Oshkosh incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment.
Context:
We discussed with UW-Oshkosh staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and UW Oshkosh’s procedures for monitoring the reporting performed by NSC. UW-Oshkosh relies on data from its student information system to compile information to transmit to NSC. UW-Oshkosh also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve. To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023 24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student who withdrew from UW-Oshkosh and two students who graduated from UW‑Oshkosh.
Questioned Costs:
None.
Effect:
UW-Oshkosh did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Oshkosh did not report to NSLDS in a timely manner who had withdrawn from enrollment without notification, we found that UW-Oshkosh indicated that it believed it needed to report to NSLDS only when students withdrew from enrollment and had notified UW-Oshkosh of the withdrawal. As a result, students detected by UW Oshkosh through procedures completed by the financial aid office at the end of each term were not communicated to those staff in the registrar’s office who were responsible for NSLDS reporting.
Second, for the student UW-Oshkosh did not accurately report as graduated within NSLDS, we found that inaccuracies in the reporting of students who had graduated were noted on NSC error reports. However, UW-Oshkosh’s registrar’s office staff did sufficiently review the errors to correct the status in NSLDS.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as communicating those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-710: Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Background:
UW Parkside operates in a highly computerized environment and is responsible for maintaining confidential and sensitive information, such as student data. UW Parkside maintains its own student information system to administer federal student financial assistance programs under the SFA Cluster.
Criteria:
To ensure data processed and stored by UW-Parkside is protected from accidental or intentional misuse or destruction, and to provide proper internal control, information technology (IT) security policies and procedures are necessary. In addition, IT controls should be established to prevent inappropriate or inadvertent access to data. UW-Parkside is responsible for following specific requirements under the Gramm-Leach-Bliley Act (GLBA), which requires entities that administer student financial assistance programs to develop, implement, and maintain safeguards to protect the security, integrity, and confidentiality of student data.
Under GLBA, UW-Parkside is required to authenticate and permit access only to authorized users. Further, UW Board of Regents Policy 25-5 requires that UW-Parkside follow the National Institute of Standards and Technology (NIST) in establishing IT controls. NIST Special Publication (SP) 800-53, Security and Privacy Controls for Information Systems and Organizations, recommends best practices in IT controls related to user access. These best practices include developing a provisioning and deprovisioning process focused on limiting access in a manner that provides the least access based on business need; retaining documentation of provisioning and deprovisioning activities, including records of when such access was added or removed; and performing periodic reviews of access to ensure it remains appropriate.
Condition:
We found UW-Parkside did not have adequate IT controls in place during FY 2023-24 to provision, deprovision, and manage access to its student information system. First, UW-Parkside did not have a formal documented process to provision or deprovision user access to its student information system. Second, UW-Parkside did not maintain a list of provisioned users with access and was unable to generate a report of users provisioned or deprovisioned during FY 2023-24. Third, UW-Parkside did not complete a periodic review of access, which assists in ensuring its provisioning and deprovisioning processes are working as intended. Although failure in any one IT control may be detected by complementary IT controls, UW‑Parkside did not have effective IT controls in any of the three areas. As a result, UW-Parkside was at a higher risk of granting unauthorized access to its student information system.
Context:
We reviewed GLBA requirements, UW System Board of Regents policies, and NIST 800-53 guidance to identify policies and procedures for UW-Parkside’s monitoring of access granted to its student information system. We requested documentation from UW-Parkside to assess compliance with these policies.
Questioned Costs:
None.
Effect:
Ineffective general IT controls may permit controls over systems to operate improperly and may allow noncompliance to occur and not be detected. Weaknesses in IT security policies, procedures, and controls increase the risk that unauthorized or erroneous transactions could be processed or changes made to student data. In addition, failure to provide an appropriate level of protection for its student information system and data increased the risk that personally identifiable information could be accidentally or maliciously exposed.
Cause:
UW-Parkside did not have a formal policy or procedures in place to provision, deprovision, and review access to its student information system. UW-Parkside staff indicated the process for provisioning and deprovisioning access had been informally operated, such as through electronic mail and direct communication and it did not consistently retain documentation of these communications. For example,
UW-Parkside indicated access requests were accepted from a variety of UW-Parkside employees. As a result, UW-Parkside had not assessed whether a user’s access was necessary or otherwise limited the access only to specific information needed or to a specified time period. Finally, UW-Parkside also indicated that prior efforts to improve its provisioning and deprovisioning of user access were not fully completed or implemented, in part, due to staff turnover.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-develop and implement written procedures for provisioning and deprovisioning user access to its student information system, including specifying those who are authorized to request user access and assigning responsibility to staff to assess access requests to restrict the access only to data needed for a specified period of time;
-retain consistent documentation of its provisioning and deprovisioning activities;
-develop and implement written procedures for a review at least annually of access granted to its student information system; and
-complete an assessment of users who currently have access to its student information system and remove those users who no longer require the access.
Finding 2024-711: Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-Madison must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. For students that begin attending classes, but who later withdraw from enrollment, 34 CFR s. 668.22 requires that UW-Madison must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In order not to consider a student to have withdrawn from enrollment under certain circumstances, which permits a student to retain federal financial assistance that otherwise would need to be returned to the federal government, 34 CFR s. 668.22 (a) (2) (ii) provides certain exemptions to students.
Condition:
For four students, we found that UW-Madison did not accurately determine the amount of federal financial assistance it disbursed that should have been returned to the U.S. Department of Education. First, we found that UW-Madison did not return all federal financial assistance it disbursed to two students that did not begin attendance and to one student who only attended one day during FY 2023-24. For these three students, UW-Madison determined it failed to return $16,403 in federal financial assistance it disbursed during FY 2023-24. Second, we found that UW-Madison did not accurately determine the federal financial assistance that should be returned after a student withdrew from enrollment during the summer 2023 term. For this student, UW-Madison incorrectly applied an exemption, which led to UW-Madison failing to return $584 in federal financial assistance to the U.S. Department of Education.
Context:
UW-Madison uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Madison staff its process for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Madison to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. When reviewing the data UW-Madison provided, we noted potential errors in the amount of aid returned for students identified as never attending.
Separately, as part of a UW systemwide sample of 60 students, we selected 6 students who had received federal financial assistance and who withdrew from enrollment from UW-Madison to determine the amount of federal financial assistance those students earned and the related amounts UW-Madison returned to the U.S. Department of Education.
Questioned Costs:
$16,987, Plus an Undetermined Amount
Effect:
UW-Madison did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Madison identified that the errors in determining the amount of the federal financial assistance that should have been returned to the federal government for the four students we identified were manual errors in the withdrawal procedures and calculations completed during and at the end of each term. These errors were not detected by any other review procedures. Although UW-Madison correctly identified the status of the two students who never attended and the need to return all disbursed federal financial assistance, it did not follow through on the actual repayment.
For the student who had an exemption applied, the exemption was incorrectly selected when UW-Madison completed a determination, and the error was not detected in UW-Madison’s review process. UW-Madison indicated that its automated review processes conducted at the end of each term did not specifically address the matters we identified for the four students.
After we identified these errors in the determination of the amount of federal financial assistance to return to the federal government, UW-Madison returned in fall 2024 the unearned federal financial assistance for the three students who never attended or withdrew from enrollment after attending one day. In addition, UW Madison returned the additional $584 in February 2025 for the student who withdrew from enrollment and did not meet the criteria for a withdrawal exemption.
Recommendation:
We recommend the University of Wisconsin-Madison review, update, and implement its procedures to improve the accuracy and follow-through for making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including thoroughly reviewing applied exemptions, and returning federal financial assistance in a timely manner to the federal government.
Finding 2024-703: Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,987, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Background:
UW-River Falls receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-River Falls reported a total of $23.6 million in federal financial assistance under the SFA Cluster. UW-River Falls is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-River Falls must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. Under Volume 5, Chapter 1 of the Federal Student Aid Handbook, when a student begins attendance in at least one course but does not begin attendance in all courses the student was scheduled to attend, the school must determine if it is necessary to recalculate the student’s eligibility for the Pell Grant based on a revised enrollment status and the cost of education pursuant to 34 CFR s. 690.80. If the student withdraws, this recalculation must be performed before determining whether to return federal financial assistance pursuant to 34 CFR s. 668.22.
Condition:
We found that UW-River Falls did not return $16,010 in federal financial assistance for four students that did not begin attendance in all enrolled courses during FY 2023-24. This included two students who never began attendance in any enrolled courses for whom all disbursed federal financial assistance was required to be returned. This also included two students who began at least one course but not all courses for which the students had enrolled. UW-River Falls did not perform the required recalculation of Pell Grant eligibility or an assessment of federal financial assistance it had disbursed that these students had not earned.
Context:
UW-River Falls uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-River Falls the process used for identifying students who did not begin attending all enrolled courses or withdrew from enrollment, and we requested a list of such students during FY 2023-24. UW-River Falls did not have a complete list readily available of students who did not begin attending all enrolled courses.
Questioned Costs:
$16,010, Plus an Undetermined Amount
Effect:
UW-River Falls did not comply with all requirements to return federal financial assistance for students who never attended or did not begin attending all enrolled courses during FY 2023-24.
Cause:
UW-River Falls did not have procedures to identify from its student information system, or other sources, those students for whom it disbursed federal financial assistance, yet the students did not attend at least one course during the term or begin all courses enrolled. Depending on whether a student dropped any of their courses, UW-River Falls indicated that the procedures to evaluate attendance may not have identified all students who would ultimately be determined as never attending for the academic term.
After we requested a list of students who did not begin attending all enrolled courses, UW-River Falls identified two students who did not begin at least one course but for whom it had disbursed federal financial assistance. For the other two students who began at least one course, UW-River Falls completed the required Pell Grant recalculation for the students. UW-River Falls also determined the amount of federal financial assistance to return for all four students, as applicable, to the U.S. Department of Education in September 2024.
Recommendation:
We recommend the University of Wisconsin-River Falls review, update, and implement procedures to:
-identify students after the start of each academic term for whom it disbursed federal financial assistance and the students did not begin all enrolled courses;
-complete required recalculations for Pell Grant eligibility and a determination of federal financial assistance that was not earned by the students, as applicable; and
-return amounts to the federal government in a timely manner.
Finding 2024-704: Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,010, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-River Falls: The University of Wisconsin-River Falls agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Background:
UW-Parkside receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Parkside reported a total of $21.3 million in federal financial assistance under the SFA Cluster. UW-Parkside is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22, requires that UW-Parkside must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW Parkside should be returned to the U.S. Department of Education unless certain conditions are met. In determining whether federal financial assistance was earned by a student, the Federal Student Aid Handbook provides guidance on how to calculate applicable institution charges and academic days under different circumstances.
Condition:
For two of three students we reviewed who withdrew from enrollment during FY 2023-24, UW-Parkside inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Parkside incorrectly accounted for a disbursement that occurred after the student’s withdrawal from enrollment as an amount that was earned by the student for the fall 2023 term. As a result, UW Parkside returned $548 less than what should have been returned to the U.S. Department of Education. For the second student, UW-Parkside incorrectly identified the end date of the spring 2024 term and did not include the correct institutional charges in its determination. As a result, UW-Parkside returned $1,190 less than should have been returned to the U.S. Department of Education.
Context:
UW-Parkside uses a student information system to track activity for students that withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Parkside staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from
UW-Parkside to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 3 students who had received federal financial assistance and withdrew from UW-Parkside to determine the amount of federal financial assistance those students earned and the related amounts UW-Parkside returned to the U.S. Department of Education.
Questioned Costs:
$1,738, Plus an Undetermined Amount
Effect:
UW-Parkside did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Parkside did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal assistance to return. Although UW-Parkside disbursed federal financial assistance later than is typical to one student, the disbursement was not correctly categorized within the calculations completed by UW-Parkside to determine that the entire amount of the federal financial assistance was required to be returned to the federal government.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the students we identified.
Finding 2024-705: Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $1,738, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Background:
UW-Platteville receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Platteville reported a total of $29.1 million in federal financial assistance under the SFA Cluster. UW-Platteville is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Under 34 CFR s. 668.21, UW-Platteville must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. In addition, when a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Platteville must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In determining whether federal financial assistance was earned by a student, Volume 5, Chapter 2 of the Federal Student Aid Handbook specifies how to calculate academic days.
Condition:
For two of the five students we reviewed who never began attendance or who withdrew from enrollment during FY 2023-24, UW-Platteville inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Platteville incorrectly determined the student began attendance because the student attended one day of the fall 2023 term. As a result, UW-Platteville failed to return $24 in federal financial assistance to the U.S. Department of Education. For the second student, UW-Platteville did not exclude a five-day break from its determination of the federal financial assistance amount the student had earned during the fall 2023 term. Although this student had earned all of the federal financial assistance prior to the student’s withdrawal from enrollment, UW-Platteville incorrectly returned $1,226. Because UW-Platteville used the same calculation for all determinations for the fall 2023 term, there may be further errors in the federal financial assistance amounts UW-Platteville determined.
Context:
UW-Platteville uses a student information system to track activity for students who withdraw from enrollment in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Platteville staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Platteville to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 5 students who had received federal financial assistance and who withdrew from UW-Platteville to determine the amount of federal financial assistance those students earned and the related amounts UW-Platteville returned to the U.S. Department of Education.
Questioned Costs:
$24, Plus an Undetermined Amount
Effect:
UW-Platteville did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Platteville did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal financial assistance to return to the federal government. After we identified the error for the student who attended only one day, UW-Platteville returned the additional $24 to the federal government in November 2024. For the fall 2023 term, UW-Platteville changed its fall break from four to five days, which required a change in the number of academic days used in the calculation of federal financial assistance earned when a student withdraws from enrollment. UW-Platteville did not have a process to review the academic calendar for purposes of its return procedures.
Recommendation:
We recommend the University of Wisconsin-Platteville review, update, and implement its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including annually reviewing the academic days used in its determinations.
Finding 2024-706: Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $24, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Platteville: The University of Wisconsin-Platteville agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Background:
UW-Whitewater receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Whitewater reported a total of $58.4 million in federal financial assistance under the SFA Cluster. UW-Whitewater is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Whitewater must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook, the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW-Whitewater is required to be returned to the U.S. Department of Education unless certain conditions are met.
Condition:
UW-Whitewater inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education for one of seven students we reviewed who withdrew from enrollment during FY 2023 24. UW-Whitewater incorrectly accounted for a disbursement to the student that occurred after the date for which UW-Whitewater later identified the student had withdrawn from enrollment as an amount that was earned by the student. As a result, UW-Whitewater failed to return $400 in federal financial assistance to the U.S. Department of Education for the spring 2024 term.
Context:
In order to determine the federal financial assistance a student earned and the amount that must be returned to the U.S. Department of Education for amounts a student did not earn, UW-Whitewater uses a student information system to track activity for students who withdraw. We discussed with UW-Whitewater staff the process used for identifying students who withdrew from enrollment. We also requested information from UW-Whitewater to identify students who withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 7 students who had received federal financial assistance and who withdrew from UW-Whitewater to determine the amount of federal financial assistance those students earned and the related amounts UW-Whitewater returned to the U.S. Department of Education.
Questioned Costs:
$400, Plus an Undetermined Amount
Effect:
UW-Whitewater did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Whitewater did not have adequate procedures to review and ensure its determination of the amount of federal assistance to return was accurate. Although UW-Whitewater disbursed federal financial assistance later than is typical to the student, the disbursement was not correctly categorized within the calculations completed by UW-Whitewater nor was the categorization error detected by other
UW-Whitewater procedures.
Recommendation:
We recommend the University of Wisconsin-Whitewater:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the student we identified.
Finding 2024-707: Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $400, Plus an Undetermined Amount
Type of Finding: Noncompliance
Response from the University of Wisconsin-Whitewater: The University of Wisconsin-Whitewater agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Madison is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to the National Student Loan Data System (NSLDS). Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Madison is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time;
-report the same effective date for a student who withdraws from enrollment as the date used in its determination of whether any federal financial assistance must be returned in accordance with
34 CFR s. 668.22;
-report a student who has completed a program with a status of “graduated” rather than “withdrawn”;
-maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed; and
-maintain the program begin date, which is the date the student first began attending the program being reported, if a student’s program of study has not changed.
Condition:
UW-Madison uses the National Student Clearinghouse (NSC) to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Madison that identify potential errors in UW-Madison’s reporting of student activities. It is the responsibility of UW-Madison to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Madison did not report to NSLDS accurate information for 12 of the 17 students we reviewed. First, UW-Madison did not accurately report a student who withdrew from enrollment without notification in a timely manner. Second, UW-Madison incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment. Third, UW-Madison incorrectly reported the program-level enrollment status effective date for two students. Fourth, UW-Madison incorrectly reported the program begin date for six students. In addition, UW Madison incorrectly reported both the program-level enrollment status effective date and program begin date for two students.
Context:
We discussed with UW-Madison staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Madison relies on data from its student information system to compile information to transmit to NSC. UW-Madison also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student that withdrew from UW-Madison and six students who graduated from UW-Madison. In addition, we selected ten additional UW-Madison students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Madison did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Madison did not report to NSLDS who had withdrawn from enrollment without notification, we found UW-Madison’s enrollment reporting procedures did not assign responsibility for communicating certain information to those staff in the registrar’s office who are responsible for NSLDS reporting. As a result, those students the financial aid office determined had withdrawn from enrollment without notification, and for which it had completed a determination of federal financial assistance the students did not earn, were not known to staff in the registrar’s office for purposes of NSLDS reporting. In addition, UW-Madison indicated that withdrawals from enrollment without notification are identified after the term ends and its student information system did not have a dedicated effective date field in order to automatically identify such student records for the required NSLDS reporting.
Second, for the student UW-Madison did not accurately report as graduated within NSLDS, we found UW‑Madison relied on a NSC process that is intended to simultaneously update a student’s enrollment status in NSLDS when UW-Madison separately updates a student’s degree as completed. UW-Madison did not complete a separate report to ensure the enrollment status for graduated students was accurately reflected in NSLDS. However, in 2022 NSC had published information that indicated reliance solely on NSC’s process may result in the incorrect status being reported under certain circumstances. Although NSC error reports identified that such errors were present, UW-Madison indicated that it did not review these errors until fall 2024 when it began implementing new U.S. Department of Education reporting requirements.
At that time, UW-Madison stated that it identified that it did not consistently and accurately report in NSLDS those students who had graduated. UW-Madison stated that it then began to work with NSC to identify the extent of the reporting inaccuracies.
Third, in 2021 NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW-Madison’s data from its student information system and had communicated error or warning codes to UW-Madison in these areas. However, UW-Madison did not sufficiently review whether the records identified by NSC as potential errors resulted in inaccurate reporting. For example, NSC used warning codes for potential errors in the program-level enrollment status effective dates. As warning codes do not prohibit submission of reporting, UW-Madison did not review the warnings.
Fourth, in 2021 NSC similarly published information on accurately reporting student program begin dates in NSLDS and NSC had also identified instances of potential inaccurate reporting in UW Madison’s data from its student information system. Although NSC had communicated error or warning codes to UW-Madison in these areas, UW-Madison had not sufficiently reviewed whether the records identified by NSC as potential errors resulted in inaccurate reporting until 2023. At that time, UW-Madison indicated that, after reviewing other NSC warnings, it identified that it did not accurately report program begin dates for students. UW-Madison indicated it then began to work to update its student information system data extraction process to identify the correct program begin date for its submissions to NSC. However, it did not implement these changes until after the audit period.
In addition, UW-Madison indicated that it had turnover in staff responsible for NSLDS reporting in 2021, which may have caused UW-Madison to have missed the NSC publications regarding reporting graduated students accurately, new warning codes, and the importance of reviewing certain warning codes to accurately complete NSLDS reporting.
Recommendation:
We recommend the University of Wisconsin-Madison:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as updating its student information system to allow for an automated identification process to communicate those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated and implement separate reporting to the National Student Clearinghouse to accurately report students who graduate;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program-level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program begin dates and update its student information system extraction process to accurately report program begin dates; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-708: Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Background:
UW-Milwaukee receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Milwaukee reported a total of $133.1 million in federal financial assistance under the SFA Cluster. UW-Milwaukee records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Milwaukee is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Milwaukee is required to maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed.
Condition:
UW-Milwaukee uses NSC to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Milwaukee that identify potential errors in UW-Milwaukee’s reporting of student activities through NSC. These errors are the responsibility of UW-Milwaukee to resolve to ensure its submissions to NSLDS are accurate and complete.
UW-Milwaukee did not report to NSLDS accurate information for the program level enrollment status effective date for five students we reviewed. In addition, based on how information from its student information system is extracted for student reporting to NSLDS, we found that the reporting inaccuracy extended to other UW-Milwaukee students.
Context:
We discussed with UW-Milwaukee staff its procedures for identifying student enrollment status changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Milwaukee relies on data from its student information system to compile information to transmit to NSC. UW-Milwaukee also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included two students who withdrew from UW-Milwaukee and four students who graduated from UW- Milwaukee. In addition, we selected ten additional UW-Milwaukee students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Milwaukee did not comply with requirements to accurately report certain student enrollment status changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
In 2021, NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW- Milwaukee’s data from its student information system and had communicated error or warning codes to UW-Milwaukee in these areas. UW-Milwaukee staff indicated that they were aware that NSC error reports included warnings to identify potential inaccurate reporting of program level enrollment status effective dates and that the errors were a known issue for Peoplesoft-based student information systems. However, UW-Milwaukee chose not to use an all-record update feature that was available to correct the program-level enrollment status effective dates for all student records simultaneously due to the risk that other reporting inaccuracies could result from the action. Further, UW-Milwaukee staff indicated that they were not aware that specific guidance on the program-level enrollment status effective date had been updated to reflect that corrections should be made to fully comply with NSLDS reporting requirements.
Recommendation:
We recommend the University of Wisconsin-Milwaukee:
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates; and
-report changes in student enrollment accurately, completely, and in a timely manner for all student changes that require reporting.
Finding 2024-709: Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Milwaukee: The University of Wisconsin-Milwaukee agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Background:
UW-Oshkosh receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Oshkosh reported a total of $45.3 million in federal financial assistance under the SFA Cluster. UW-Oshkosh records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Oshkosh is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Oshkosh is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time; and
-report a student who has completed a program with a status of “graduated” rather than “withdrawn.”
Condition:
UW-Oshkosh uses NSC to facilitate the enrollment reporting in NSLDS. NSC provides error reports to UW-Oshkosh that identify potential errors in UW Oshkosh’s reporting of student activities. It is the responsibility of UW-Oshkosh to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Oshkosh did not report to NSLDS accurate information for two of the three students we reviewed.
First, UW-Oshkosh did not report in a timely manner one student who withdrew from enrollment without notification. Second, UW-Oshkosh incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment.
Context:
We discussed with UW-Oshkosh staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and UW Oshkosh’s procedures for monitoring the reporting performed by NSC. UW-Oshkosh relies on data from its student information system to compile information to transmit to NSC. UW-Oshkosh also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve. To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023 24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student who withdrew from UW-Oshkosh and two students who graduated from UW‑Oshkosh.
Questioned Costs:
None.
Effect:
UW-Oshkosh did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Oshkosh did not report to NSLDS in a timely manner who had withdrawn from enrollment without notification, we found that UW-Oshkosh indicated that it believed it needed to report to NSLDS only when students withdrew from enrollment and had notified UW-Oshkosh of the withdrawal. As a result, students detected by UW Oshkosh through procedures completed by the financial aid office at the end of each term were not communicated to those staff in the registrar’s office who were responsible for NSLDS reporting.
Second, for the student UW-Oshkosh did not accurately report as graduated within NSLDS, we found that inaccuracies in the reporting of students who had graduated were noted on NSC error reports. However, UW-Oshkosh’s registrar’s office staff did sufficiently review the errors to correct the status in NSLDS.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as communicating those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-710: Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Background:
UW Parkside operates in a highly computerized environment and is responsible for maintaining confidential and sensitive information, such as student data. UW Parkside maintains its own student information system to administer federal student financial assistance programs under the SFA Cluster.
Criteria:
To ensure data processed and stored by UW-Parkside is protected from accidental or intentional misuse or destruction, and to provide proper internal control, information technology (IT) security policies and procedures are necessary. In addition, IT controls should be established to prevent inappropriate or inadvertent access to data. UW-Parkside is responsible for following specific requirements under the Gramm-Leach-Bliley Act (GLBA), which requires entities that administer student financial assistance programs to develop, implement, and maintain safeguards to protect the security, integrity, and confidentiality of student data.
Under GLBA, UW-Parkside is required to authenticate and permit access only to authorized users. Further, UW Board of Regents Policy 25-5 requires that UW-Parkside follow the National Institute of Standards and Technology (NIST) in establishing IT controls. NIST Special Publication (SP) 800-53, Security and Privacy Controls for Information Systems and Organizations, recommends best practices in IT controls related to user access. These best practices include developing a provisioning and deprovisioning process focused on limiting access in a manner that provides the least access based on business need; retaining documentation of provisioning and deprovisioning activities, including records of when such access was added or removed; and performing periodic reviews of access to ensure it remains appropriate.
Condition:
We found UW-Parkside did not have adequate IT controls in place during FY 2023-24 to provision, deprovision, and manage access to its student information system. First, UW-Parkside did not have a formal documented process to provision or deprovision user access to its student information system. Second, UW-Parkside did not maintain a list of provisioned users with access and was unable to generate a report of users provisioned or deprovisioned during FY 2023-24. Third, UW-Parkside did not complete a periodic review of access, which assists in ensuring its provisioning and deprovisioning processes are working as intended. Although failure in any one IT control may be detected by complementary IT controls, UW‑Parkside did not have effective IT controls in any of the three areas. As a result, UW-Parkside was at a higher risk of granting unauthorized access to its student information system.
Context:
We reviewed GLBA requirements, UW System Board of Regents policies, and NIST 800-53 guidance to identify policies and procedures for UW-Parkside’s monitoring of access granted to its student information system. We requested documentation from UW-Parkside to assess compliance with these policies.
Questioned Costs:
None.
Effect:
Ineffective general IT controls may permit controls over systems to operate improperly and may allow noncompliance to occur and not be detected. Weaknesses in IT security policies, procedures, and controls increase the risk that unauthorized or erroneous transactions could be processed or changes made to student data. In addition, failure to provide an appropriate level of protection for its student information system and data increased the risk that personally identifiable information could be accidentally or maliciously exposed.
Cause:
UW-Parkside did not have a formal policy or procedures in place to provision, deprovision, and review access to its student information system. UW-Parkside staff indicated the process for provisioning and deprovisioning access had been informally operated, such as through electronic mail and direct communication and it did not consistently retain documentation of these communications. For example,
UW-Parkside indicated access requests were accepted from a variety of UW-Parkside employees. As a result, UW-Parkside had not assessed whether a user’s access was necessary or otherwise limited the access only to specific information needed or to a specified time period. Finally, UW-Parkside also indicated that prior efforts to improve its provisioning and deprovisioning of user access were not fully completed or implemented, in part, due to staff turnover.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-develop and implement written procedures for provisioning and deprovisioning user access to its student information system, including specifying those who are authorized to request user access and assigning responsibility to staff to assess access requests to restrict the access only to data needed for a specified period of time;
-retain consistent documentation of its provisioning and deprovisioning activities;
-develop and implement written procedures for a review at least annually of access granted to its student information system; and
-complete an assessment of users who currently have access to its student information system and remove those users who no longer require the access.
Finding 2024-711: Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Monthly Reconciliations
Background:
UW institutions receive funding for several grant and loan programs, such as Federal Direct Student Loans (Assistance Listing number 84.268) and the Federal Pell Grant Program (Assistance Listing number 84.063), from the U.S. Department of Education that are administered under the SFA Cluster. UW Oshkosh is required to comply with U.S. Department of Education requirements for disbursing funds to students under the Direct Student Loans and Pell Grant programs. This includes reporting disbursement activity in a U.S. Department of Education system in a timely manner. For FY 2023-24, UW-Oshkosh reported federal financial assistance of $29.7 million in Direct Student Loans and $10.3 million in Pell Grants.
Criteria:
Pursuant to 34 CFR s. 685.300 (b) (5), UW-Oshkosh is required to perform monthly reconciliations between U.S. Department of Education systems and its financial and business systems for all Direct Student Loans activity. The monthly reconciliations include two components:
-an external review between UW Oshkosh’s disbursements in its student information system compared to data in a U.S. Department of Education reporting system; and
-an internal reconciliation between UW Oshkosh’s student information system and its accounting system.
In addition, U.S. Department of Education guidance included in Volume 4, Chapter 5, of the Federal Student Aid Handbook, recommends that UW Oshkosh similarly complete monthly reconciliations for Pell Grant activity.
Condition:
Although UW-Oshkosh provided documentation for the external component of reconciliations it completed for the two months we selected to review for the Direct Student Loans and Pell Grant reconciliations during FY 2023 24, it did not provide documentation for the internal component of these reconciliations.
Context:
We reviewed and discussed UW Oshkosh’s procedures for performing monthly reconciliations for Direct Student Loans and Pell Grant disbursements. We selected two monthly Direct Student Loans and Pell Grant reconciliations and reviewed the internal and external reconciliation components for each month.
Questioned Costs:
None.
Effect:
Without documentation, UW-Oshkosh cannot be assured that it accurately completed the required reconciliations to identify whether Direct Student Loans or Pell Grant disbursements were properly reported to the U.S. Department of Education and other federal requirements were being met.
Cause:
UW-Oshkosh indicated that it was unable to locate documentation for the internal component of the reconciliation for the months we requested because the documentation was not retained in a shared folder. In addition, UW Oshkosh indicated that there had been staff turnover in the position that completed the reconciliations.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-ensure all required monthly reconciliations are completed in a timely manner; and
-retain documentation to support all monthly reconciliations it completes.
Finding 2024-700: Student Financial Assistance Cluster—UW-Oshkosh Monthly Reconciliations
Federal Pell Grant Program (Assistance Listing number 84.063)
Award Numbers Award Years
Various Various
Questioned Costs: None
Federal Direct Student Loans (Assistance Listing number 84.268)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-Madison must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. For students that begin attending classes, but who later withdraw from enrollment, 34 CFR s. 668.22 requires that UW-Madison must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In order not to consider a student to have withdrawn from enrollment under certain circumstances, which permits a student to retain federal financial assistance that otherwise would need to be returned to the federal government, 34 CFR s. 668.22 (a) (2) (ii) provides certain exemptions to students.
Condition:
For four students, we found that UW-Madison did not accurately determine the amount of federal financial assistance it disbursed that should have been returned to the U.S. Department of Education. First, we found that UW-Madison did not return all federal financial assistance it disbursed to two students that did not begin attendance and to one student who only attended one day during FY 2023-24. For these three students, UW-Madison determined it failed to return $16,403 in federal financial assistance it disbursed during FY 2023-24. Second, we found that UW-Madison did not accurately determine the federal financial assistance that should be returned after a student withdrew from enrollment during the summer 2023 term. For this student, UW-Madison incorrectly applied an exemption, which led to UW-Madison failing to return $584 in federal financial assistance to the U.S. Department of Education.
Context:
UW-Madison uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Madison staff its process for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Madison to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. When reviewing the data UW-Madison provided, we noted potential errors in the amount of aid returned for students identified as never attending.
Separately, as part of a UW systemwide sample of 60 students, we selected 6 students who had received federal financial assistance and who withdrew from enrollment from UW-Madison to determine the amount of federal financial assistance those students earned and the related amounts UW-Madison returned to the U.S. Department of Education.
Questioned Costs:
$16,987, Plus an Undetermined Amount
Effect:
UW-Madison did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Madison identified that the errors in determining the amount of the federal financial assistance that should have been returned to the federal government for the four students we identified were manual errors in the withdrawal procedures and calculations completed during and at the end of each term. These errors were not detected by any other review procedures. Although UW-Madison correctly identified the status of the two students who never attended and the need to return all disbursed federal financial assistance, it did not follow through on the actual repayment.
For the student who had an exemption applied, the exemption was incorrectly selected when UW-Madison completed a determination, and the error was not detected in UW-Madison’s review process. UW-Madison indicated that its automated review processes conducted at the end of each term did not specifically address the matters we identified for the four students.
After we identified these errors in the determination of the amount of federal financial assistance to return to the federal government, UW-Madison returned in fall 2024 the unearned federal financial assistance for the three students who never attended or withdrew from enrollment after attending one day. In addition, UW Madison returned the additional $584 in February 2025 for the student who withdrew from enrollment and did not meet the criteria for a withdrawal exemption.
Recommendation:
We recommend the University of Wisconsin-Madison review, update, and implement its procedures to improve the accuracy and follow-through for making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including thoroughly reviewing applied exemptions, and returning federal financial assistance in a timely manner to the federal government.
Finding 2024-703: Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,987, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Background:
UW-River Falls receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-River Falls reported a total of $23.6 million in federal financial assistance under the SFA Cluster. UW-River Falls is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-River Falls must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. Under Volume 5, Chapter 1 of the Federal Student Aid Handbook, when a student begins attendance in at least one course but does not begin attendance in all courses the student was scheduled to attend, the school must determine if it is necessary to recalculate the student’s eligibility for the Pell Grant based on a revised enrollment status and the cost of education pursuant to 34 CFR s. 690.80. If the student withdraws, this recalculation must be performed before determining whether to return federal financial assistance pursuant to 34 CFR s. 668.22.
Condition:
We found that UW-River Falls did not return $16,010 in federal financial assistance for four students that did not begin attendance in all enrolled courses during FY 2023-24. This included two students who never began attendance in any enrolled courses for whom all disbursed federal financial assistance was required to be returned. This also included two students who began at least one course but not all courses for which the students had enrolled. UW-River Falls did not perform the required recalculation of Pell Grant eligibility or an assessment of federal financial assistance it had disbursed that these students had not earned.
Context:
UW-River Falls uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-River Falls the process used for identifying students who did not begin attending all enrolled courses or withdrew from enrollment, and we requested a list of such students during FY 2023-24. UW-River Falls did not have a complete list readily available of students who did not begin attending all enrolled courses.
Questioned Costs:
$16,010, Plus an Undetermined Amount
Effect:
UW-River Falls did not comply with all requirements to return federal financial assistance for students who never attended or did not begin attending all enrolled courses during FY 2023-24.
Cause:
UW-River Falls did not have procedures to identify from its student information system, or other sources, those students for whom it disbursed federal financial assistance, yet the students did not attend at least one course during the term or begin all courses enrolled. Depending on whether a student dropped any of their courses, UW-River Falls indicated that the procedures to evaluate attendance may not have identified all students who would ultimately be determined as never attending for the academic term.
After we requested a list of students who did not begin attending all enrolled courses, UW-River Falls identified two students who did not begin at least one course but for whom it had disbursed federal financial assistance. For the other two students who began at least one course, UW-River Falls completed the required Pell Grant recalculation for the students. UW-River Falls also determined the amount of federal financial assistance to return for all four students, as applicable, to the U.S. Department of Education in September 2024.
Recommendation:
We recommend the University of Wisconsin-River Falls review, update, and implement procedures to:
-identify students after the start of each academic term for whom it disbursed federal financial assistance and the students did not begin all enrolled courses;
-complete required recalculations for Pell Grant eligibility and a determination of federal financial assistance that was not earned by the students, as applicable; and
-return amounts to the federal government in a timely manner.
Finding 2024-704: Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,010, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-River Falls: The University of Wisconsin-River Falls agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Background:
UW-Parkside receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Parkside reported a total of $21.3 million in federal financial assistance under the SFA Cluster. UW-Parkside is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22, requires that UW-Parkside must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW Parkside should be returned to the U.S. Department of Education unless certain conditions are met. In determining whether federal financial assistance was earned by a student, the Federal Student Aid Handbook provides guidance on how to calculate applicable institution charges and academic days under different circumstances.
Condition:
For two of three students we reviewed who withdrew from enrollment during FY 2023-24, UW-Parkside inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Parkside incorrectly accounted for a disbursement that occurred after the student’s withdrawal from enrollment as an amount that was earned by the student for the fall 2023 term. As a result, UW Parkside returned $548 less than what should have been returned to the U.S. Department of Education. For the second student, UW-Parkside incorrectly identified the end date of the spring 2024 term and did not include the correct institutional charges in its determination. As a result, UW-Parkside returned $1,190 less than should have been returned to the U.S. Department of Education.
Context:
UW-Parkside uses a student information system to track activity for students that withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Parkside staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from
UW-Parkside to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 3 students who had received federal financial assistance and withdrew from UW-Parkside to determine the amount of federal financial assistance those students earned and the related amounts UW-Parkside returned to the U.S. Department of Education.
Questioned Costs:
$1,738, Plus an Undetermined Amount
Effect:
UW-Parkside did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Parkside did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal assistance to return. Although UW-Parkside disbursed federal financial assistance later than is typical to one student, the disbursement was not correctly categorized within the calculations completed by UW-Parkside to determine that the entire amount of the federal financial assistance was required to be returned to the federal government.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the students we identified.
Finding 2024-705: Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $1,738, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Background:
UW-Platteville receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Platteville reported a total of $29.1 million in federal financial assistance under the SFA Cluster. UW-Platteville is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Under 34 CFR s. 668.21, UW-Platteville must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. In addition, when a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Platteville must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In determining whether federal financial assistance was earned by a student, Volume 5, Chapter 2 of the Federal Student Aid Handbook specifies how to calculate academic days.
Condition:
For two of the five students we reviewed who never began attendance or who withdrew from enrollment during FY 2023-24, UW-Platteville inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Platteville incorrectly determined the student began attendance because the student attended one day of the fall 2023 term. As a result, UW-Platteville failed to return $24 in federal financial assistance to the U.S. Department of Education. For the second student, UW-Platteville did not exclude a five-day break from its determination of the federal financial assistance amount the student had earned during the fall 2023 term. Although this student had earned all of the federal financial assistance prior to the student’s withdrawal from enrollment, UW-Platteville incorrectly returned $1,226. Because UW-Platteville used the same calculation for all determinations for the fall 2023 term, there may be further errors in the federal financial assistance amounts UW-Platteville determined.
Context:
UW-Platteville uses a student information system to track activity for students who withdraw from enrollment in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Platteville staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Platteville to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 5 students who had received federal financial assistance and who withdrew from UW-Platteville to determine the amount of federal financial assistance those students earned and the related amounts UW-Platteville returned to the U.S. Department of Education.
Questioned Costs:
$24, Plus an Undetermined Amount
Effect:
UW-Platteville did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Platteville did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal financial assistance to return to the federal government. After we identified the error for the student who attended only one day, UW-Platteville returned the additional $24 to the federal government in November 2024. For the fall 2023 term, UW-Platteville changed its fall break from four to five days, which required a change in the number of academic days used in the calculation of federal financial assistance earned when a student withdraws from enrollment. UW-Platteville did not have a process to review the academic calendar for purposes of its return procedures.
Recommendation:
We recommend the University of Wisconsin-Platteville review, update, and implement its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including annually reviewing the academic days used in its determinations.
Finding 2024-706: Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $24, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Platteville: The University of Wisconsin-Platteville agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Background:
UW-Whitewater receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Whitewater reported a total of $58.4 million in federal financial assistance under the SFA Cluster. UW-Whitewater is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Whitewater must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook, the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW-Whitewater is required to be returned to the U.S. Department of Education unless certain conditions are met.
Condition:
UW-Whitewater inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education for one of seven students we reviewed who withdrew from enrollment during FY 2023 24. UW-Whitewater incorrectly accounted for a disbursement to the student that occurred after the date for which UW-Whitewater later identified the student had withdrawn from enrollment as an amount that was earned by the student. As a result, UW-Whitewater failed to return $400 in federal financial assistance to the U.S. Department of Education for the spring 2024 term.
Context:
In order to determine the federal financial assistance a student earned and the amount that must be returned to the U.S. Department of Education for amounts a student did not earn, UW-Whitewater uses a student information system to track activity for students who withdraw. We discussed with UW-Whitewater staff the process used for identifying students who withdrew from enrollment. We also requested information from UW-Whitewater to identify students who withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 7 students who had received federal financial assistance and who withdrew from UW-Whitewater to determine the amount of federal financial assistance those students earned and the related amounts UW-Whitewater returned to the U.S. Department of Education.
Questioned Costs:
$400, Plus an Undetermined Amount
Effect:
UW-Whitewater did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Whitewater did not have adequate procedures to review and ensure its determination of the amount of federal assistance to return was accurate. Although UW-Whitewater disbursed federal financial assistance later than is typical to the student, the disbursement was not correctly categorized within the calculations completed by UW-Whitewater nor was the categorization error detected by other
UW-Whitewater procedures.
Recommendation:
We recommend the University of Wisconsin-Whitewater:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the student we identified.
Finding 2024-707: Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $400, Plus an Undetermined Amount
Type of Finding: Noncompliance
Response from the University of Wisconsin-Whitewater: The University of Wisconsin-Whitewater agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Madison is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to the National Student Loan Data System (NSLDS). Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Madison is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time;
-report the same effective date for a student who withdraws from enrollment as the date used in its determination of whether any federal financial assistance must be returned in accordance with
34 CFR s. 668.22;
-report a student who has completed a program with a status of “graduated” rather than “withdrawn”;
-maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed; and
-maintain the program begin date, which is the date the student first began attending the program being reported, if a student’s program of study has not changed.
Condition:
UW-Madison uses the National Student Clearinghouse (NSC) to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Madison that identify potential errors in UW-Madison’s reporting of student activities. It is the responsibility of UW-Madison to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Madison did not report to NSLDS accurate information for 12 of the 17 students we reviewed. First, UW-Madison did not accurately report a student who withdrew from enrollment without notification in a timely manner. Second, UW-Madison incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment. Third, UW-Madison incorrectly reported the program-level enrollment status effective date for two students. Fourth, UW-Madison incorrectly reported the program begin date for six students. In addition, UW Madison incorrectly reported both the program-level enrollment status effective date and program begin date for two students.
Context:
We discussed with UW-Madison staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Madison relies on data from its student information system to compile information to transmit to NSC. UW-Madison also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student that withdrew from UW-Madison and six students who graduated from UW-Madison. In addition, we selected ten additional UW-Madison students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Madison did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Madison did not report to NSLDS who had withdrawn from enrollment without notification, we found UW-Madison’s enrollment reporting procedures did not assign responsibility for communicating certain information to those staff in the registrar’s office who are responsible for NSLDS reporting. As a result, those students the financial aid office determined had withdrawn from enrollment without notification, and for which it had completed a determination of federal financial assistance the students did not earn, were not known to staff in the registrar’s office for purposes of NSLDS reporting. In addition, UW-Madison indicated that withdrawals from enrollment without notification are identified after the term ends and its student information system did not have a dedicated effective date field in order to automatically identify such student records for the required NSLDS reporting.
Second, for the student UW-Madison did not accurately report as graduated within NSLDS, we found UW‑Madison relied on a NSC process that is intended to simultaneously update a student’s enrollment status in NSLDS when UW-Madison separately updates a student’s degree as completed. UW-Madison did not complete a separate report to ensure the enrollment status for graduated students was accurately reflected in NSLDS. However, in 2022 NSC had published information that indicated reliance solely on NSC’s process may result in the incorrect status being reported under certain circumstances. Although NSC error reports identified that such errors were present, UW-Madison indicated that it did not review these errors until fall 2024 when it began implementing new U.S. Department of Education reporting requirements.
At that time, UW-Madison stated that it identified that it did not consistently and accurately report in NSLDS those students who had graduated. UW-Madison stated that it then began to work with NSC to identify the extent of the reporting inaccuracies.
Third, in 2021 NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW-Madison’s data from its student information system and had communicated error or warning codes to UW-Madison in these areas. However, UW-Madison did not sufficiently review whether the records identified by NSC as potential errors resulted in inaccurate reporting. For example, NSC used warning codes for potential errors in the program-level enrollment status effective dates. As warning codes do not prohibit submission of reporting, UW-Madison did not review the warnings.
Fourth, in 2021 NSC similarly published information on accurately reporting student program begin dates in NSLDS and NSC had also identified instances of potential inaccurate reporting in UW Madison’s data from its student information system. Although NSC had communicated error or warning codes to UW-Madison in these areas, UW-Madison had not sufficiently reviewed whether the records identified by NSC as potential errors resulted in inaccurate reporting until 2023. At that time, UW-Madison indicated that, after reviewing other NSC warnings, it identified that it did not accurately report program begin dates for students. UW-Madison indicated it then began to work to update its student information system data extraction process to identify the correct program begin date for its submissions to NSC. However, it did not implement these changes until after the audit period.
In addition, UW-Madison indicated that it had turnover in staff responsible for NSLDS reporting in 2021, which may have caused UW-Madison to have missed the NSC publications regarding reporting graduated students accurately, new warning codes, and the importance of reviewing certain warning codes to accurately complete NSLDS reporting.
Recommendation:
We recommend the University of Wisconsin-Madison:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as updating its student information system to allow for an automated identification process to communicate those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated and implement separate reporting to the National Student Clearinghouse to accurately report students who graduate;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program-level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program begin dates and update its student information system extraction process to accurately report program begin dates; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-708: Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Background:
UW-Milwaukee receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Milwaukee reported a total of $133.1 million in federal financial assistance under the SFA Cluster. UW-Milwaukee records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Milwaukee is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Milwaukee is required to maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed.
Condition:
UW-Milwaukee uses NSC to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Milwaukee that identify potential errors in UW-Milwaukee’s reporting of student activities through NSC. These errors are the responsibility of UW-Milwaukee to resolve to ensure its submissions to NSLDS are accurate and complete.
UW-Milwaukee did not report to NSLDS accurate information for the program level enrollment status effective date for five students we reviewed. In addition, based on how information from its student information system is extracted for student reporting to NSLDS, we found that the reporting inaccuracy extended to other UW-Milwaukee students.
Context:
We discussed with UW-Milwaukee staff its procedures for identifying student enrollment status changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Milwaukee relies on data from its student information system to compile information to transmit to NSC. UW-Milwaukee also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included two students who withdrew from UW-Milwaukee and four students who graduated from UW- Milwaukee. In addition, we selected ten additional UW-Milwaukee students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Milwaukee did not comply with requirements to accurately report certain student enrollment status changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
In 2021, NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW- Milwaukee’s data from its student information system and had communicated error or warning codes to UW-Milwaukee in these areas. UW-Milwaukee staff indicated that they were aware that NSC error reports included warnings to identify potential inaccurate reporting of program level enrollment status effective dates and that the errors were a known issue for Peoplesoft-based student information systems. However, UW-Milwaukee chose not to use an all-record update feature that was available to correct the program-level enrollment status effective dates for all student records simultaneously due to the risk that other reporting inaccuracies could result from the action. Further, UW-Milwaukee staff indicated that they were not aware that specific guidance on the program-level enrollment status effective date had been updated to reflect that corrections should be made to fully comply with NSLDS reporting requirements.
Recommendation:
We recommend the University of Wisconsin-Milwaukee:
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates; and
-report changes in student enrollment accurately, completely, and in a timely manner for all student changes that require reporting.
Finding 2024-709: Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Milwaukee: The University of Wisconsin-Milwaukee agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Background:
UW-Oshkosh receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Oshkosh reported a total of $45.3 million in federal financial assistance under the SFA Cluster. UW-Oshkosh records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Oshkosh is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Oshkosh is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time; and
-report a student who has completed a program with a status of “graduated” rather than “withdrawn.”
Condition:
UW-Oshkosh uses NSC to facilitate the enrollment reporting in NSLDS. NSC provides error reports to UW-Oshkosh that identify potential errors in UW Oshkosh’s reporting of student activities. It is the responsibility of UW-Oshkosh to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Oshkosh did not report to NSLDS accurate information for two of the three students we reviewed.
First, UW-Oshkosh did not report in a timely manner one student who withdrew from enrollment without notification. Second, UW-Oshkosh incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment.
Context:
We discussed with UW-Oshkosh staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and UW Oshkosh’s procedures for monitoring the reporting performed by NSC. UW-Oshkosh relies on data from its student information system to compile information to transmit to NSC. UW-Oshkosh also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve. To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023 24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student who withdrew from UW-Oshkosh and two students who graduated from UW‑Oshkosh.
Questioned Costs:
None.
Effect:
UW-Oshkosh did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Oshkosh did not report to NSLDS in a timely manner who had withdrawn from enrollment without notification, we found that UW-Oshkosh indicated that it believed it needed to report to NSLDS only when students withdrew from enrollment and had notified UW-Oshkosh of the withdrawal. As a result, students detected by UW Oshkosh through procedures completed by the financial aid office at the end of each term were not communicated to those staff in the registrar’s office who were responsible for NSLDS reporting.
Second, for the student UW-Oshkosh did not accurately report as graduated within NSLDS, we found that inaccuracies in the reporting of students who had graduated were noted on NSC error reports. However, UW-Oshkosh’s registrar’s office staff did sufficiently review the errors to correct the status in NSLDS.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as communicating those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-710: Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Background:
UW Parkside operates in a highly computerized environment and is responsible for maintaining confidential and sensitive information, such as student data. UW Parkside maintains its own student information system to administer federal student financial assistance programs under the SFA Cluster.
Criteria:
To ensure data processed and stored by UW-Parkside is protected from accidental or intentional misuse or destruction, and to provide proper internal control, information technology (IT) security policies and procedures are necessary. In addition, IT controls should be established to prevent inappropriate or inadvertent access to data. UW-Parkside is responsible for following specific requirements under the Gramm-Leach-Bliley Act (GLBA), which requires entities that administer student financial assistance programs to develop, implement, and maintain safeguards to protect the security, integrity, and confidentiality of student data.
Under GLBA, UW-Parkside is required to authenticate and permit access only to authorized users. Further, UW Board of Regents Policy 25-5 requires that UW-Parkside follow the National Institute of Standards and Technology (NIST) in establishing IT controls. NIST Special Publication (SP) 800-53, Security and Privacy Controls for Information Systems and Organizations, recommends best practices in IT controls related to user access. These best practices include developing a provisioning and deprovisioning process focused on limiting access in a manner that provides the least access based on business need; retaining documentation of provisioning and deprovisioning activities, including records of when such access was added or removed; and performing periodic reviews of access to ensure it remains appropriate.
Condition:
We found UW-Parkside did not have adequate IT controls in place during FY 2023-24 to provision, deprovision, and manage access to its student information system. First, UW-Parkside did not have a formal documented process to provision or deprovision user access to its student information system. Second, UW-Parkside did not maintain a list of provisioned users with access and was unable to generate a report of users provisioned or deprovisioned during FY 2023-24. Third, UW-Parkside did not complete a periodic review of access, which assists in ensuring its provisioning and deprovisioning processes are working as intended. Although failure in any one IT control may be detected by complementary IT controls, UW‑Parkside did not have effective IT controls in any of the three areas. As a result, UW-Parkside was at a higher risk of granting unauthorized access to its student information system.
Context:
We reviewed GLBA requirements, UW System Board of Regents policies, and NIST 800-53 guidance to identify policies and procedures for UW-Parkside’s monitoring of access granted to its student information system. We requested documentation from UW-Parkside to assess compliance with these policies.
Questioned Costs:
None.
Effect:
Ineffective general IT controls may permit controls over systems to operate improperly and may allow noncompliance to occur and not be detected. Weaknesses in IT security policies, procedures, and controls increase the risk that unauthorized or erroneous transactions could be processed or changes made to student data. In addition, failure to provide an appropriate level of protection for its student information system and data increased the risk that personally identifiable information could be accidentally or maliciously exposed.
Cause:
UW-Parkside did not have a formal policy or procedures in place to provision, deprovision, and review access to its student information system. UW-Parkside staff indicated the process for provisioning and deprovisioning access had been informally operated, such as through electronic mail and direct communication and it did not consistently retain documentation of these communications. For example,
UW-Parkside indicated access requests were accepted from a variety of UW-Parkside employees. As a result, UW-Parkside had not assessed whether a user’s access was necessary or otherwise limited the access only to specific information needed or to a specified time period. Finally, UW-Parkside also indicated that prior efforts to improve its provisioning and deprovisioning of user access were not fully completed or implemented, in part, due to staff turnover.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-develop and implement written procedures for provisioning and deprovisioning user access to its student information system, including specifying those who are authorized to request user access and assigning responsibility to staff to assess access requests to restrict the access only to data needed for a specified period of time;
-retain consistent documentation of its provisioning and deprovisioning activities;
-develop and implement written procedures for a review at least annually of access granted to its student information system; and
-complete an assessment of users who currently have access to its student information system and remove those users who no longer require the access.
Finding 2024-711: Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Monthly Reconciliations
Background:
UW institutions receive funding for several grant and loan programs, such as Federal Direct Student Loans (Assistance Listing number 84.268) and the Federal Pell Grant Program (Assistance Listing number 84.063), from the U.S. Department of Education that are administered under the SFA Cluster. UW Oshkosh is required to comply with U.S. Department of Education requirements for disbursing funds to students under the Direct Student Loans and Pell Grant programs. This includes reporting disbursement activity in a U.S. Department of Education system in a timely manner. For FY 2023-24, UW-Oshkosh reported federal financial assistance of $29.7 million in Direct Student Loans and $10.3 million in Pell Grants.
Criteria:
Pursuant to 34 CFR s. 685.300 (b) (5), UW-Oshkosh is required to perform monthly reconciliations between U.S. Department of Education systems and its financial and business systems for all Direct Student Loans activity. The monthly reconciliations include two components:
-an external review between UW Oshkosh’s disbursements in its student information system compared to data in a U.S. Department of Education reporting system; and
-an internal reconciliation between UW Oshkosh’s student information system and its accounting system.
In addition, U.S. Department of Education guidance included in Volume 4, Chapter 5, of the Federal Student Aid Handbook, recommends that UW Oshkosh similarly complete monthly reconciliations for Pell Grant activity.
Condition:
Although UW-Oshkosh provided documentation for the external component of reconciliations it completed for the two months we selected to review for the Direct Student Loans and Pell Grant reconciliations during FY 2023 24, it did not provide documentation for the internal component of these reconciliations.
Context:
We reviewed and discussed UW Oshkosh’s procedures for performing monthly reconciliations for Direct Student Loans and Pell Grant disbursements. We selected two monthly Direct Student Loans and Pell Grant reconciliations and reviewed the internal and external reconciliation components for each month.
Questioned Costs:
None.
Effect:
Without documentation, UW-Oshkosh cannot be assured that it accurately completed the required reconciliations to identify whether Direct Student Loans or Pell Grant disbursements were properly reported to the U.S. Department of Education and other federal requirements were being met.
Cause:
UW-Oshkosh indicated that it was unable to locate documentation for the internal component of the reconciliation for the months we requested because the documentation was not retained in a shared folder. In addition, UW Oshkosh indicated that there had been staff turnover in the position that completed the reconciliations.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-ensure all required monthly reconciliations are completed in a timely manner; and
-retain documentation to support all monthly reconciliations it completes.
Finding 2024-700: Student Financial Assistance Cluster—UW-Oshkosh Monthly Reconciliations
Federal Pell Grant Program (Assistance Listing number 84.063)
Award Numbers Award Years
Various Various
Questioned Costs: None
Federal Direct Student Loans (Assistance Listing number 84.268)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-Madison must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. For students that begin attending classes, but who later withdraw from enrollment, 34 CFR s. 668.22 requires that UW-Madison must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In order not to consider a student to have withdrawn from enrollment under certain circumstances, which permits a student to retain federal financial assistance that otherwise would need to be returned to the federal government, 34 CFR s. 668.22 (a) (2) (ii) provides certain exemptions to students.
Condition:
For four students, we found that UW-Madison did not accurately determine the amount of federal financial assistance it disbursed that should have been returned to the U.S. Department of Education. First, we found that UW-Madison did not return all federal financial assistance it disbursed to two students that did not begin attendance and to one student who only attended one day during FY 2023-24. For these three students, UW-Madison determined it failed to return $16,403 in federal financial assistance it disbursed during FY 2023-24. Second, we found that UW-Madison did not accurately determine the federal financial assistance that should be returned after a student withdrew from enrollment during the summer 2023 term. For this student, UW-Madison incorrectly applied an exemption, which led to UW-Madison failing to return $584 in federal financial assistance to the U.S. Department of Education.
Context:
UW-Madison uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Madison staff its process for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Madison to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. When reviewing the data UW-Madison provided, we noted potential errors in the amount of aid returned for students identified as never attending.
Separately, as part of a UW systemwide sample of 60 students, we selected 6 students who had received federal financial assistance and who withdrew from enrollment from UW-Madison to determine the amount of federal financial assistance those students earned and the related amounts UW-Madison returned to the U.S. Department of Education.
Questioned Costs:
$16,987, Plus an Undetermined Amount
Effect:
UW-Madison did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Madison identified that the errors in determining the amount of the federal financial assistance that should have been returned to the federal government for the four students we identified were manual errors in the withdrawal procedures and calculations completed during and at the end of each term. These errors were not detected by any other review procedures. Although UW-Madison correctly identified the status of the two students who never attended and the need to return all disbursed federal financial assistance, it did not follow through on the actual repayment.
For the student who had an exemption applied, the exemption was incorrectly selected when UW-Madison completed a determination, and the error was not detected in UW-Madison’s review process. UW-Madison indicated that its automated review processes conducted at the end of each term did not specifically address the matters we identified for the four students.
After we identified these errors in the determination of the amount of federal financial assistance to return to the federal government, UW-Madison returned in fall 2024 the unearned federal financial assistance for the three students who never attended or withdrew from enrollment after attending one day. In addition, UW Madison returned the additional $584 in February 2025 for the student who withdrew from enrollment and did not meet the criteria for a withdrawal exemption.
Recommendation:
We recommend the University of Wisconsin-Madison review, update, and implement its procedures to improve the accuracy and follow-through for making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including thoroughly reviewing applied exemptions, and returning federal financial assistance in a timely manner to the federal government.
Finding 2024-703: Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,987, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Background:
UW-River Falls receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-River Falls reported a total of $23.6 million in federal financial assistance under the SFA Cluster. UW-River Falls is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-River Falls must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. Under Volume 5, Chapter 1 of the Federal Student Aid Handbook, when a student begins attendance in at least one course but does not begin attendance in all courses the student was scheduled to attend, the school must determine if it is necessary to recalculate the student’s eligibility for the Pell Grant based on a revised enrollment status and the cost of education pursuant to 34 CFR s. 690.80. If the student withdraws, this recalculation must be performed before determining whether to return federal financial assistance pursuant to 34 CFR s. 668.22.
Condition:
We found that UW-River Falls did not return $16,010 in federal financial assistance for four students that did not begin attendance in all enrolled courses during FY 2023-24. This included two students who never began attendance in any enrolled courses for whom all disbursed federal financial assistance was required to be returned. This also included two students who began at least one course but not all courses for which the students had enrolled. UW-River Falls did not perform the required recalculation of Pell Grant eligibility or an assessment of federal financial assistance it had disbursed that these students had not earned.
Context:
UW-River Falls uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-River Falls the process used for identifying students who did not begin attending all enrolled courses or withdrew from enrollment, and we requested a list of such students during FY 2023-24. UW-River Falls did not have a complete list readily available of students who did not begin attending all enrolled courses.
Questioned Costs:
$16,010, Plus an Undetermined Amount
Effect:
UW-River Falls did not comply with all requirements to return federal financial assistance for students who never attended or did not begin attending all enrolled courses during FY 2023-24.
Cause:
UW-River Falls did not have procedures to identify from its student information system, or other sources, those students for whom it disbursed federal financial assistance, yet the students did not attend at least one course during the term or begin all courses enrolled. Depending on whether a student dropped any of their courses, UW-River Falls indicated that the procedures to evaluate attendance may not have identified all students who would ultimately be determined as never attending for the academic term.
After we requested a list of students who did not begin attending all enrolled courses, UW-River Falls identified two students who did not begin at least one course but for whom it had disbursed federal financial assistance. For the other two students who began at least one course, UW-River Falls completed the required Pell Grant recalculation for the students. UW-River Falls also determined the amount of federal financial assistance to return for all four students, as applicable, to the U.S. Department of Education in September 2024.
Recommendation:
We recommend the University of Wisconsin-River Falls review, update, and implement procedures to:
-identify students after the start of each academic term for whom it disbursed federal financial assistance and the students did not begin all enrolled courses;
-complete required recalculations for Pell Grant eligibility and a determination of federal financial assistance that was not earned by the students, as applicable; and
-return amounts to the federal government in a timely manner.
Finding 2024-704: Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,010, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-River Falls: The University of Wisconsin-River Falls agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Background:
UW-Parkside receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Parkside reported a total of $21.3 million in federal financial assistance under the SFA Cluster. UW-Parkside is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22, requires that UW-Parkside must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW Parkside should be returned to the U.S. Department of Education unless certain conditions are met. In determining whether federal financial assistance was earned by a student, the Federal Student Aid Handbook provides guidance on how to calculate applicable institution charges and academic days under different circumstances.
Condition:
For two of three students we reviewed who withdrew from enrollment during FY 2023-24, UW-Parkside inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Parkside incorrectly accounted for a disbursement that occurred after the student’s withdrawal from enrollment as an amount that was earned by the student for the fall 2023 term. As a result, UW Parkside returned $548 less than what should have been returned to the U.S. Department of Education. For the second student, UW-Parkside incorrectly identified the end date of the spring 2024 term and did not include the correct institutional charges in its determination. As a result, UW-Parkside returned $1,190 less than should have been returned to the U.S. Department of Education.
Context:
UW-Parkside uses a student information system to track activity for students that withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Parkside staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from
UW-Parkside to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 3 students who had received federal financial assistance and withdrew from UW-Parkside to determine the amount of federal financial assistance those students earned and the related amounts UW-Parkside returned to the U.S. Department of Education.
Questioned Costs:
$1,738, Plus an Undetermined Amount
Effect:
UW-Parkside did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Parkside did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal assistance to return. Although UW-Parkside disbursed federal financial assistance later than is typical to one student, the disbursement was not correctly categorized within the calculations completed by UW-Parkside to determine that the entire amount of the federal financial assistance was required to be returned to the federal government.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the students we identified.
Finding 2024-705: Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $1,738, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Background:
UW-Platteville receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Platteville reported a total of $29.1 million in federal financial assistance under the SFA Cluster. UW-Platteville is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Under 34 CFR s. 668.21, UW-Platteville must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. In addition, when a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Platteville must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In determining whether federal financial assistance was earned by a student, Volume 5, Chapter 2 of the Federal Student Aid Handbook specifies how to calculate academic days.
Condition:
For two of the five students we reviewed who never began attendance or who withdrew from enrollment during FY 2023-24, UW-Platteville inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Platteville incorrectly determined the student began attendance because the student attended one day of the fall 2023 term. As a result, UW-Platteville failed to return $24 in federal financial assistance to the U.S. Department of Education. For the second student, UW-Platteville did not exclude a five-day break from its determination of the federal financial assistance amount the student had earned during the fall 2023 term. Although this student had earned all of the federal financial assistance prior to the student’s withdrawal from enrollment, UW-Platteville incorrectly returned $1,226. Because UW-Platteville used the same calculation for all determinations for the fall 2023 term, there may be further errors in the federal financial assistance amounts UW-Platteville determined.
Context:
UW-Platteville uses a student information system to track activity for students who withdraw from enrollment in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Platteville staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Platteville to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 5 students who had received federal financial assistance and who withdrew from UW-Platteville to determine the amount of federal financial assistance those students earned and the related amounts UW-Platteville returned to the U.S. Department of Education.
Questioned Costs:
$24, Plus an Undetermined Amount
Effect:
UW-Platteville did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Platteville did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal financial assistance to return to the federal government. After we identified the error for the student who attended only one day, UW-Platteville returned the additional $24 to the federal government in November 2024. For the fall 2023 term, UW-Platteville changed its fall break from four to five days, which required a change in the number of academic days used in the calculation of federal financial assistance earned when a student withdraws from enrollment. UW-Platteville did not have a process to review the academic calendar for purposes of its return procedures.
Recommendation:
We recommend the University of Wisconsin-Platteville review, update, and implement its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including annually reviewing the academic days used in its determinations.
Finding 2024-706: Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $24, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Platteville: The University of Wisconsin-Platteville agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Background:
UW-Whitewater receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Whitewater reported a total of $58.4 million in federal financial assistance under the SFA Cluster. UW-Whitewater is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Whitewater must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook, the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW-Whitewater is required to be returned to the U.S. Department of Education unless certain conditions are met.
Condition:
UW-Whitewater inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education for one of seven students we reviewed who withdrew from enrollment during FY 2023 24. UW-Whitewater incorrectly accounted for a disbursement to the student that occurred after the date for which UW-Whitewater later identified the student had withdrawn from enrollment as an amount that was earned by the student. As a result, UW-Whitewater failed to return $400 in federal financial assistance to the U.S. Department of Education for the spring 2024 term.
Context:
In order to determine the federal financial assistance a student earned and the amount that must be returned to the U.S. Department of Education for amounts a student did not earn, UW-Whitewater uses a student information system to track activity for students who withdraw. We discussed with UW-Whitewater staff the process used for identifying students who withdrew from enrollment. We also requested information from UW-Whitewater to identify students who withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 7 students who had received federal financial assistance and who withdrew from UW-Whitewater to determine the amount of federal financial assistance those students earned and the related amounts UW-Whitewater returned to the U.S. Department of Education.
Questioned Costs:
$400, Plus an Undetermined Amount
Effect:
UW-Whitewater did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Whitewater did not have adequate procedures to review and ensure its determination of the amount of federal assistance to return was accurate. Although UW-Whitewater disbursed federal financial assistance later than is typical to the student, the disbursement was not correctly categorized within the calculations completed by UW-Whitewater nor was the categorization error detected by other
UW-Whitewater procedures.
Recommendation:
We recommend the University of Wisconsin-Whitewater:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the student we identified.
Finding 2024-707: Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $400, Plus an Undetermined Amount
Type of Finding: Noncompliance
Response from the University of Wisconsin-Whitewater: The University of Wisconsin-Whitewater agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Madison is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to the National Student Loan Data System (NSLDS). Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Madison is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time;
-report the same effective date for a student who withdraws from enrollment as the date used in its determination of whether any federal financial assistance must be returned in accordance with
34 CFR s. 668.22;
-report a student who has completed a program with a status of “graduated” rather than “withdrawn”;
-maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed; and
-maintain the program begin date, which is the date the student first began attending the program being reported, if a student’s program of study has not changed.
Condition:
UW-Madison uses the National Student Clearinghouse (NSC) to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Madison that identify potential errors in UW-Madison’s reporting of student activities. It is the responsibility of UW-Madison to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Madison did not report to NSLDS accurate information for 12 of the 17 students we reviewed. First, UW-Madison did not accurately report a student who withdrew from enrollment without notification in a timely manner. Second, UW-Madison incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment. Third, UW-Madison incorrectly reported the program-level enrollment status effective date for two students. Fourth, UW-Madison incorrectly reported the program begin date for six students. In addition, UW Madison incorrectly reported both the program-level enrollment status effective date and program begin date for two students.
Context:
We discussed with UW-Madison staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Madison relies on data from its student information system to compile information to transmit to NSC. UW-Madison also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student that withdrew from UW-Madison and six students who graduated from UW-Madison. In addition, we selected ten additional UW-Madison students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Madison did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Madison did not report to NSLDS who had withdrawn from enrollment without notification, we found UW-Madison’s enrollment reporting procedures did not assign responsibility for communicating certain information to those staff in the registrar’s office who are responsible for NSLDS reporting. As a result, those students the financial aid office determined had withdrawn from enrollment without notification, and for which it had completed a determination of federal financial assistance the students did not earn, were not known to staff in the registrar’s office for purposes of NSLDS reporting. In addition, UW-Madison indicated that withdrawals from enrollment without notification are identified after the term ends and its student information system did not have a dedicated effective date field in order to automatically identify such student records for the required NSLDS reporting.
Second, for the student UW-Madison did not accurately report as graduated within NSLDS, we found UW‑Madison relied on a NSC process that is intended to simultaneously update a student’s enrollment status in NSLDS when UW-Madison separately updates a student’s degree as completed. UW-Madison did not complete a separate report to ensure the enrollment status for graduated students was accurately reflected in NSLDS. However, in 2022 NSC had published information that indicated reliance solely on NSC’s process may result in the incorrect status being reported under certain circumstances. Although NSC error reports identified that such errors were present, UW-Madison indicated that it did not review these errors until fall 2024 when it began implementing new U.S. Department of Education reporting requirements.
At that time, UW-Madison stated that it identified that it did not consistently and accurately report in NSLDS those students who had graduated. UW-Madison stated that it then began to work with NSC to identify the extent of the reporting inaccuracies.
Third, in 2021 NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW-Madison’s data from its student information system and had communicated error or warning codes to UW-Madison in these areas. However, UW-Madison did not sufficiently review whether the records identified by NSC as potential errors resulted in inaccurate reporting. For example, NSC used warning codes for potential errors in the program-level enrollment status effective dates. As warning codes do not prohibit submission of reporting, UW-Madison did not review the warnings.
Fourth, in 2021 NSC similarly published information on accurately reporting student program begin dates in NSLDS and NSC had also identified instances of potential inaccurate reporting in UW Madison’s data from its student information system. Although NSC had communicated error or warning codes to UW-Madison in these areas, UW-Madison had not sufficiently reviewed whether the records identified by NSC as potential errors resulted in inaccurate reporting until 2023. At that time, UW-Madison indicated that, after reviewing other NSC warnings, it identified that it did not accurately report program begin dates for students. UW-Madison indicated it then began to work to update its student information system data extraction process to identify the correct program begin date for its submissions to NSC. However, it did not implement these changes until after the audit period.
In addition, UW-Madison indicated that it had turnover in staff responsible for NSLDS reporting in 2021, which may have caused UW-Madison to have missed the NSC publications regarding reporting graduated students accurately, new warning codes, and the importance of reviewing certain warning codes to accurately complete NSLDS reporting.
Recommendation:
We recommend the University of Wisconsin-Madison:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as updating its student information system to allow for an automated identification process to communicate those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated and implement separate reporting to the National Student Clearinghouse to accurately report students who graduate;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program-level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program begin dates and update its student information system extraction process to accurately report program begin dates; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-708: Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Background:
UW-Milwaukee receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Milwaukee reported a total of $133.1 million in federal financial assistance under the SFA Cluster. UW-Milwaukee records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Milwaukee is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Milwaukee is required to maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed.
Condition:
UW-Milwaukee uses NSC to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Milwaukee that identify potential errors in UW-Milwaukee’s reporting of student activities through NSC. These errors are the responsibility of UW-Milwaukee to resolve to ensure its submissions to NSLDS are accurate and complete.
UW-Milwaukee did not report to NSLDS accurate information for the program level enrollment status effective date for five students we reviewed. In addition, based on how information from its student information system is extracted for student reporting to NSLDS, we found that the reporting inaccuracy extended to other UW-Milwaukee students.
Context:
We discussed with UW-Milwaukee staff its procedures for identifying student enrollment status changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Milwaukee relies on data from its student information system to compile information to transmit to NSC. UW-Milwaukee also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included two students who withdrew from UW-Milwaukee and four students who graduated from UW- Milwaukee. In addition, we selected ten additional UW-Milwaukee students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Milwaukee did not comply with requirements to accurately report certain student enrollment status changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
In 2021, NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW- Milwaukee’s data from its student information system and had communicated error or warning codes to UW-Milwaukee in these areas. UW-Milwaukee staff indicated that they were aware that NSC error reports included warnings to identify potential inaccurate reporting of program level enrollment status effective dates and that the errors were a known issue for Peoplesoft-based student information systems. However, UW-Milwaukee chose not to use an all-record update feature that was available to correct the program-level enrollment status effective dates for all student records simultaneously due to the risk that other reporting inaccuracies could result from the action. Further, UW-Milwaukee staff indicated that they were not aware that specific guidance on the program-level enrollment status effective date had been updated to reflect that corrections should be made to fully comply with NSLDS reporting requirements.
Recommendation:
We recommend the University of Wisconsin-Milwaukee:
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates; and
-report changes in student enrollment accurately, completely, and in a timely manner for all student changes that require reporting.
Finding 2024-709: Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Milwaukee: The University of Wisconsin-Milwaukee agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Background:
UW-Oshkosh receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Oshkosh reported a total of $45.3 million in federal financial assistance under the SFA Cluster. UW-Oshkosh records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Oshkosh is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Oshkosh is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time; and
-report a student who has completed a program with a status of “graduated” rather than “withdrawn.”
Condition:
UW-Oshkosh uses NSC to facilitate the enrollment reporting in NSLDS. NSC provides error reports to UW-Oshkosh that identify potential errors in UW Oshkosh’s reporting of student activities. It is the responsibility of UW-Oshkosh to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Oshkosh did not report to NSLDS accurate information for two of the three students we reviewed.
First, UW-Oshkosh did not report in a timely manner one student who withdrew from enrollment without notification. Second, UW-Oshkosh incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment.
Context:
We discussed with UW-Oshkosh staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and UW Oshkosh’s procedures for monitoring the reporting performed by NSC. UW-Oshkosh relies on data from its student information system to compile information to transmit to NSC. UW-Oshkosh also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve. To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023 24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student who withdrew from UW-Oshkosh and two students who graduated from UW‑Oshkosh.
Questioned Costs:
None.
Effect:
UW-Oshkosh did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Oshkosh did not report to NSLDS in a timely manner who had withdrawn from enrollment without notification, we found that UW-Oshkosh indicated that it believed it needed to report to NSLDS only when students withdrew from enrollment and had notified UW-Oshkosh of the withdrawal. As a result, students detected by UW Oshkosh through procedures completed by the financial aid office at the end of each term were not communicated to those staff in the registrar’s office who were responsible for NSLDS reporting.
Second, for the student UW-Oshkosh did not accurately report as graduated within NSLDS, we found that inaccuracies in the reporting of students who had graduated were noted on NSC error reports. However, UW-Oshkosh’s registrar’s office staff did sufficiently review the errors to correct the status in NSLDS.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as communicating those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-710: Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Background:
UW Parkside operates in a highly computerized environment and is responsible for maintaining confidential and sensitive information, such as student data. UW Parkside maintains its own student information system to administer federal student financial assistance programs under the SFA Cluster.
Criteria:
To ensure data processed and stored by UW-Parkside is protected from accidental or intentional misuse or destruction, and to provide proper internal control, information technology (IT) security policies and procedures are necessary. In addition, IT controls should be established to prevent inappropriate or inadvertent access to data. UW-Parkside is responsible for following specific requirements under the Gramm-Leach-Bliley Act (GLBA), which requires entities that administer student financial assistance programs to develop, implement, and maintain safeguards to protect the security, integrity, and confidentiality of student data.
Under GLBA, UW-Parkside is required to authenticate and permit access only to authorized users. Further, UW Board of Regents Policy 25-5 requires that UW-Parkside follow the National Institute of Standards and Technology (NIST) in establishing IT controls. NIST Special Publication (SP) 800-53, Security and Privacy Controls for Information Systems and Organizations, recommends best practices in IT controls related to user access. These best practices include developing a provisioning and deprovisioning process focused on limiting access in a manner that provides the least access based on business need; retaining documentation of provisioning and deprovisioning activities, including records of when such access was added or removed; and performing periodic reviews of access to ensure it remains appropriate.
Condition:
We found UW-Parkside did not have adequate IT controls in place during FY 2023-24 to provision, deprovision, and manage access to its student information system. First, UW-Parkside did not have a formal documented process to provision or deprovision user access to its student information system. Second, UW-Parkside did not maintain a list of provisioned users with access and was unable to generate a report of users provisioned or deprovisioned during FY 2023-24. Third, UW-Parkside did not complete a periodic review of access, which assists in ensuring its provisioning and deprovisioning processes are working as intended. Although failure in any one IT control may be detected by complementary IT controls, UW‑Parkside did not have effective IT controls in any of the three areas. As a result, UW-Parkside was at a higher risk of granting unauthorized access to its student information system.
Context:
We reviewed GLBA requirements, UW System Board of Regents policies, and NIST 800-53 guidance to identify policies and procedures for UW-Parkside’s monitoring of access granted to its student information system. We requested documentation from UW-Parkside to assess compliance with these policies.
Questioned Costs:
None.
Effect:
Ineffective general IT controls may permit controls over systems to operate improperly and may allow noncompliance to occur and not be detected. Weaknesses in IT security policies, procedures, and controls increase the risk that unauthorized or erroneous transactions could be processed or changes made to student data. In addition, failure to provide an appropriate level of protection for its student information system and data increased the risk that personally identifiable information could be accidentally or maliciously exposed.
Cause:
UW-Parkside did not have a formal policy or procedures in place to provision, deprovision, and review access to its student information system. UW-Parkside staff indicated the process for provisioning and deprovisioning access had been informally operated, such as through electronic mail and direct communication and it did not consistently retain documentation of these communications. For example,
UW-Parkside indicated access requests were accepted from a variety of UW-Parkside employees. As a result, UW-Parkside had not assessed whether a user’s access was necessary or otherwise limited the access only to specific information needed or to a specified time period. Finally, UW-Parkside also indicated that prior efforts to improve its provisioning and deprovisioning of user access were not fully completed or implemented, in part, due to staff turnover.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-develop and implement written procedures for provisioning and deprovisioning user access to its student information system, including specifying those who are authorized to request user access and assigning responsibility to staff to assess access requests to restrict the access only to data needed for a specified period of time;
-retain consistent documentation of its provisioning and deprovisioning activities;
-develop and implement written procedures for a review at least annually of access granted to its student information system; and
-complete an assessment of users who currently have access to its student information system and remove those users who no longer require the access.
Finding 2024-711: Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-Madison must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. For students that begin attending classes, but who later withdraw from enrollment, 34 CFR s. 668.22 requires that UW-Madison must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In order not to consider a student to have withdrawn from enrollment under certain circumstances, which permits a student to retain federal financial assistance that otherwise would need to be returned to the federal government, 34 CFR s. 668.22 (a) (2) (ii) provides certain exemptions to students.
Condition:
For four students, we found that UW-Madison did not accurately determine the amount of federal financial assistance it disbursed that should have been returned to the U.S. Department of Education. First, we found that UW-Madison did not return all federal financial assistance it disbursed to two students that did not begin attendance and to one student who only attended one day during FY 2023-24. For these three students, UW-Madison determined it failed to return $16,403 in federal financial assistance it disbursed during FY 2023-24. Second, we found that UW-Madison did not accurately determine the federal financial assistance that should be returned after a student withdrew from enrollment during the summer 2023 term. For this student, UW-Madison incorrectly applied an exemption, which led to UW-Madison failing to return $584 in federal financial assistance to the U.S. Department of Education.
Context:
UW-Madison uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Madison staff its process for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Madison to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. When reviewing the data UW-Madison provided, we noted potential errors in the amount of aid returned for students identified as never attending.
Separately, as part of a UW systemwide sample of 60 students, we selected 6 students who had received federal financial assistance and who withdrew from enrollment from UW-Madison to determine the amount of federal financial assistance those students earned and the related amounts UW-Madison returned to the U.S. Department of Education.
Questioned Costs:
$16,987, Plus an Undetermined Amount
Effect:
UW-Madison did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Madison identified that the errors in determining the amount of the federal financial assistance that should have been returned to the federal government for the four students we identified were manual errors in the withdrawal procedures and calculations completed during and at the end of each term. These errors were not detected by any other review procedures. Although UW-Madison correctly identified the status of the two students who never attended and the need to return all disbursed federal financial assistance, it did not follow through on the actual repayment.
For the student who had an exemption applied, the exemption was incorrectly selected when UW-Madison completed a determination, and the error was not detected in UW-Madison’s review process. UW-Madison indicated that its automated review processes conducted at the end of each term did not specifically address the matters we identified for the four students.
After we identified these errors in the determination of the amount of federal financial assistance to return to the federal government, UW-Madison returned in fall 2024 the unearned federal financial assistance for the three students who never attended or withdrew from enrollment after attending one day. In addition, UW Madison returned the additional $584 in February 2025 for the student who withdrew from enrollment and did not meet the criteria for a withdrawal exemption.
Recommendation:
We recommend the University of Wisconsin-Madison review, update, and implement its procedures to improve the accuracy and follow-through for making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including thoroughly reviewing applied exemptions, and returning federal financial assistance in a timely manner to the federal government.
Finding 2024-703: Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,987, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Background:
UW-River Falls receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-River Falls reported a total of $23.6 million in federal financial assistance under the SFA Cluster. UW-River Falls is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-River Falls must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. Under Volume 5, Chapter 1 of the Federal Student Aid Handbook, when a student begins attendance in at least one course but does not begin attendance in all courses the student was scheduled to attend, the school must determine if it is necessary to recalculate the student’s eligibility for the Pell Grant based on a revised enrollment status and the cost of education pursuant to 34 CFR s. 690.80. If the student withdraws, this recalculation must be performed before determining whether to return federal financial assistance pursuant to 34 CFR s. 668.22.
Condition:
We found that UW-River Falls did not return $16,010 in federal financial assistance for four students that did not begin attendance in all enrolled courses during FY 2023-24. This included two students who never began attendance in any enrolled courses for whom all disbursed federal financial assistance was required to be returned. This also included two students who began at least one course but not all courses for which the students had enrolled. UW-River Falls did not perform the required recalculation of Pell Grant eligibility or an assessment of federal financial assistance it had disbursed that these students had not earned.
Context:
UW-River Falls uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-River Falls the process used for identifying students who did not begin attending all enrolled courses or withdrew from enrollment, and we requested a list of such students during FY 2023-24. UW-River Falls did not have a complete list readily available of students who did not begin attending all enrolled courses.
Questioned Costs:
$16,010, Plus an Undetermined Amount
Effect:
UW-River Falls did not comply with all requirements to return federal financial assistance for students who never attended or did not begin attending all enrolled courses during FY 2023-24.
Cause:
UW-River Falls did not have procedures to identify from its student information system, or other sources, those students for whom it disbursed federal financial assistance, yet the students did not attend at least one course during the term or begin all courses enrolled. Depending on whether a student dropped any of their courses, UW-River Falls indicated that the procedures to evaluate attendance may not have identified all students who would ultimately be determined as never attending for the academic term.
After we requested a list of students who did not begin attending all enrolled courses, UW-River Falls identified two students who did not begin at least one course but for whom it had disbursed federal financial assistance. For the other two students who began at least one course, UW-River Falls completed the required Pell Grant recalculation for the students. UW-River Falls also determined the amount of federal financial assistance to return for all four students, as applicable, to the U.S. Department of Education in September 2024.
Recommendation:
We recommend the University of Wisconsin-River Falls review, update, and implement procedures to:
-identify students after the start of each academic term for whom it disbursed federal financial assistance and the students did not begin all enrolled courses;
-complete required recalculations for Pell Grant eligibility and a determination of federal financial assistance that was not earned by the students, as applicable; and
-return amounts to the federal government in a timely manner.
Finding 2024-704: Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,010, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-River Falls: The University of Wisconsin-River Falls agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Background:
UW-Parkside receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Parkside reported a total of $21.3 million in federal financial assistance under the SFA Cluster. UW-Parkside is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22, requires that UW-Parkside must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW Parkside should be returned to the U.S. Department of Education unless certain conditions are met. In determining whether federal financial assistance was earned by a student, the Federal Student Aid Handbook provides guidance on how to calculate applicable institution charges and academic days under different circumstances.
Condition:
For two of three students we reviewed who withdrew from enrollment during FY 2023-24, UW-Parkside inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Parkside incorrectly accounted for a disbursement that occurred after the student’s withdrawal from enrollment as an amount that was earned by the student for the fall 2023 term. As a result, UW Parkside returned $548 less than what should have been returned to the U.S. Department of Education. For the second student, UW-Parkside incorrectly identified the end date of the spring 2024 term and did not include the correct institutional charges in its determination. As a result, UW-Parkside returned $1,190 less than should have been returned to the U.S. Department of Education.
Context:
UW-Parkside uses a student information system to track activity for students that withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Parkside staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from
UW-Parkside to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 3 students who had received federal financial assistance and withdrew from UW-Parkside to determine the amount of federal financial assistance those students earned and the related amounts UW-Parkside returned to the U.S. Department of Education.
Questioned Costs:
$1,738, Plus an Undetermined Amount
Effect:
UW-Parkside did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Parkside did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal assistance to return. Although UW-Parkside disbursed federal financial assistance later than is typical to one student, the disbursement was not correctly categorized within the calculations completed by UW-Parkside to determine that the entire amount of the federal financial assistance was required to be returned to the federal government.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the students we identified.
Finding 2024-705: Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $1,738, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Background:
UW-Platteville receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Platteville reported a total of $29.1 million in federal financial assistance under the SFA Cluster. UW-Platteville is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Under 34 CFR s. 668.21, UW-Platteville must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. In addition, when a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Platteville must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In determining whether federal financial assistance was earned by a student, Volume 5, Chapter 2 of the Federal Student Aid Handbook specifies how to calculate academic days.
Condition:
For two of the five students we reviewed who never began attendance or who withdrew from enrollment during FY 2023-24, UW-Platteville inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Platteville incorrectly determined the student began attendance because the student attended one day of the fall 2023 term. As a result, UW-Platteville failed to return $24 in federal financial assistance to the U.S. Department of Education. For the second student, UW-Platteville did not exclude a five-day break from its determination of the federal financial assistance amount the student had earned during the fall 2023 term. Although this student had earned all of the federal financial assistance prior to the student’s withdrawal from enrollment, UW-Platteville incorrectly returned $1,226. Because UW-Platteville used the same calculation for all determinations for the fall 2023 term, there may be further errors in the federal financial assistance amounts UW-Platteville determined.
Context:
UW-Platteville uses a student information system to track activity for students who withdraw from enrollment in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Platteville staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Platteville to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 5 students who had received federal financial assistance and who withdrew from UW-Platteville to determine the amount of federal financial assistance those students earned and the related amounts UW-Platteville returned to the U.S. Department of Education.
Questioned Costs:
$24, Plus an Undetermined Amount
Effect:
UW-Platteville did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Platteville did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal financial assistance to return to the federal government. After we identified the error for the student who attended only one day, UW-Platteville returned the additional $24 to the federal government in November 2024. For the fall 2023 term, UW-Platteville changed its fall break from four to five days, which required a change in the number of academic days used in the calculation of federal financial assistance earned when a student withdraws from enrollment. UW-Platteville did not have a process to review the academic calendar for purposes of its return procedures.
Recommendation:
We recommend the University of Wisconsin-Platteville review, update, and implement its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including annually reviewing the academic days used in its determinations.
Finding 2024-706: Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $24, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Platteville: The University of Wisconsin-Platteville agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Background:
UW-Whitewater receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Whitewater reported a total of $58.4 million in federal financial assistance under the SFA Cluster. UW-Whitewater is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Whitewater must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook, the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW-Whitewater is required to be returned to the U.S. Department of Education unless certain conditions are met.
Condition:
UW-Whitewater inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education for one of seven students we reviewed who withdrew from enrollment during FY 2023 24. UW-Whitewater incorrectly accounted for a disbursement to the student that occurred after the date for which UW-Whitewater later identified the student had withdrawn from enrollment as an amount that was earned by the student. As a result, UW-Whitewater failed to return $400 in federal financial assistance to the U.S. Department of Education for the spring 2024 term.
Context:
In order to determine the federal financial assistance a student earned and the amount that must be returned to the U.S. Department of Education for amounts a student did not earn, UW-Whitewater uses a student information system to track activity for students who withdraw. We discussed with UW-Whitewater staff the process used for identifying students who withdrew from enrollment. We also requested information from UW-Whitewater to identify students who withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 7 students who had received federal financial assistance and who withdrew from UW-Whitewater to determine the amount of federal financial assistance those students earned and the related amounts UW-Whitewater returned to the U.S. Department of Education.
Questioned Costs:
$400, Plus an Undetermined Amount
Effect:
UW-Whitewater did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Whitewater did not have adequate procedures to review and ensure its determination of the amount of federal assistance to return was accurate. Although UW-Whitewater disbursed federal financial assistance later than is typical to the student, the disbursement was not correctly categorized within the calculations completed by UW-Whitewater nor was the categorization error detected by other
UW-Whitewater procedures.
Recommendation:
We recommend the University of Wisconsin-Whitewater:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the student we identified.
Finding 2024-707: Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $400, Plus an Undetermined Amount
Type of Finding: Noncompliance
Response from the University of Wisconsin-Whitewater: The University of Wisconsin-Whitewater agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Madison is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to the National Student Loan Data System (NSLDS). Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Madison is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time;
-report the same effective date for a student who withdraws from enrollment as the date used in its determination of whether any federal financial assistance must be returned in accordance with
34 CFR s. 668.22;
-report a student who has completed a program with a status of “graduated” rather than “withdrawn”;
-maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed; and
-maintain the program begin date, which is the date the student first began attending the program being reported, if a student’s program of study has not changed.
Condition:
UW-Madison uses the National Student Clearinghouse (NSC) to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Madison that identify potential errors in UW-Madison’s reporting of student activities. It is the responsibility of UW-Madison to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Madison did not report to NSLDS accurate information for 12 of the 17 students we reviewed. First, UW-Madison did not accurately report a student who withdrew from enrollment without notification in a timely manner. Second, UW-Madison incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment. Third, UW-Madison incorrectly reported the program-level enrollment status effective date for two students. Fourth, UW-Madison incorrectly reported the program begin date for six students. In addition, UW Madison incorrectly reported both the program-level enrollment status effective date and program begin date for two students.
Context:
We discussed with UW-Madison staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Madison relies on data from its student information system to compile information to transmit to NSC. UW-Madison also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student that withdrew from UW-Madison and six students who graduated from UW-Madison. In addition, we selected ten additional UW-Madison students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Madison did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Madison did not report to NSLDS who had withdrawn from enrollment without notification, we found UW-Madison’s enrollment reporting procedures did not assign responsibility for communicating certain information to those staff in the registrar’s office who are responsible for NSLDS reporting. As a result, those students the financial aid office determined had withdrawn from enrollment without notification, and for which it had completed a determination of federal financial assistance the students did not earn, were not known to staff in the registrar’s office for purposes of NSLDS reporting. In addition, UW-Madison indicated that withdrawals from enrollment without notification are identified after the term ends and its student information system did not have a dedicated effective date field in order to automatically identify such student records for the required NSLDS reporting.
Second, for the student UW-Madison did not accurately report as graduated within NSLDS, we found UW‑Madison relied on a NSC process that is intended to simultaneously update a student’s enrollment status in NSLDS when UW-Madison separately updates a student’s degree as completed. UW-Madison did not complete a separate report to ensure the enrollment status for graduated students was accurately reflected in NSLDS. However, in 2022 NSC had published information that indicated reliance solely on NSC’s process may result in the incorrect status being reported under certain circumstances. Although NSC error reports identified that such errors were present, UW-Madison indicated that it did not review these errors until fall 2024 when it began implementing new U.S. Department of Education reporting requirements.
At that time, UW-Madison stated that it identified that it did not consistently and accurately report in NSLDS those students who had graduated. UW-Madison stated that it then began to work with NSC to identify the extent of the reporting inaccuracies.
Third, in 2021 NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW-Madison’s data from its student information system and had communicated error or warning codes to UW-Madison in these areas. However, UW-Madison did not sufficiently review whether the records identified by NSC as potential errors resulted in inaccurate reporting. For example, NSC used warning codes for potential errors in the program-level enrollment status effective dates. As warning codes do not prohibit submission of reporting, UW-Madison did not review the warnings.
Fourth, in 2021 NSC similarly published information on accurately reporting student program begin dates in NSLDS and NSC had also identified instances of potential inaccurate reporting in UW Madison’s data from its student information system. Although NSC had communicated error or warning codes to UW-Madison in these areas, UW-Madison had not sufficiently reviewed whether the records identified by NSC as potential errors resulted in inaccurate reporting until 2023. At that time, UW-Madison indicated that, after reviewing other NSC warnings, it identified that it did not accurately report program begin dates for students. UW-Madison indicated it then began to work to update its student information system data extraction process to identify the correct program begin date for its submissions to NSC. However, it did not implement these changes until after the audit period.
In addition, UW-Madison indicated that it had turnover in staff responsible for NSLDS reporting in 2021, which may have caused UW-Madison to have missed the NSC publications regarding reporting graduated students accurately, new warning codes, and the importance of reviewing certain warning codes to accurately complete NSLDS reporting.
Recommendation:
We recommend the University of Wisconsin-Madison:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as updating its student information system to allow for an automated identification process to communicate those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated and implement separate reporting to the National Student Clearinghouse to accurately report students who graduate;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program-level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program begin dates and update its student information system extraction process to accurately report program begin dates; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-708: Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Background:
UW-Milwaukee receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Milwaukee reported a total of $133.1 million in federal financial assistance under the SFA Cluster. UW-Milwaukee records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Milwaukee is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Milwaukee is required to maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed.
Condition:
UW-Milwaukee uses NSC to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Milwaukee that identify potential errors in UW-Milwaukee’s reporting of student activities through NSC. These errors are the responsibility of UW-Milwaukee to resolve to ensure its submissions to NSLDS are accurate and complete.
UW-Milwaukee did not report to NSLDS accurate information for the program level enrollment status effective date for five students we reviewed. In addition, based on how information from its student information system is extracted for student reporting to NSLDS, we found that the reporting inaccuracy extended to other UW-Milwaukee students.
Context:
We discussed with UW-Milwaukee staff its procedures for identifying student enrollment status changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Milwaukee relies on data from its student information system to compile information to transmit to NSC. UW-Milwaukee also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included two students who withdrew from UW-Milwaukee and four students who graduated from UW- Milwaukee. In addition, we selected ten additional UW-Milwaukee students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Milwaukee did not comply with requirements to accurately report certain student enrollment status changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
In 2021, NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW- Milwaukee’s data from its student information system and had communicated error or warning codes to UW-Milwaukee in these areas. UW-Milwaukee staff indicated that they were aware that NSC error reports included warnings to identify potential inaccurate reporting of program level enrollment status effective dates and that the errors were a known issue for Peoplesoft-based student information systems. However, UW-Milwaukee chose not to use an all-record update feature that was available to correct the program-level enrollment status effective dates for all student records simultaneously due to the risk that other reporting inaccuracies could result from the action. Further, UW-Milwaukee staff indicated that they were not aware that specific guidance on the program-level enrollment status effective date had been updated to reflect that corrections should be made to fully comply with NSLDS reporting requirements.
Recommendation:
We recommend the University of Wisconsin-Milwaukee:
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates; and
-report changes in student enrollment accurately, completely, and in a timely manner for all student changes that require reporting.
Finding 2024-709: Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Milwaukee: The University of Wisconsin-Milwaukee agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Background:
UW-Oshkosh receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Oshkosh reported a total of $45.3 million in federal financial assistance under the SFA Cluster. UW-Oshkosh records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Oshkosh is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Oshkosh is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time; and
-report a student who has completed a program with a status of “graduated” rather than “withdrawn.”
Condition:
UW-Oshkosh uses NSC to facilitate the enrollment reporting in NSLDS. NSC provides error reports to UW-Oshkosh that identify potential errors in UW Oshkosh’s reporting of student activities. It is the responsibility of UW-Oshkosh to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Oshkosh did not report to NSLDS accurate information for two of the three students we reviewed.
First, UW-Oshkosh did not report in a timely manner one student who withdrew from enrollment without notification. Second, UW-Oshkosh incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment.
Context:
We discussed with UW-Oshkosh staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and UW Oshkosh’s procedures for monitoring the reporting performed by NSC. UW-Oshkosh relies on data from its student information system to compile information to transmit to NSC. UW-Oshkosh also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve. To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023 24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student who withdrew from UW-Oshkosh and two students who graduated from UW‑Oshkosh.
Questioned Costs:
None.
Effect:
UW-Oshkosh did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Oshkosh did not report to NSLDS in a timely manner who had withdrawn from enrollment without notification, we found that UW-Oshkosh indicated that it believed it needed to report to NSLDS only when students withdrew from enrollment and had notified UW-Oshkosh of the withdrawal. As a result, students detected by UW Oshkosh through procedures completed by the financial aid office at the end of each term were not communicated to those staff in the registrar’s office who were responsible for NSLDS reporting.
Second, for the student UW-Oshkosh did not accurately report as graduated within NSLDS, we found that inaccuracies in the reporting of students who had graduated were noted on NSC error reports. However, UW-Oshkosh’s registrar’s office staff did sufficiently review the errors to correct the status in NSLDS.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as communicating those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-710: Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Background:
UW Parkside operates in a highly computerized environment and is responsible for maintaining confidential and sensitive information, such as student data. UW Parkside maintains its own student information system to administer federal student financial assistance programs under the SFA Cluster.
Criteria:
To ensure data processed and stored by UW-Parkside is protected from accidental or intentional misuse or destruction, and to provide proper internal control, information technology (IT) security policies and procedures are necessary. In addition, IT controls should be established to prevent inappropriate or inadvertent access to data. UW-Parkside is responsible for following specific requirements under the Gramm-Leach-Bliley Act (GLBA), which requires entities that administer student financial assistance programs to develop, implement, and maintain safeguards to protect the security, integrity, and confidentiality of student data.
Under GLBA, UW-Parkside is required to authenticate and permit access only to authorized users. Further, UW Board of Regents Policy 25-5 requires that UW-Parkside follow the National Institute of Standards and Technology (NIST) in establishing IT controls. NIST Special Publication (SP) 800-53, Security and Privacy Controls for Information Systems and Organizations, recommends best practices in IT controls related to user access. These best practices include developing a provisioning and deprovisioning process focused on limiting access in a manner that provides the least access based on business need; retaining documentation of provisioning and deprovisioning activities, including records of when such access was added or removed; and performing periodic reviews of access to ensure it remains appropriate.
Condition:
We found UW-Parkside did not have adequate IT controls in place during FY 2023-24 to provision, deprovision, and manage access to its student information system. First, UW-Parkside did not have a formal documented process to provision or deprovision user access to its student information system. Second, UW-Parkside did not maintain a list of provisioned users with access and was unable to generate a report of users provisioned or deprovisioned during FY 2023-24. Third, UW-Parkside did not complete a periodic review of access, which assists in ensuring its provisioning and deprovisioning processes are working as intended. Although failure in any one IT control may be detected by complementary IT controls, UW‑Parkside did not have effective IT controls in any of the three areas. As a result, UW-Parkside was at a higher risk of granting unauthorized access to its student information system.
Context:
We reviewed GLBA requirements, UW System Board of Regents policies, and NIST 800-53 guidance to identify policies and procedures for UW-Parkside’s monitoring of access granted to its student information system. We requested documentation from UW-Parkside to assess compliance with these policies.
Questioned Costs:
None.
Effect:
Ineffective general IT controls may permit controls over systems to operate improperly and may allow noncompliance to occur and not be detected. Weaknesses in IT security policies, procedures, and controls increase the risk that unauthorized or erroneous transactions could be processed or changes made to student data. In addition, failure to provide an appropriate level of protection for its student information system and data increased the risk that personally identifiable information could be accidentally or maliciously exposed.
Cause:
UW-Parkside did not have a formal policy or procedures in place to provision, deprovision, and review access to its student information system. UW-Parkside staff indicated the process for provisioning and deprovisioning access had been informally operated, such as through electronic mail and direct communication and it did not consistently retain documentation of these communications. For example,
UW-Parkside indicated access requests were accepted from a variety of UW-Parkside employees. As a result, UW-Parkside had not assessed whether a user’s access was necessary or otherwise limited the access only to specific information needed or to a specified time period. Finally, UW-Parkside also indicated that prior efforts to improve its provisioning and deprovisioning of user access were not fully completed or implemented, in part, due to staff turnover.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-develop and implement written procedures for provisioning and deprovisioning user access to its student information system, including specifying those who are authorized to request user access and assigning responsibility to staff to assess access requests to restrict the access only to data needed for a specified period of time;
-retain consistent documentation of its provisioning and deprovisioning activities;
-develop and implement written procedures for a review at least annually of access granted to its student information system; and
-complete an assessment of users who currently have access to its student information system and remove those users who no longer require the access.
Finding 2024-711: Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-Madison must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. For students that begin attending classes, but who later withdraw from enrollment, 34 CFR s. 668.22 requires that UW-Madison must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In order not to consider a student to have withdrawn from enrollment under certain circumstances, which permits a student to retain federal financial assistance that otherwise would need to be returned to the federal government, 34 CFR s. 668.22 (a) (2) (ii) provides certain exemptions to students.
Condition:
For four students, we found that UW-Madison did not accurately determine the amount of federal financial assistance it disbursed that should have been returned to the U.S. Department of Education. First, we found that UW-Madison did not return all federal financial assistance it disbursed to two students that did not begin attendance and to one student who only attended one day during FY 2023-24. For these three students, UW-Madison determined it failed to return $16,403 in federal financial assistance it disbursed during FY 2023-24. Second, we found that UW-Madison did not accurately determine the federal financial assistance that should be returned after a student withdrew from enrollment during the summer 2023 term. For this student, UW-Madison incorrectly applied an exemption, which led to UW-Madison failing to return $584 in federal financial assistance to the U.S. Department of Education.
Context:
UW-Madison uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Madison staff its process for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Madison to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. When reviewing the data UW-Madison provided, we noted potential errors in the amount of aid returned for students identified as never attending.
Separately, as part of a UW systemwide sample of 60 students, we selected 6 students who had received federal financial assistance and who withdrew from enrollment from UW-Madison to determine the amount of federal financial assistance those students earned and the related amounts UW-Madison returned to the U.S. Department of Education.
Questioned Costs:
$16,987, Plus an Undetermined Amount
Effect:
UW-Madison did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Madison identified that the errors in determining the amount of the federal financial assistance that should have been returned to the federal government for the four students we identified were manual errors in the withdrawal procedures and calculations completed during and at the end of each term. These errors were not detected by any other review procedures. Although UW-Madison correctly identified the status of the two students who never attended and the need to return all disbursed federal financial assistance, it did not follow through on the actual repayment.
For the student who had an exemption applied, the exemption was incorrectly selected when UW-Madison completed a determination, and the error was not detected in UW-Madison’s review process. UW-Madison indicated that its automated review processes conducted at the end of each term did not specifically address the matters we identified for the four students.
After we identified these errors in the determination of the amount of federal financial assistance to return to the federal government, UW-Madison returned in fall 2024 the unearned federal financial assistance for the three students who never attended or withdrew from enrollment after attending one day. In addition, UW Madison returned the additional $584 in February 2025 for the student who withdrew from enrollment and did not meet the criteria for a withdrawal exemption.
Recommendation:
We recommend the University of Wisconsin-Madison review, update, and implement its procedures to improve the accuracy and follow-through for making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including thoroughly reviewing applied exemptions, and returning federal financial assistance in a timely manner to the federal government.
Finding 2024-703: Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,987, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Background:
UW-River Falls receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-River Falls reported a total of $23.6 million in federal financial assistance under the SFA Cluster. UW-River Falls is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-River Falls must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. Under Volume 5, Chapter 1 of the Federal Student Aid Handbook, when a student begins attendance in at least one course but does not begin attendance in all courses the student was scheduled to attend, the school must determine if it is necessary to recalculate the student’s eligibility for the Pell Grant based on a revised enrollment status and the cost of education pursuant to 34 CFR s. 690.80. If the student withdraws, this recalculation must be performed before determining whether to return federal financial assistance pursuant to 34 CFR s. 668.22.
Condition:
We found that UW-River Falls did not return $16,010 in federal financial assistance for four students that did not begin attendance in all enrolled courses during FY 2023-24. This included two students who never began attendance in any enrolled courses for whom all disbursed federal financial assistance was required to be returned. This also included two students who began at least one course but not all courses for which the students had enrolled. UW-River Falls did not perform the required recalculation of Pell Grant eligibility or an assessment of federal financial assistance it had disbursed that these students had not earned.
Context:
UW-River Falls uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-River Falls the process used for identifying students who did not begin attending all enrolled courses or withdrew from enrollment, and we requested a list of such students during FY 2023-24. UW-River Falls did not have a complete list readily available of students who did not begin attending all enrolled courses.
Questioned Costs:
$16,010, Plus an Undetermined Amount
Effect:
UW-River Falls did not comply with all requirements to return federal financial assistance for students who never attended or did not begin attending all enrolled courses during FY 2023-24.
Cause:
UW-River Falls did not have procedures to identify from its student information system, or other sources, those students for whom it disbursed federal financial assistance, yet the students did not attend at least one course during the term or begin all courses enrolled. Depending on whether a student dropped any of their courses, UW-River Falls indicated that the procedures to evaluate attendance may not have identified all students who would ultimately be determined as never attending for the academic term.
After we requested a list of students who did not begin attending all enrolled courses, UW-River Falls identified two students who did not begin at least one course but for whom it had disbursed federal financial assistance. For the other two students who began at least one course, UW-River Falls completed the required Pell Grant recalculation for the students. UW-River Falls also determined the amount of federal financial assistance to return for all four students, as applicable, to the U.S. Department of Education in September 2024.
Recommendation:
We recommend the University of Wisconsin-River Falls review, update, and implement procedures to:
-identify students after the start of each academic term for whom it disbursed federal financial assistance and the students did not begin all enrolled courses;
-complete required recalculations for Pell Grant eligibility and a determination of federal financial assistance that was not earned by the students, as applicable; and
-return amounts to the federal government in a timely manner.
Finding 2024-704: Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,010, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-River Falls: The University of Wisconsin-River Falls agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Background:
UW-Parkside receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Parkside reported a total of $21.3 million in federal financial assistance under the SFA Cluster. UW-Parkside is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22, requires that UW-Parkside must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW Parkside should be returned to the U.S. Department of Education unless certain conditions are met. In determining whether federal financial assistance was earned by a student, the Federal Student Aid Handbook provides guidance on how to calculate applicable institution charges and academic days under different circumstances.
Condition:
For two of three students we reviewed who withdrew from enrollment during FY 2023-24, UW-Parkside inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Parkside incorrectly accounted for a disbursement that occurred after the student’s withdrawal from enrollment as an amount that was earned by the student for the fall 2023 term. As a result, UW Parkside returned $548 less than what should have been returned to the U.S. Department of Education. For the second student, UW-Parkside incorrectly identified the end date of the spring 2024 term and did not include the correct institutional charges in its determination. As a result, UW-Parkside returned $1,190 less than should have been returned to the U.S. Department of Education.
Context:
UW-Parkside uses a student information system to track activity for students that withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Parkside staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from
UW-Parkside to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 3 students who had received federal financial assistance and withdrew from UW-Parkside to determine the amount of federal financial assistance those students earned and the related amounts UW-Parkside returned to the U.S. Department of Education.
Questioned Costs:
$1,738, Plus an Undetermined Amount
Effect:
UW-Parkside did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Parkside did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal assistance to return. Although UW-Parkside disbursed federal financial assistance later than is typical to one student, the disbursement was not correctly categorized within the calculations completed by UW-Parkside to determine that the entire amount of the federal financial assistance was required to be returned to the federal government.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the students we identified.
Finding 2024-705: Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $1,738, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Background:
UW-Platteville receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Platteville reported a total of $29.1 million in federal financial assistance under the SFA Cluster. UW-Platteville is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Under 34 CFR s. 668.21, UW-Platteville must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. In addition, when a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Platteville must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In determining whether federal financial assistance was earned by a student, Volume 5, Chapter 2 of the Federal Student Aid Handbook specifies how to calculate academic days.
Condition:
For two of the five students we reviewed who never began attendance or who withdrew from enrollment during FY 2023-24, UW-Platteville inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Platteville incorrectly determined the student began attendance because the student attended one day of the fall 2023 term. As a result, UW-Platteville failed to return $24 in federal financial assistance to the U.S. Department of Education. For the second student, UW-Platteville did not exclude a five-day break from its determination of the federal financial assistance amount the student had earned during the fall 2023 term. Although this student had earned all of the federal financial assistance prior to the student’s withdrawal from enrollment, UW-Platteville incorrectly returned $1,226. Because UW-Platteville used the same calculation for all determinations for the fall 2023 term, there may be further errors in the federal financial assistance amounts UW-Platteville determined.
Context:
UW-Platteville uses a student information system to track activity for students who withdraw from enrollment in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Platteville staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Platteville to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 5 students who had received federal financial assistance and who withdrew from UW-Platteville to determine the amount of federal financial assistance those students earned and the related amounts UW-Platteville returned to the U.S. Department of Education.
Questioned Costs:
$24, Plus an Undetermined Amount
Effect:
UW-Platteville did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Platteville did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal financial assistance to return to the federal government. After we identified the error for the student who attended only one day, UW-Platteville returned the additional $24 to the federal government in November 2024. For the fall 2023 term, UW-Platteville changed its fall break from four to five days, which required a change in the number of academic days used in the calculation of federal financial assistance earned when a student withdraws from enrollment. UW-Platteville did not have a process to review the academic calendar for purposes of its return procedures.
Recommendation:
We recommend the University of Wisconsin-Platteville review, update, and implement its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including annually reviewing the academic days used in its determinations.
Finding 2024-706: Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $24, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Platteville: The University of Wisconsin-Platteville agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Background:
UW-Whitewater receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Whitewater reported a total of $58.4 million in federal financial assistance under the SFA Cluster. UW-Whitewater is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Whitewater must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook, the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW-Whitewater is required to be returned to the U.S. Department of Education unless certain conditions are met.
Condition:
UW-Whitewater inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education for one of seven students we reviewed who withdrew from enrollment during FY 2023 24. UW-Whitewater incorrectly accounted for a disbursement to the student that occurred after the date for which UW-Whitewater later identified the student had withdrawn from enrollment as an amount that was earned by the student. As a result, UW-Whitewater failed to return $400 in federal financial assistance to the U.S. Department of Education for the spring 2024 term.
Context:
In order to determine the federal financial assistance a student earned and the amount that must be returned to the U.S. Department of Education for amounts a student did not earn, UW-Whitewater uses a student information system to track activity for students who withdraw. We discussed with UW-Whitewater staff the process used for identifying students who withdrew from enrollment. We also requested information from UW-Whitewater to identify students who withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 7 students who had received federal financial assistance and who withdrew from UW-Whitewater to determine the amount of federal financial assistance those students earned and the related amounts UW-Whitewater returned to the U.S. Department of Education.
Questioned Costs:
$400, Plus an Undetermined Amount
Effect:
UW-Whitewater did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Whitewater did not have adequate procedures to review and ensure its determination of the amount of federal assistance to return was accurate. Although UW-Whitewater disbursed federal financial assistance later than is typical to the student, the disbursement was not correctly categorized within the calculations completed by UW-Whitewater nor was the categorization error detected by other
UW-Whitewater procedures.
Recommendation:
We recommend the University of Wisconsin-Whitewater:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the student we identified.
Finding 2024-707: Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $400, Plus an Undetermined Amount
Type of Finding: Noncompliance
Response from the University of Wisconsin-Whitewater: The University of Wisconsin-Whitewater agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Madison is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to the National Student Loan Data System (NSLDS). Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Madison is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time;
-report the same effective date for a student who withdraws from enrollment as the date used in its determination of whether any federal financial assistance must be returned in accordance with
34 CFR s. 668.22;
-report a student who has completed a program with a status of “graduated” rather than “withdrawn”;
-maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed; and
-maintain the program begin date, which is the date the student first began attending the program being reported, if a student’s program of study has not changed.
Condition:
UW-Madison uses the National Student Clearinghouse (NSC) to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Madison that identify potential errors in UW-Madison’s reporting of student activities. It is the responsibility of UW-Madison to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Madison did not report to NSLDS accurate information for 12 of the 17 students we reviewed. First, UW-Madison did not accurately report a student who withdrew from enrollment without notification in a timely manner. Second, UW-Madison incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment. Third, UW-Madison incorrectly reported the program-level enrollment status effective date for two students. Fourth, UW-Madison incorrectly reported the program begin date for six students. In addition, UW Madison incorrectly reported both the program-level enrollment status effective date and program begin date for two students.
Context:
We discussed with UW-Madison staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Madison relies on data from its student information system to compile information to transmit to NSC. UW-Madison also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student that withdrew from UW-Madison and six students who graduated from UW-Madison. In addition, we selected ten additional UW-Madison students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Madison did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Madison did not report to NSLDS who had withdrawn from enrollment without notification, we found UW-Madison’s enrollment reporting procedures did not assign responsibility for communicating certain information to those staff in the registrar’s office who are responsible for NSLDS reporting. As a result, those students the financial aid office determined had withdrawn from enrollment without notification, and for which it had completed a determination of federal financial assistance the students did not earn, were not known to staff in the registrar’s office for purposes of NSLDS reporting. In addition, UW-Madison indicated that withdrawals from enrollment without notification are identified after the term ends and its student information system did not have a dedicated effective date field in order to automatically identify such student records for the required NSLDS reporting.
Second, for the student UW-Madison did not accurately report as graduated within NSLDS, we found UW‑Madison relied on a NSC process that is intended to simultaneously update a student’s enrollment status in NSLDS when UW-Madison separately updates a student’s degree as completed. UW-Madison did not complete a separate report to ensure the enrollment status for graduated students was accurately reflected in NSLDS. However, in 2022 NSC had published information that indicated reliance solely on NSC’s process may result in the incorrect status being reported under certain circumstances. Although NSC error reports identified that such errors were present, UW-Madison indicated that it did not review these errors until fall 2024 when it began implementing new U.S. Department of Education reporting requirements.
At that time, UW-Madison stated that it identified that it did not consistently and accurately report in NSLDS those students who had graduated. UW-Madison stated that it then began to work with NSC to identify the extent of the reporting inaccuracies.
Third, in 2021 NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW-Madison’s data from its student information system and had communicated error or warning codes to UW-Madison in these areas. However, UW-Madison did not sufficiently review whether the records identified by NSC as potential errors resulted in inaccurate reporting. For example, NSC used warning codes for potential errors in the program-level enrollment status effective dates. As warning codes do not prohibit submission of reporting, UW-Madison did not review the warnings.
Fourth, in 2021 NSC similarly published information on accurately reporting student program begin dates in NSLDS and NSC had also identified instances of potential inaccurate reporting in UW Madison’s data from its student information system. Although NSC had communicated error or warning codes to UW-Madison in these areas, UW-Madison had not sufficiently reviewed whether the records identified by NSC as potential errors resulted in inaccurate reporting until 2023. At that time, UW-Madison indicated that, after reviewing other NSC warnings, it identified that it did not accurately report program begin dates for students. UW-Madison indicated it then began to work to update its student information system data extraction process to identify the correct program begin date for its submissions to NSC. However, it did not implement these changes until after the audit period.
In addition, UW-Madison indicated that it had turnover in staff responsible for NSLDS reporting in 2021, which may have caused UW-Madison to have missed the NSC publications regarding reporting graduated students accurately, new warning codes, and the importance of reviewing certain warning codes to accurately complete NSLDS reporting.
Recommendation:
We recommend the University of Wisconsin-Madison:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as updating its student information system to allow for an automated identification process to communicate those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated and implement separate reporting to the National Student Clearinghouse to accurately report students who graduate;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program-level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program begin dates and update its student information system extraction process to accurately report program begin dates; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-708: Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Background:
UW-Milwaukee receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Milwaukee reported a total of $133.1 million in federal financial assistance under the SFA Cluster. UW-Milwaukee records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Milwaukee is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Milwaukee is required to maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed.
Condition:
UW-Milwaukee uses NSC to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Milwaukee that identify potential errors in UW-Milwaukee’s reporting of student activities through NSC. These errors are the responsibility of UW-Milwaukee to resolve to ensure its submissions to NSLDS are accurate and complete.
UW-Milwaukee did not report to NSLDS accurate information for the program level enrollment status effective date for five students we reviewed. In addition, based on how information from its student information system is extracted for student reporting to NSLDS, we found that the reporting inaccuracy extended to other UW-Milwaukee students.
Context:
We discussed with UW-Milwaukee staff its procedures for identifying student enrollment status changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Milwaukee relies on data from its student information system to compile information to transmit to NSC. UW-Milwaukee also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included two students who withdrew from UW-Milwaukee and four students who graduated from UW- Milwaukee. In addition, we selected ten additional UW-Milwaukee students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Milwaukee did not comply with requirements to accurately report certain student enrollment status changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
In 2021, NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW- Milwaukee’s data from its student information system and had communicated error or warning codes to UW-Milwaukee in these areas. UW-Milwaukee staff indicated that they were aware that NSC error reports included warnings to identify potential inaccurate reporting of program level enrollment status effective dates and that the errors were a known issue for Peoplesoft-based student information systems. However, UW-Milwaukee chose not to use an all-record update feature that was available to correct the program-level enrollment status effective dates for all student records simultaneously due to the risk that other reporting inaccuracies could result from the action. Further, UW-Milwaukee staff indicated that they were not aware that specific guidance on the program-level enrollment status effective date had been updated to reflect that corrections should be made to fully comply with NSLDS reporting requirements.
Recommendation:
We recommend the University of Wisconsin-Milwaukee:
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates; and
-report changes in student enrollment accurately, completely, and in a timely manner for all student changes that require reporting.
Finding 2024-709: Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Milwaukee: The University of Wisconsin-Milwaukee agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Background:
UW-Oshkosh receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Oshkosh reported a total of $45.3 million in federal financial assistance under the SFA Cluster. UW-Oshkosh records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Oshkosh is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Oshkosh is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time; and
-report a student who has completed a program with a status of “graduated” rather than “withdrawn.”
Condition:
UW-Oshkosh uses NSC to facilitate the enrollment reporting in NSLDS. NSC provides error reports to UW-Oshkosh that identify potential errors in UW Oshkosh’s reporting of student activities. It is the responsibility of UW-Oshkosh to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Oshkosh did not report to NSLDS accurate information for two of the three students we reviewed.
First, UW-Oshkosh did not report in a timely manner one student who withdrew from enrollment without notification. Second, UW-Oshkosh incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment.
Context:
We discussed with UW-Oshkosh staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and UW Oshkosh’s procedures for monitoring the reporting performed by NSC. UW-Oshkosh relies on data from its student information system to compile information to transmit to NSC. UW-Oshkosh also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve. To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023 24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student who withdrew from UW-Oshkosh and two students who graduated from UW‑Oshkosh.
Questioned Costs:
None.
Effect:
UW-Oshkosh did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Oshkosh did not report to NSLDS in a timely manner who had withdrawn from enrollment without notification, we found that UW-Oshkosh indicated that it believed it needed to report to NSLDS only when students withdrew from enrollment and had notified UW-Oshkosh of the withdrawal. As a result, students detected by UW Oshkosh through procedures completed by the financial aid office at the end of each term were not communicated to those staff in the registrar’s office who were responsible for NSLDS reporting.
Second, for the student UW-Oshkosh did not accurately report as graduated within NSLDS, we found that inaccuracies in the reporting of students who had graduated were noted on NSC error reports. However, UW-Oshkosh’s registrar’s office staff did sufficiently review the errors to correct the status in NSLDS.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as communicating those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-710: Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Background:
UW Parkside operates in a highly computerized environment and is responsible for maintaining confidential and sensitive information, such as student data. UW Parkside maintains its own student information system to administer federal student financial assistance programs under the SFA Cluster.
Criteria:
To ensure data processed and stored by UW-Parkside is protected from accidental or intentional misuse or destruction, and to provide proper internal control, information technology (IT) security policies and procedures are necessary. In addition, IT controls should be established to prevent inappropriate or inadvertent access to data. UW-Parkside is responsible for following specific requirements under the Gramm-Leach-Bliley Act (GLBA), which requires entities that administer student financial assistance programs to develop, implement, and maintain safeguards to protect the security, integrity, and confidentiality of student data.
Under GLBA, UW-Parkside is required to authenticate and permit access only to authorized users. Further, UW Board of Regents Policy 25-5 requires that UW-Parkside follow the National Institute of Standards and Technology (NIST) in establishing IT controls. NIST Special Publication (SP) 800-53, Security and Privacy Controls for Information Systems and Organizations, recommends best practices in IT controls related to user access. These best practices include developing a provisioning and deprovisioning process focused on limiting access in a manner that provides the least access based on business need; retaining documentation of provisioning and deprovisioning activities, including records of when such access was added or removed; and performing periodic reviews of access to ensure it remains appropriate.
Condition:
We found UW-Parkside did not have adequate IT controls in place during FY 2023-24 to provision, deprovision, and manage access to its student information system. First, UW-Parkside did not have a formal documented process to provision or deprovision user access to its student information system. Second, UW-Parkside did not maintain a list of provisioned users with access and was unable to generate a report of users provisioned or deprovisioned during FY 2023-24. Third, UW-Parkside did not complete a periodic review of access, which assists in ensuring its provisioning and deprovisioning processes are working as intended. Although failure in any one IT control may be detected by complementary IT controls, UW‑Parkside did not have effective IT controls in any of the three areas. As a result, UW-Parkside was at a higher risk of granting unauthorized access to its student information system.
Context:
We reviewed GLBA requirements, UW System Board of Regents policies, and NIST 800-53 guidance to identify policies and procedures for UW-Parkside’s monitoring of access granted to its student information system. We requested documentation from UW-Parkside to assess compliance with these policies.
Questioned Costs:
None.
Effect:
Ineffective general IT controls may permit controls over systems to operate improperly and may allow noncompliance to occur and not be detected. Weaknesses in IT security policies, procedures, and controls increase the risk that unauthorized or erroneous transactions could be processed or changes made to student data. In addition, failure to provide an appropriate level of protection for its student information system and data increased the risk that personally identifiable information could be accidentally or maliciously exposed.
Cause:
UW-Parkside did not have a formal policy or procedures in place to provision, deprovision, and review access to its student information system. UW-Parkside staff indicated the process for provisioning and deprovisioning access had been informally operated, such as through electronic mail and direct communication and it did not consistently retain documentation of these communications. For example,
UW-Parkside indicated access requests were accepted from a variety of UW-Parkside employees. As a result, UW-Parkside had not assessed whether a user’s access was necessary or otherwise limited the access only to specific information needed or to a specified time period. Finally, UW-Parkside also indicated that prior efforts to improve its provisioning and deprovisioning of user access were not fully completed or implemented, in part, due to staff turnover.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-develop and implement written procedures for provisioning and deprovisioning user access to its student information system, including specifying those who are authorized to request user access and assigning responsibility to staff to assess access requests to restrict the access only to data needed for a specified period of time;
-retain consistent documentation of its provisioning and deprovisioning activities;
-develop and implement written procedures for a review at least annually of access granted to its student information system; and
-complete an assessment of users who currently have access to its student information system and remove those users who no longer require the access.
Finding 2024-711: Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-Madison must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. For students that begin attending classes, but who later withdraw from enrollment, 34 CFR s. 668.22 requires that UW-Madison must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In order not to consider a student to have withdrawn from enrollment under certain circumstances, which permits a student to retain federal financial assistance that otherwise would need to be returned to the federal government, 34 CFR s. 668.22 (a) (2) (ii) provides certain exemptions to students.
Condition:
For four students, we found that UW-Madison did not accurately determine the amount of federal financial assistance it disbursed that should have been returned to the U.S. Department of Education. First, we found that UW-Madison did not return all federal financial assistance it disbursed to two students that did not begin attendance and to one student who only attended one day during FY 2023-24. For these three students, UW-Madison determined it failed to return $16,403 in federal financial assistance it disbursed during FY 2023-24. Second, we found that UW-Madison did not accurately determine the federal financial assistance that should be returned after a student withdrew from enrollment during the summer 2023 term. For this student, UW-Madison incorrectly applied an exemption, which led to UW-Madison failing to return $584 in federal financial assistance to the U.S. Department of Education.
Context:
UW-Madison uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Madison staff its process for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Madison to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. When reviewing the data UW-Madison provided, we noted potential errors in the amount of aid returned for students identified as never attending.
Separately, as part of a UW systemwide sample of 60 students, we selected 6 students who had received federal financial assistance and who withdrew from enrollment from UW-Madison to determine the amount of federal financial assistance those students earned and the related amounts UW-Madison returned to the U.S. Department of Education.
Questioned Costs:
$16,987, Plus an Undetermined Amount
Effect:
UW-Madison did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Madison identified that the errors in determining the amount of the federal financial assistance that should have been returned to the federal government for the four students we identified were manual errors in the withdrawal procedures and calculations completed during and at the end of each term. These errors were not detected by any other review procedures. Although UW-Madison correctly identified the status of the two students who never attended and the need to return all disbursed federal financial assistance, it did not follow through on the actual repayment.
For the student who had an exemption applied, the exemption was incorrectly selected when UW-Madison completed a determination, and the error was not detected in UW-Madison’s review process. UW-Madison indicated that its automated review processes conducted at the end of each term did not specifically address the matters we identified for the four students.
After we identified these errors in the determination of the amount of federal financial assistance to return to the federal government, UW-Madison returned in fall 2024 the unearned federal financial assistance for the three students who never attended or withdrew from enrollment after attending one day. In addition, UW Madison returned the additional $584 in February 2025 for the student who withdrew from enrollment and did not meet the criteria for a withdrawal exemption.
Recommendation:
We recommend the University of Wisconsin-Madison review, update, and implement its procedures to improve the accuracy and follow-through for making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including thoroughly reviewing applied exemptions, and returning federal financial assistance in a timely manner to the federal government.
Finding 2024-703: Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,987, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Background:
UW-River Falls receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-River Falls reported a total of $23.6 million in federal financial assistance under the SFA Cluster. UW-River Falls is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-River Falls must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. Under Volume 5, Chapter 1 of the Federal Student Aid Handbook, when a student begins attendance in at least one course but does not begin attendance in all courses the student was scheduled to attend, the school must determine if it is necessary to recalculate the student’s eligibility for the Pell Grant based on a revised enrollment status and the cost of education pursuant to 34 CFR s. 690.80. If the student withdraws, this recalculation must be performed before determining whether to return federal financial assistance pursuant to 34 CFR s. 668.22.
Condition:
We found that UW-River Falls did not return $16,010 in federal financial assistance for four students that did not begin attendance in all enrolled courses during FY 2023-24. This included two students who never began attendance in any enrolled courses for whom all disbursed federal financial assistance was required to be returned. This also included two students who began at least one course but not all courses for which the students had enrolled. UW-River Falls did not perform the required recalculation of Pell Grant eligibility or an assessment of federal financial assistance it had disbursed that these students had not earned.
Context:
UW-River Falls uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-River Falls the process used for identifying students who did not begin attending all enrolled courses or withdrew from enrollment, and we requested a list of such students during FY 2023-24. UW-River Falls did not have a complete list readily available of students who did not begin attending all enrolled courses.
Questioned Costs:
$16,010, Plus an Undetermined Amount
Effect:
UW-River Falls did not comply with all requirements to return federal financial assistance for students who never attended or did not begin attending all enrolled courses during FY 2023-24.
Cause:
UW-River Falls did not have procedures to identify from its student information system, or other sources, those students for whom it disbursed federal financial assistance, yet the students did not attend at least one course during the term or begin all courses enrolled. Depending on whether a student dropped any of their courses, UW-River Falls indicated that the procedures to evaluate attendance may not have identified all students who would ultimately be determined as never attending for the academic term.
After we requested a list of students who did not begin attending all enrolled courses, UW-River Falls identified two students who did not begin at least one course but for whom it had disbursed federal financial assistance. For the other two students who began at least one course, UW-River Falls completed the required Pell Grant recalculation for the students. UW-River Falls also determined the amount of federal financial assistance to return for all four students, as applicable, to the U.S. Department of Education in September 2024.
Recommendation:
We recommend the University of Wisconsin-River Falls review, update, and implement procedures to:
-identify students after the start of each academic term for whom it disbursed federal financial assistance and the students did not begin all enrolled courses;
-complete required recalculations for Pell Grant eligibility and a determination of federal financial assistance that was not earned by the students, as applicable; and
-return amounts to the federal government in a timely manner.
Finding 2024-704: Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,010, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-River Falls: The University of Wisconsin-River Falls agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Background:
UW-Parkside receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Parkside reported a total of $21.3 million in federal financial assistance under the SFA Cluster. UW-Parkside is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22, requires that UW-Parkside must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW Parkside should be returned to the U.S. Department of Education unless certain conditions are met. In determining whether federal financial assistance was earned by a student, the Federal Student Aid Handbook provides guidance on how to calculate applicable institution charges and academic days under different circumstances.
Condition:
For two of three students we reviewed who withdrew from enrollment during FY 2023-24, UW-Parkside inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Parkside incorrectly accounted for a disbursement that occurred after the student’s withdrawal from enrollment as an amount that was earned by the student for the fall 2023 term. As a result, UW Parkside returned $548 less than what should have been returned to the U.S. Department of Education. For the second student, UW-Parkside incorrectly identified the end date of the spring 2024 term and did not include the correct institutional charges in its determination. As a result, UW-Parkside returned $1,190 less than should have been returned to the U.S. Department of Education.
Context:
UW-Parkside uses a student information system to track activity for students that withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Parkside staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from
UW-Parkside to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 3 students who had received federal financial assistance and withdrew from UW-Parkside to determine the amount of federal financial assistance those students earned and the related amounts UW-Parkside returned to the U.S. Department of Education.
Questioned Costs:
$1,738, Plus an Undetermined Amount
Effect:
UW-Parkside did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Parkside did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal assistance to return. Although UW-Parkside disbursed federal financial assistance later than is typical to one student, the disbursement was not correctly categorized within the calculations completed by UW-Parkside to determine that the entire amount of the federal financial assistance was required to be returned to the federal government.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the students we identified.
Finding 2024-705: Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $1,738, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Background:
UW-Platteville receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Platteville reported a total of $29.1 million in federal financial assistance under the SFA Cluster. UW-Platteville is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Under 34 CFR s. 668.21, UW-Platteville must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. In addition, when a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Platteville must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In determining whether federal financial assistance was earned by a student, Volume 5, Chapter 2 of the Federal Student Aid Handbook specifies how to calculate academic days.
Condition:
For two of the five students we reviewed who never began attendance or who withdrew from enrollment during FY 2023-24, UW-Platteville inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Platteville incorrectly determined the student began attendance because the student attended one day of the fall 2023 term. As a result, UW-Platteville failed to return $24 in federal financial assistance to the U.S. Department of Education. For the second student, UW-Platteville did not exclude a five-day break from its determination of the federal financial assistance amount the student had earned during the fall 2023 term. Although this student had earned all of the federal financial assistance prior to the student’s withdrawal from enrollment, UW-Platteville incorrectly returned $1,226. Because UW-Platteville used the same calculation for all determinations for the fall 2023 term, there may be further errors in the federal financial assistance amounts UW-Platteville determined.
Context:
UW-Platteville uses a student information system to track activity for students who withdraw from enrollment in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Platteville staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Platteville to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 5 students who had received federal financial assistance and who withdrew from UW-Platteville to determine the amount of federal financial assistance those students earned and the related amounts UW-Platteville returned to the U.S. Department of Education.
Questioned Costs:
$24, Plus an Undetermined Amount
Effect:
UW-Platteville did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Platteville did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal financial assistance to return to the federal government. After we identified the error for the student who attended only one day, UW-Platteville returned the additional $24 to the federal government in November 2024. For the fall 2023 term, UW-Platteville changed its fall break from four to five days, which required a change in the number of academic days used in the calculation of federal financial assistance earned when a student withdraws from enrollment. UW-Platteville did not have a process to review the academic calendar for purposes of its return procedures.
Recommendation:
We recommend the University of Wisconsin-Platteville review, update, and implement its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including annually reviewing the academic days used in its determinations.
Finding 2024-706: Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $24, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Platteville: The University of Wisconsin-Platteville agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Background:
UW-Whitewater receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Whitewater reported a total of $58.4 million in federal financial assistance under the SFA Cluster. UW-Whitewater is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Whitewater must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook, the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW-Whitewater is required to be returned to the U.S. Department of Education unless certain conditions are met.
Condition:
UW-Whitewater inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education for one of seven students we reviewed who withdrew from enrollment during FY 2023 24. UW-Whitewater incorrectly accounted for a disbursement to the student that occurred after the date for which UW-Whitewater later identified the student had withdrawn from enrollment as an amount that was earned by the student. As a result, UW-Whitewater failed to return $400 in federal financial assistance to the U.S. Department of Education for the spring 2024 term.
Context:
In order to determine the federal financial assistance a student earned and the amount that must be returned to the U.S. Department of Education for amounts a student did not earn, UW-Whitewater uses a student information system to track activity for students who withdraw. We discussed with UW-Whitewater staff the process used for identifying students who withdrew from enrollment. We also requested information from UW-Whitewater to identify students who withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 7 students who had received federal financial assistance and who withdrew from UW-Whitewater to determine the amount of federal financial assistance those students earned and the related amounts UW-Whitewater returned to the U.S. Department of Education.
Questioned Costs:
$400, Plus an Undetermined Amount
Effect:
UW-Whitewater did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Whitewater did not have adequate procedures to review and ensure its determination of the amount of federal assistance to return was accurate. Although UW-Whitewater disbursed federal financial assistance later than is typical to the student, the disbursement was not correctly categorized within the calculations completed by UW-Whitewater nor was the categorization error detected by other
UW-Whitewater procedures.
Recommendation:
We recommend the University of Wisconsin-Whitewater:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the student we identified.
Finding 2024-707: Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $400, Plus an Undetermined Amount
Type of Finding: Noncompliance
Response from the University of Wisconsin-Whitewater: The University of Wisconsin-Whitewater agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Madison is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to the National Student Loan Data System (NSLDS). Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Madison is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time;
-report the same effective date for a student who withdraws from enrollment as the date used in its determination of whether any federal financial assistance must be returned in accordance with
34 CFR s. 668.22;
-report a student who has completed a program with a status of “graduated” rather than “withdrawn”;
-maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed; and
-maintain the program begin date, which is the date the student first began attending the program being reported, if a student’s program of study has not changed.
Condition:
UW-Madison uses the National Student Clearinghouse (NSC) to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Madison that identify potential errors in UW-Madison’s reporting of student activities. It is the responsibility of UW-Madison to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Madison did not report to NSLDS accurate information for 12 of the 17 students we reviewed. First, UW-Madison did not accurately report a student who withdrew from enrollment without notification in a timely manner. Second, UW-Madison incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment. Third, UW-Madison incorrectly reported the program-level enrollment status effective date for two students. Fourth, UW-Madison incorrectly reported the program begin date for six students. In addition, UW Madison incorrectly reported both the program-level enrollment status effective date and program begin date for two students.
Context:
We discussed with UW-Madison staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Madison relies on data from its student information system to compile information to transmit to NSC. UW-Madison also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student that withdrew from UW-Madison and six students who graduated from UW-Madison. In addition, we selected ten additional UW-Madison students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Madison did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Madison did not report to NSLDS who had withdrawn from enrollment without notification, we found UW-Madison’s enrollment reporting procedures did not assign responsibility for communicating certain information to those staff in the registrar’s office who are responsible for NSLDS reporting. As a result, those students the financial aid office determined had withdrawn from enrollment without notification, and for which it had completed a determination of federal financial assistance the students did not earn, were not known to staff in the registrar’s office for purposes of NSLDS reporting. In addition, UW-Madison indicated that withdrawals from enrollment without notification are identified after the term ends and its student information system did not have a dedicated effective date field in order to automatically identify such student records for the required NSLDS reporting.
Second, for the student UW-Madison did not accurately report as graduated within NSLDS, we found UW‑Madison relied on a NSC process that is intended to simultaneously update a student’s enrollment status in NSLDS when UW-Madison separately updates a student’s degree as completed. UW-Madison did not complete a separate report to ensure the enrollment status for graduated students was accurately reflected in NSLDS. However, in 2022 NSC had published information that indicated reliance solely on NSC’s process may result in the incorrect status being reported under certain circumstances. Although NSC error reports identified that such errors were present, UW-Madison indicated that it did not review these errors until fall 2024 when it began implementing new U.S. Department of Education reporting requirements.
At that time, UW-Madison stated that it identified that it did not consistently and accurately report in NSLDS those students who had graduated. UW-Madison stated that it then began to work with NSC to identify the extent of the reporting inaccuracies.
Third, in 2021 NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW-Madison’s data from its student information system and had communicated error or warning codes to UW-Madison in these areas. However, UW-Madison did not sufficiently review whether the records identified by NSC as potential errors resulted in inaccurate reporting. For example, NSC used warning codes for potential errors in the program-level enrollment status effective dates. As warning codes do not prohibit submission of reporting, UW-Madison did not review the warnings.
Fourth, in 2021 NSC similarly published information on accurately reporting student program begin dates in NSLDS and NSC had also identified instances of potential inaccurate reporting in UW Madison’s data from its student information system. Although NSC had communicated error or warning codes to UW-Madison in these areas, UW-Madison had not sufficiently reviewed whether the records identified by NSC as potential errors resulted in inaccurate reporting until 2023. At that time, UW-Madison indicated that, after reviewing other NSC warnings, it identified that it did not accurately report program begin dates for students. UW-Madison indicated it then began to work to update its student information system data extraction process to identify the correct program begin date for its submissions to NSC. However, it did not implement these changes until after the audit period.
In addition, UW-Madison indicated that it had turnover in staff responsible for NSLDS reporting in 2021, which may have caused UW-Madison to have missed the NSC publications regarding reporting graduated students accurately, new warning codes, and the importance of reviewing certain warning codes to accurately complete NSLDS reporting.
Recommendation:
We recommend the University of Wisconsin-Madison:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as updating its student information system to allow for an automated identification process to communicate those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated and implement separate reporting to the National Student Clearinghouse to accurately report students who graduate;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program-level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program begin dates and update its student information system extraction process to accurately report program begin dates; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-708: Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Background:
UW-Milwaukee receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Milwaukee reported a total of $133.1 million in federal financial assistance under the SFA Cluster. UW-Milwaukee records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Milwaukee is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Milwaukee is required to maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed.
Condition:
UW-Milwaukee uses NSC to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Milwaukee that identify potential errors in UW-Milwaukee’s reporting of student activities through NSC. These errors are the responsibility of UW-Milwaukee to resolve to ensure its submissions to NSLDS are accurate and complete.
UW-Milwaukee did not report to NSLDS accurate information for the program level enrollment status effective date for five students we reviewed. In addition, based on how information from its student information system is extracted for student reporting to NSLDS, we found that the reporting inaccuracy extended to other UW-Milwaukee students.
Context:
We discussed with UW-Milwaukee staff its procedures for identifying student enrollment status changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Milwaukee relies on data from its student information system to compile information to transmit to NSC. UW-Milwaukee also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included two students who withdrew from UW-Milwaukee and four students who graduated from UW- Milwaukee. In addition, we selected ten additional UW-Milwaukee students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Milwaukee did not comply with requirements to accurately report certain student enrollment status changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
In 2021, NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW- Milwaukee’s data from its student information system and had communicated error or warning codes to UW-Milwaukee in these areas. UW-Milwaukee staff indicated that they were aware that NSC error reports included warnings to identify potential inaccurate reporting of program level enrollment status effective dates and that the errors were a known issue for Peoplesoft-based student information systems. However, UW-Milwaukee chose not to use an all-record update feature that was available to correct the program-level enrollment status effective dates for all student records simultaneously due to the risk that other reporting inaccuracies could result from the action. Further, UW-Milwaukee staff indicated that they were not aware that specific guidance on the program-level enrollment status effective date had been updated to reflect that corrections should be made to fully comply with NSLDS reporting requirements.
Recommendation:
We recommend the University of Wisconsin-Milwaukee:
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates; and
-report changes in student enrollment accurately, completely, and in a timely manner for all student changes that require reporting.
Finding 2024-709: Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Milwaukee: The University of Wisconsin-Milwaukee agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Background:
UW-Oshkosh receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Oshkosh reported a total of $45.3 million in federal financial assistance under the SFA Cluster. UW-Oshkosh records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Oshkosh is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Oshkosh is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time; and
-report a student who has completed a program with a status of “graduated” rather than “withdrawn.”
Condition:
UW-Oshkosh uses NSC to facilitate the enrollment reporting in NSLDS. NSC provides error reports to UW-Oshkosh that identify potential errors in UW Oshkosh’s reporting of student activities. It is the responsibility of UW-Oshkosh to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Oshkosh did not report to NSLDS accurate information for two of the three students we reviewed.
First, UW-Oshkosh did not report in a timely manner one student who withdrew from enrollment without notification. Second, UW-Oshkosh incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment.
Context:
We discussed with UW-Oshkosh staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and UW Oshkosh’s procedures for monitoring the reporting performed by NSC. UW-Oshkosh relies on data from its student information system to compile information to transmit to NSC. UW-Oshkosh also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve. To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023 24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student who withdrew from UW-Oshkosh and two students who graduated from UW‑Oshkosh.
Questioned Costs:
None.
Effect:
UW-Oshkosh did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Oshkosh did not report to NSLDS in a timely manner who had withdrawn from enrollment without notification, we found that UW-Oshkosh indicated that it believed it needed to report to NSLDS only when students withdrew from enrollment and had notified UW-Oshkosh of the withdrawal. As a result, students detected by UW Oshkosh through procedures completed by the financial aid office at the end of each term were not communicated to those staff in the registrar’s office who were responsible for NSLDS reporting.
Second, for the student UW-Oshkosh did not accurately report as graduated within NSLDS, we found that inaccuracies in the reporting of students who had graduated were noted on NSC error reports. However, UW-Oshkosh’s registrar’s office staff did sufficiently review the errors to correct the status in NSLDS.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as communicating those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-710: Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Background:
UW Parkside operates in a highly computerized environment and is responsible for maintaining confidential and sensitive information, such as student data. UW Parkside maintains its own student information system to administer federal student financial assistance programs under the SFA Cluster.
Criteria:
To ensure data processed and stored by UW-Parkside is protected from accidental or intentional misuse or destruction, and to provide proper internal control, information technology (IT) security policies and procedures are necessary. In addition, IT controls should be established to prevent inappropriate or inadvertent access to data. UW-Parkside is responsible for following specific requirements under the Gramm-Leach-Bliley Act (GLBA), which requires entities that administer student financial assistance programs to develop, implement, and maintain safeguards to protect the security, integrity, and confidentiality of student data.
Under GLBA, UW-Parkside is required to authenticate and permit access only to authorized users. Further, UW Board of Regents Policy 25-5 requires that UW-Parkside follow the National Institute of Standards and Technology (NIST) in establishing IT controls. NIST Special Publication (SP) 800-53, Security and Privacy Controls for Information Systems and Organizations, recommends best practices in IT controls related to user access. These best practices include developing a provisioning and deprovisioning process focused on limiting access in a manner that provides the least access based on business need; retaining documentation of provisioning and deprovisioning activities, including records of when such access was added or removed; and performing periodic reviews of access to ensure it remains appropriate.
Condition:
We found UW-Parkside did not have adequate IT controls in place during FY 2023-24 to provision, deprovision, and manage access to its student information system. First, UW-Parkside did not have a formal documented process to provision or deprovision user access to its student information system. Second, UW-Parkside did not maintain a list of provisioned users with access and was unable to generate a report of users provisioned or deprovisioned during FY 2023-24. Third, UW-Parkside did not complete a periodic review of access, which assists in ensuring its provisioning and deprovisioning processes are working as intended. Although failure in any one IT control may be detected by complementary IT controls, UW‑Parkside did not have effective IT controls in any of the three areas. As a result, UW-Parkside was at a higher risk of granting unauthorized access to its student information system.
Context:
We reviewed GLBA requirements, UW System Board of Regents policies, and NIST 800-53 guidance to identify policies and procedures for UW-Parkside’s monitoring of access granted to its student information system. We requested documentation from UW-Parkside to assess compliance with these policies.
Questioned Costs:
None.
Effect:
Ineffective general IT controls may permit controls over systems to operate improperly and may allow noncompliance to occur and not be detected. Weaknesses in IT security policies, procedures, and controls increase the risk that unauthorized or erroneous transactions could be processed or changes made to student data. In addition, failure to provide an appropriate level of protection for its student information system and data increased the risk that personally identifiable information could be accidentally or maliciously exposed.
Cause:
UW-Parkside did not have a formal policy or procedures in place to provision, deprovision, and review access to its student information system. UW-Parkside staff indicated the process for provisioning and deprovisioning access had been informally operated, such as through electronic mail and direct communication and it did not consistently retain documentation of these communications. For example,
UW-Parkside indicated access requests were accepted from a variety of UW-Parkside employees. As a result, UW-Parkside had not assessed whether a user’s access was necessary or otherwise limited the access only to specific information needed or to a specified time period. Finally, UW-Parkside also indicated that prior efforts to improve its provisioning and deprovisioning of user access were not fully completed or implemented, in part, due to staff turnover.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-develop and implement written procedures for provisioning and deprovisioning user access to its student information system, including specifying those who are authorized to request user access and assigning responsibility to staff to assess access requests to restrict the access only to data needed for a specified period of time;
-retain consistent documentation of its provisioning and deprovisioning activities;
-develop and implement written procedures for a review at least annually of access granted to its student information system; and
-complete an assessment of users who currently have access to its student information system and remove those users who no longer require the access.
Finding 2024-711: Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-Madison must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. For students that begin attending classes, but who later withdraw from enrollment, 34 CFR s. 668.22 requires that UW-Madison must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In order not to consider a student to have withdrawn from enrollment under certain circumstances, which permits a student to retain federal financial assistance that otherwise would need to be returned to the federal government, 34 CFR s. 668.22 (a) (2) (ii) provides certain exemptions to students.
Condition:
For four students, we found that UW-Madison did not accurately determine the amount of federal financial assistance it disbursed that should have been returned to the U.S. Department of Education. First, we found that UW-Madison did not return all federal financial assistance it disbursed to two students that did not begin attendance and to one student who only attended one day during FY 2023-24. For these three students, UW-Madison determined it failed to return $16,403 in federal financial assistance it disbursed during FY 2023-24. Second, we found that UW-Madison did not accurately determine the federal financial assistance that should be returned after a student withdrew from enrollment during the summer 2023 term. For this student, UW-Madison incorrectly applied an exemption, which led to UW-Madison failing to return $584 in federal financial assistance to the U.S. Department of Education.
Context:
UW-Madison uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Madison staff its process for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Madison to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. When reviewing the data UW-Madison provided, we noted potential errors in the amount of aid returned for students identified as never attending.
Separately, as part of a UW systemwide sample of 60 students, we selected 6 students who had received federal financial assistance and who withdrew from enrollment from UW-Madison to determine the amount of federal financial assistance those students earned and the related amounts UW-Madison returned to the U.S. Department of Education.
Questioned Costs:
$16,987, Plus an Undetermined Amount
Effect:
UW-Madison did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Madison identified that the errors in determining the amount of the federal financial assistance that should have been returned to the federal government for the four students we identified were manual errors in the withdrawal procedures and calculations completed during and at the end of each term. These errors were not detected by any other review procedures. Although UW-Madison correctly identified the status of the two students who never attended and the need to return all disbursed federal financial assistance, it did not follow through on the actual repayment.
For the student who had an exemption applied, the exemption was incorrectly selected when UW-Madison completed a determination, and the error was not detected in UW-Madison’s review process. UW-Madison indicated that its automated review processes conducted at the end of each term did not specifically address the matters we identified for the four students.
After we identified these errors in the determination of the amount of federal financial assistance to return to the federal government, UW-Madison returned in fall 2024 the unearned federal financial assistance for the three students who never attended or withdrew from enrollment after attending one day. In addition, UW Madison returned the additional $584 in February 2025 for the student who withdrew from enrollment and did not meet the criteria for a withdrawal exemption.
Recommendation:
We recommend the University of Wisconsin-Madison review, update, and implement its procedures to improve the accuracy and follow-through for making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including thoroughly reviewing applied exemptions, and returning federal financial assistance in a timely manner to the federal government.
Finding 2024-703: Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,987, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Background:
UW-River Falls receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-River Falls reported a total of $23.6 million in federal financial assistance under the SFA Cluster. UW-River Falls is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-River Falls must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. Under Volume 5, Chapter 1 of the Federal Student Aid Handbook, when a student begins attendance in at least one course but does not begin attendance in all courses the student was scheduled to attend, the school must determine if it is necessary to recalculate the student’s eligibility for the Pell Grant based on a revised enrollment status and the cost of education pursuant to 34 CFR s. 690.80. If the student withdraws, this recalculation must be performed before determining whether to return federal financial assistance pursuant to 34 CFR s. 668.22.
Condition:
We found that UW-River Falls did not return $16,010 in federal financial assistance for four students that did not begin attendance in all enrolled courses during FY 2023-24. This included two students who never began attendance in any enrolled courses for whom all disbursed federal financial assistance was required to be returned. This also included two students who began at least one course but not all courses for which the students had enrolled. UW-River Falls did not perform the required recalculation of Pell Grant eligibility or an assessment of federal financial assistance it had disbursed that these students had not earned.
Context:
UW-River Falls uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-River Falls the process used for identifying students who did not begin attending all enrolled courses or withdrew from enrollment, and we requested a list of such students during FY 2023-24. UW-River Falls did not have a complete list readily available of students who did not begin attending all enrolled courses.
Questioned Costs:
$16,010, Plus an Undetermined Amount
Effect:
UW-River Falls did not comply with all requirements to return federal financial assistance for students who never attended or did not begin attending all enrolled courses during FY 2023-24.
Cause:
UW-River Falls did not have procedures to identify from its student information system, or other sources, those students for whom it disbursed federal financial assistance, yet the students did not attend at least one course during the term or begin all courses enrolled. Depending on whether a student dropped any of their courses, UW-River Falls indicated that the procedures to evaluate attendance may not have identified all students who would ultimately be determined as never attending for the academic term.
After we requested a list of students who did not begin attending all enrolled courses, UW-River Falls identified two students who did not begin at least one course but for whom it had disbursed federal financial assistance. For the other two students who began at least one course, UW-River Falls completed the required Pell Grant recalculation for the students. UW-River Falls also determined the amount of federal financial assistance to return for all four students, as applicable, to the U.S. Department of Education in September 2024.
Recommendation:
We recommend the University of Wisconsin-River Falls review, update, and implement procedures to:
-identify students after the start of each academic term for whom it disbursed federal financial assistance and the students did not begin all enrolled courses;
-complete required recalculations for Pell Grant eligibility and a determination of federal financial assistance that was not earned by the students, as applicable; and
-return amounts to the federal government in a timely manner.
Finding 2024-704: Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,010, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-River Falls: The University of Wisconsin-River Falls agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Background:
UW-Parkside receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Parkside reported a total of $21.3 million in federal financial assistance under the SFA Cluster. UW-Parkside is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22, requires that UW-Parkside must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW Parkside should be returned to the U.S. Department of Education unless certain conditions are met. In determining whether federal financial assistance was earned by a student, the Federal Student Aid Handbook provides guidance on how to calculate applicable institution charges and academic days under different circumstances.
Condition:
For two of three students we reviewed who withdrew from enrollment during FY 2023-24, UW-Parkside inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Parkside incorrectly accounted for a disbursement that occurred after the student’s withdrawal from enrollment as an amount that was earned by the student for the fall 2023 term. As a result, UW Parkside returned $548 less than what should have been returned to the U.S. Department of Education. For the second student, UW-Parkside incorrectly identified the end date of the spring 2024 term and did not include the correct institutional charges in its determination. As a result, UW-Parkside returned $1,190 less than should have been returned to the U.S. Department of Education.
Context:
UW-Parkside uses a student information system to track activity for students that withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Parkside staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from
UW-Parkside to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 3 students who had received federal financial assistance and withdrew from UW-Parkside to determine the amount of federal financial assistance those students earned and the related amounts UW-Parkside returned to the U.S. Department of Education.
Questioned Costs:
$1,738, Plus an Undetermined Amount
Effect:
UW-Parkside did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Parkside did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal assistance to return. Although UW-Parkside disbursed federal financial assistance later than is typical to one student, the disbursement was not correctly categorized within the calculations completed by UW-Parkside to determine that the entire amount of the federal financial assistance was required to be returned to the federal government.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the students we identified.
Finding 2024-705: Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $1,738, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Background:
UW-Platteville receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Platteville reported a total of $29.1 million in federal financial assistance under the SFA Cluster. UW-Platteville is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Under 34 CFR s. 668.21, UW-Platteville must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. In addition, when a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Platteville must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In determining whether federal financial assistance was earned by a student, Volume 5, Chapter 2 of the Federal Student Aid Handbook specifies how to calculate academic days.
Condition:
For two of the five students we reviewed who never began attendance or who withdrew from enrollment during FY 2023-24, UW-Platteville inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Platteville incorrectly determined the student began attendance because the student attended one day of the fall 2023 term. As a result, UW-Platteville failed to return $24 in federal financial assistance to the U.S. Department of Education. For the second student, UW-Platteville did not exclude a five-day break from its determination of the federal financial assistance amount the student had earned during the fall 2023 term. Although this student had earned all of the federal financial assistance prior to the student’s withdrawal from enrollment, UW-Platteville incorrectly returned $1,226. Because UW-Platteville used the same calculation for all determinations for the fall 2023 term, there may be further errors in the federal financial assistance amounts UW-Platteville determined.
Context:
UW-Platteville uses a student information system to track activity for students who withdraw from enrollment in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Platteville staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Platteville to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 5 students who had received federal financial assistance and who withdrew from UW-Platteville to determine the amount of federal financial assistance those students earned and the related amounts UW-Platteville returned to the U.S. Department of Education.
Questioned Costs:
$24, Plus an Undetermined Amount
Effect:
UW-Platteville did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Platteville did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal financial assistance to return to the federal government. After we identified the error for the student who attended only one day, UW-Platteville returned the additional $24 to the federal government in November 2024. For the fall 2023 term, UW-Platteville changed its fall break from four to five days, which required a change in the number of academic days used in the calculation of federal financial assistance earned when a student withdraws from enrollment. UW-Platteville did not have a process to review the academic calendar for purposes of its return procedures.
Recommendation:
We recommend the University of Wisconsin-Platteville review, update, and implement its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including annually reviewing the academic days used in its determinations.
Finding 2024-706: Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $24, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Platteville: The University of Wisconsin-Platteville agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Background:
UW-Whitewater receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Whitewater reported a total of $58.4 million in federal financial assistance under the SFA Cluster. UW-Whitewater is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Whitewater must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook, the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW-Whitewater is required to be returned to the U.S. Department of Education unless certain conditions are met.
Condition:
UW-Whitewater inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education for one of seven students we reviewed who withdrew from enrollment during FY 2023 24. UW-Whitewater incorrectly accounted for a disbursement to the student that occurred after the date for which UW-Whitewater later identified the student had withdrawn from enrollment as an amount that was earned by the student. As a result, UW-Whitewater failed to return $400 in federal financial assistance to the U.S. Department of Education for the spring 2024 term.
Context:
In order to determine the federal financial assistance a student earned and the amount that must be returned to the U.S. Department of Education for amounts a student did not earn, UW-Whitewater uses a student information system to track activity for students who withdraw. We discussed with UW-Whitewater staff the process used for identifying students who withdrew from enrollment. We also requested information from UW-Whitewater to identify students who withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 7 students who had received federal financial assistance and who withdrew from UW-Whitewater to determine the amount of federal financial assistance those students earned and the related amounts UW-Whitewater returned to the U.S. Department of Education.
Questioned Costs:
$400, Plus an Undetermined Amount
Effect:
UW-Whitewater did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Whitewater did not have adequate procedures to review and ensure its determination of the amount of federal assistance to return was accurate. Although UW-Whitewater disbursed federal financial assistance later than is typical to the student, the disbursement was not correctly categorized within the calculations completed by UW-Whitewater nor was the categorization error detected by other
UW-Whitewater procedures.
Recommendation:
We recommend the University of Wisconsin-Whitewater:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the student we identified.
Finding 2024-707: Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $400, Plus an Undetermined Amount
Type of Finding: Noncompliance
Response from the University of Wisconsin-Whitewater: The University of Wisconsin-Whitewater agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Madison is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to the National Student Loan Data System (NSLDS). Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Madison is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time;
-report the same effective date for a student who withdraws from enrollment as the date used in its determination of whether any federal financial assistance must be returned in accordance with
34 CFR s. 668.22;
-report a student who has completed a program with a status of “graduated” rather than “withdrawn”;
-maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed; and
-maintain the program begin date, which is the date the student first began attending the program being reported, if a student’s program of study has not changed.
Condition:
UW-Madison uses the National Student Clearinghouse (NSC) to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Madison that identify potential errors in UW-Madison’s reporting of student activities. It is the responsibility of UW-Madison to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Madison did not report to NSLDS accurate information for 12 of the 17 students we reviewed. First, UW-Madison did not accurately report a student who withdrew from enrollment without notification in a timely manner. Second, UW-Madison incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment. Third, UW-Madison incorrectly reported the program-level enrollment status effective date for two students. Fourth, UW-Madison incorrectly reported the program begin date for six students. In addition, UW Madison incorrectly reported both the program-level enrollment status effective date and program begin date for two students.
Context:
We discussed with UW-Madison staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Madison relies on data from its student information system to compile information to transmit to NSC. UW-Madison also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student that withdrew from UW-Madison and six students who graduated from UW-Madison. In addition, we selected ten additional UW-Madison students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Madison did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Madison did not report to NSLDS who had withdrawn from enrollment without notification, we found UW-Madison’s enrollment reporting procedures did not assign responsibility for communicating certain information to those staff in the registrar’s office who are responsible for NSLDS reporting. As a result, those students the financial aid office determined had withdrawn from enrollment without notification, and for which it had completed a determination of federal financial assistance the students did not earn, were not known to staff in the registrar’s office for purposes of NSLDS reporting. In addition, UW-Madison indicated that withdrawals from enrollment without notification are identified after the term ends and its student information system did not have a dedicated effective date field in order to automatically identify such student records for the required NSLDS reporting.
Second, for the student UW-Madison did not accurately report as graduated within NSLDS, we found UW‑Madison relied on a NSC process that is intended to simultaneously update a student’s enrollment status in NSLDS when UW-Madison separately updates a student’s degree as completed. UW-Madison did not complete a separate report to ensure the enrollment status for graduated students was accurately reflected in NSLDS. However, in 2022 NSC had published information that indicated reliance solely on NSC’s process may result in the incorrect status being reported under certain circumstances. Although NSC error reports identified that such errors were present, UW-Madison indicated that it did not review these errors until fall 2024 when it began implementing new U.S. Department of Education reporting requirements.
At that time, UW-Madison stated that it identified that it did not consistently and accurately report in NSLDS those students who had graduated. UW-Madison stated that it then began to work with NSC to identify the extent of the reporting inaccuracies.
Third, in 2021 NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW-Madison’s data from its student information system and had communicated error or warning codes to UW-Madison in these areas. However, UW-Madison did not sufficiently review whether the records identified by NSC as potential errors resulted in inaccurate reporting. For example, NSC used warning codes for potential errors in the program-level enrollment status effective dates. As warning codes do not prohibit submission of reporting, UW-Madison did not review the warnings.
Fourth, in 2021 NSC similarly published information on accurately reporting student program begin dates in NSLDS and NSC had also identified instances of potential inaccurate reporting in UW Madison’s data from its student information system. Although NSC had communicated error or warning codes to UW-Madison in these areas, UW-Madison had not sufficiently reviewed whether the records identified by NSC as potential errors resulted in inaccurate reporting until 2023. At that time, UW-Madison indicated that, after reviewing other NSC warnings, it identified that it did not accurately report program begin dates for students. UW-Madison indicated it then began to work to update its student information system data extraction process to identify the correct program begin date for its submissions to NSC. However, it did not implement these changes until after the audit period.
In addition, UW-Madison indicated that it had turnover in staff responsible for NSLDS reporting in 2021, which may have caused UW-Madison to have missed the NSC publications regarding reporting graduated students accurately, new warning codes, and the importance of reviewing certain warning codes to accurately complete NSLDS reporting.
Recommendation:
We recommend the University of Wisconsin-Madison:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as updating its student information system to allow for an automated identification process to communicate those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated and implement separate reporting to the National Student Clearinghouse to accurately report students who graduate;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program-level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program begin dates and update its student information system extraction process to accurately report program begin dates; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-708: Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Background:
UW-Milwaukee receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Milwaukee reported a total of $133.1 million in federal financial assistance under the SFA Cluster. UW-Milwaukee records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Milwaukee is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Milwaukee is required to maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed.
Condition:
UW-Milwaukee uses NSC to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Milwaukee that identify potential errors in UW-Milwaukee’s reporting of student activities through NSC. These errors are the responsibility of UW-Milwaukee to resolve to ensure its submissions to NSLDS are accurate and complete.
UW-Milwaukee did not report to NSLDS accurate information for the program level enrollment status effective date for five students we reviewed. In addition, based on how information from its student information system is extracted for student reporting to NSLDS, we found that the reporting inaccuracy extended to other UW-Milwaukee students.
Context:
We discussed with UW-Milwaukee staff its procedures for identifying student enrollment status changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Milwaukee relies on data from its student information system to compile information to transmit to NSC. UW-Milwaukee also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included two students who withdrew from UW-Milwaukee and four students who graduated from UW- Milwaukee. In addition, we selected ten additional UW-Milwaukee students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Milwaukee did not comply with requirements to accurately report certain student enrollment status changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
In 2021, NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW- Milwaukee’s data from its student information system and had communicated error or warning codes to UW-Milwaukee in these areas. UW-Milwaukee staff indicated that they were aware that NSC error reports included warnings to identify potential inaccurate reporting of program level enrollment status effective dates and that the errors were a known issue for Peoplesoft-based student information systems. However, UW-Milwaukee chose not to use an all-record update feature that was available to correct the program-level enrollment status effective dates for all student records simultaneously due to the risk that other reporting inaccuracies could result from the action. Further, UW-Milwaukee staff indicated that they were not aware that specific guidance on the program-level enrollment status effective date had been updated to reflect that corrections should be made to fully comply with NSLDS reporting requirements.
Recommendation:
We recommend the University of Wisconsin-Milwaukee:
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates; and
-report changes in student enrollment accurately, completely, and in a timely manner for all student changes that require reporting.
Finding 2024-709: Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Milwaukee: The University of Wisconsin-Milwaukee agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Background:
UW-Oshkosh receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Oshkosh reported a total of $45.3 million in federal financial assistance under the SFA Cluster. UW-Oshkosh records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Oshkosh is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Oshkosh is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time; and
-report a student who has completed a program with a status of “graduated” rather than “withdrawn.”
Condition:
UW-Oshkosh uses NSC to facilitate the enrollment reporting in NSLDS. NSC provides error reports to UW-Oshkosh that identify potential errors in UW Oshkosh’s reporting of student activities. It is the responsibility of UW-Oshkosh to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Oshkosh did not report to NSLDS accurate information for two of the three students we reviewed.
First, UW-Oshkosh did not report in a timely manner one student who withdrew from enrollment without notification. Second, UW-Oshkosh incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment.
Context:
We discussed with UW-Oshkosh staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and UW Oshkosh’s procedures for monitoring the reporting performed by NSC. UW-Oshkosh relies on data from its student information system to compile information to transmit to NSC. UW-Oshkosh also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve. To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023 24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student who withdrew from UW-Oshkosh and two students who graduated from UW‑Oshkosh.
Questioned Costs:
None.
Effect:
UW-Oshkosh did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Oshkosh did not report to NSLDS in a timely manner who had withdrawn from enrollment without notification, we found that UW-Oshkosh indicated that it believed it needed to report to NSLDS only when students withdrew from enrollment and had notified UW-Oshkosh of the withdrawal. As a result, students detected by UW Oshkosh through procedures completed by the financial aid office at the end of each term were not communicated to those staff in the registrar’s office who were responsible for NSLDS reporting.
Second, for the student UW-Oshkosh did not accurately report as graduated within NSLDS, we found that inaccuracies in the reporting of students who had graduated were noted on NSC error reports. However, UW-Oshkosh’s registrar’s office staff did sufficiently review the errors to correct the status in NSLDS.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as communicating those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-710: Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Background:
UW Parkside operates in a highly computerized environment and is responsible for maintaining confidential and sensitive information, such as student data. UW Parkside maintains its own student information system to administer federal student financial assistance programs under the SFA Cluster.
Criteria:
To ensure data processed and stored by UW-Parkside is protected from accidental or intentional misuse or destruction, and to provide proper internal control, information technology (IT) security policies and procedures are necessary. In addition, IT controls should be established to prevent inappropriate or inadvertent access to data. UW-Parkside is responsible for following specific requirements under the Gramm-Leach-Bliley Act (GLBA), which requires entities that administer student financial assistance programs to develop, implement, and maintain safeguards to protect the security, integrity, and confidentiality of student data.
Under GLBA, UW-Parkside is required to authenticate and permit access only to authorized users. Further, UW Board of Regents Policy 25-5 requires that UW-Parkside follow the National Institute of Standards and Technology (NIST) in establishing IT controls. NIST Special Publication (SP) 800-53, Security and Privacy Controls for Information Systems and Organizations, recommends best practices in IT controls related to user access. These best practices include developing a provisioning and deprovisioning process focused on limiting access in a manner that provides the least access based on business need; retaining documentation of provisioning and deprovisioning activities, including records of when such access was added or removed; and performing periodic reviews of access to ensure it remains appropriate.
Condition:
We found UW-Parkside did not have adequate IT controls in place during FY 2023-24 to provision, deprovision, and manage access to its student information system. First, UW-Parkside did not have a formal documented process to provision or deprovision user access to its student information system. Second, UW-Parkside did not maintain a list of provisioned users with access and was unable to generate a report of users provisioned or deprovisioned during FY 2023-24. Third, UW-Parkside did not complete a periodic review of access, which assists in ensuring its provisioning and deprovisioning processes are working as intended. Although failure in any one IT control may be detected by complementary IT controls, UW‑Parkside did not have effective IT controls in any of the three areas. As a result, UW-Parkside was at a higher risk of granting unauthorized access to its student information system.
Context:
We reviewed GLBA requirements, UW System Board of Regents policies, and NIST 800-53 guidance to identify policies and procedures for UW-Parkside’s monitoring of access granted to its student information system. We requested documentation from UW-Parkside to assess compliance with these policies.
Questioned Costs:
None.
Effect:
Ineffective general IT controls may permit controls over systems to operate improperly and may allow noncompliance to occur and not be detected. Weaknesses in IT security policies, procedures, and controls increase the risk that unauthorized or erroneous transactions could be processed or changes made to student data. In addition, failure to provide an appropriate level of protection for its student information system and data increased the risk that personally identifiable information could be accidentally or maliciously exposed.
Cause:
UW-Parkside did not have a formal policy or procedures in place to provision, deprovision, and review access to its student information system. UW-Parkside staff indicated the process for provisioning and deprovisioning access had been informally operated, such as through electronic mail and direct communication and it did not consistently retain documentation of these communications. For example,
UW-Parkside indicated access requests were accepted from a variety of UW-Parkside employees. As a result, UW-Parkside had not assessed whether a user’s access was necessary or otherwise limited the access only to specific information needed or to a specified time period. Finally, UW-Parkside also indicated that prior efforts to improve its provisioning and deprovisioning of user access were not fully completed or implemented, in part, due to staff turnover.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-develop and implement written procedures for provisioning and deprovisioning user access to its student information system, including specifying those who are authorized to request user access and assigning responsibility to staff to assess access requests to restrict the access only to data needed for a specified period of time;
-retain consistent documentation of its provisioning and deprovisioning activities;
-develop and implement written procedures for a review at least annually of access granted to its student information system; and
-complete an assessment of users who currently have access to its student information system and remove those users who no longer require the access.
Finding 2024-711: Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-Madison must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. For students that begin attending classes, but who later withdraw from enrollment, 34 CFR s. 668.22 requires that UW-Madison must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In order not to consider a student to have withdrawn from enrollment under certain circumstances, which permits a student to retain federal financial assistance that otherwise would need to be returned to the federal government, 34 CFR s. 668.22 (a) (2) (ii) provides certain exemptions to students.
Condition:
For four students, we found that UW-Madison did not accurately determine the amount of federal financial assistance it disbursed that should have been returned to the U.S. Department of Education. First, we found that UW-Madison did not return all federal financial assistance it disbursed to two students that did not begin attendance and to one student who only attended one day during FY 2023-24. For these three students, UW-Madison determined it failed to return $16,403 in federal financial assistance it disbursed during FY 2023-24. Second, we found that UW-Madison did not accurately determine the federal financial assistance that should be returned after a student withdrew from enrollment during the summer 2023 term. For this student, UW-Madison incorrectly applied an exemption, which led to UW-Madison failing to return $584 in federal financial assistance to the U.S. Department of Education.
Context:
UW-Madison uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Madison staff its process for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Madison to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. When reviewing the data UW-Madison provided, we noted potential errors in the amount of aid returned for students identified as never attending.
Separately, as part of a UW systemwide sample of 60 students, we selected 6 students who had received federal financial assistance and who withdrew from enrollment from UW-Madison to determine the amount of federal financial assistance those students earned and the related amounts UW-Madison returned to the U.S. Department of Education.
Questioned Costs:
$16,987, Plus an Undetermined Amount
Effect:
UW-Madison did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Madison identified that the errors in determining the amount of the federal financial assistance that should have been returned to the federal government for the four students we identified were manual errors in the withdrawal procedures and calculations completed during and at the end of each term. These errors were not detected by any other review procedures. Although UW-Madison correctly identified the status of the two students who never attended and the need to return all disbursed federal financial assistance, it did not follow through on the actual repayment.
For the student who had an exemption applied, the exemption was incorrectly selected when UW-Madison completed a determination, and the error was not detected in UW-Madison’s review process. UW-Madison indicated that its automated review processes conducted at the end of each term did not specifically address the matters we identified for the four students.
After we identified these errors in the determination of the amount of federal financial assistance to return to the federal government, UW-Madison returned in fall 2024 the unearned federal financial assistance for the three students who never attended or withdrew from enrollment after attending one day. In addition, UW Madison returned the additional $584 in February 2025 for the student who withdrew from enrollment and did not meet the criteria for a withdrawal exemption.
Recommendation:
We recommend the University of Wisconsin-Madison review, update, and implement its procedures to improve the accuracy and follow-through for making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including thoroughly reviewing applied exemptions, and returning federal financial assistance in a timely manner to the federal government.
Finding 2024-703: Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,987, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Background:
UW-River Falls receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-River Falls reported a total of $23.6 million in federal financial assistance under the SFA Cluster. UW-River Falls is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-River Falls must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. Under Volume 5, Chapter 1 of the Federal Student Aid Handbook, when a student begins attendance in at least one course but does not begin attendance in all courses the student was scheduled to attend, the school must determine if it is necessary to recalculate the student’s eligibility for the Pell Grant based on a revised enrollment status and the cost of education pursuant to 34 CFR s. 690.80. If the student withdraws, this recalculation must be performed before determining whether to return federal financial assistance pursuant to 34 CFR s. 668.22.
Condition:
We found that UW-River Falls did not return $16,010 in federal financial assistance for four students that did not begin attendance in all enrolled courses during FY 2023-24. This included two students who never began attendance in any enrolled courses for whom all disbursed federal financial assistance was required to be returned. This also included two students who began at least one course but not all courses for which the students had enrolled. UW-River Falls did not perform the required recalculation of Pell Grant eligibility or an assessment of federal financial assistance it had disbursed that these students had not earned.
Context:
UW-River Falls uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-River Falls the process used for identifying students who did not begin attending all enrolled courses or withdrew from enrollment, and we requested a list of such students during FY 2023-24. UW-River Falls did not have a complete list readily available of students who did not begin attending all enrolled courses.
Questioned Costs:
$16,010, Plus an Undetermined Amount
Effect:
UW-River Falls did not comply with all requirements to return federal financial assistance for students who never attended or did not begin attending all enrolled courses during FY 2023-24.
Cause:
UW-River Falls did not have procedures to identify from its student information system, or other sources, those students for whom it disbursed federal financial assistance, yet the students did not attend at least one course during the term or begin all courses enrolled. Depending on whether a student dropped any of their courses, UW-River Falls indicated that the procedures to evaluate attendance may not have identified all students who would ultimately be determined as never attending for the academic term.
After we requested a list of students who did not begin attending all enrolled courses, UW-River Falls identified two students who did not begin at least one course but for whom it had disbursed federal financial assistance. For the other two students who began at least one course, UW-River Falls completed the required Pell Grant recalculation for the students. UW-River Falls also determined the amount of federal financial assistance to return for all four students, as applicable, to the U.S. Department of Education in September 2024.
Recommendation:
We recommend the University of Wisconsin-River Falls review, update, and implement procedures to:
-identify students after the start of each academic term for whom it disbursed federal financial assistance and the students did not begin all enrolled courses;
-complete required recalculations for Pell Grant eligibility and a determination of federal financial assistance that was not earned by the students, as applicable; and
-return amounts to the federal government in a timely manner.
Finding 2024-704: Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,010, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-River Falls: The University of Wisconsin-River Falls agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Background:
UW-Parkside receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Parkside reported a total of $21.3 million in federal financial assistance under the SFA Cluster. UW-Parkside is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22, requires that UW-Parkside must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW Parkside should be returned to the U.S. Department of Education unless certain conditions are met. In determining whether federal financial assistance was earned by a student, the Federal Student Aid Handbook provides guidance on how to calculate applicable institution charges and academic days under different circumstances.
Condition:
For two of three students we reviewed who withdrew from enrollment during FY 2023-24, UW-Parkside inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Parkside incorrectly accounted for a disbursement that occurred after the student’s withdrawal from enrollment as an amount that was earned by the student for the fall 2023 term. As a result, UW Parkside returned $548 less than what should have been returned to the U.S. Department of Education. For the second student, UW-Parkside incorrectly identified the end date of the spring 2024 term and did not include the correct institutional charges in its determination. As a result, UW-Parkside returned $1,190 less than should have been returned to the U.S. Department of Education.
Context:
UW-Parkside uses a student information system to track activity for students that withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Parkside staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from
UW-Parkside to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 3 students who had received federal financial assistance and withdrew from UW-Parkside to determine the amount of federal financial assistance those students earned and the related amounts UW-Parkside returned to the U.S. Department of Education.
Questioned Costs:
$1,738, Plus an Undetermined Amount
Effect:
UW-Parkside did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Parkside did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal assistance to return. Although UW-Parkside disbursed federal financial assistance later than is typical to one student, the disbursement was not correctly categorized within the calculations completed by UW-Parkside to determine that the entire amount of the federal financial assistance was required to be returned to the federal government.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the students we identified.
Finding 2024-705: Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $1,738, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Background:
UW-Platteville receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Platteville reported a total of $29.1 million in federal financial assistance under the SFA Cluster. UW-Platteville is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Under 34 CFR s. 668.21, UW-Platteville must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. In addition, when a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Platteville must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In determining whether federal financial assistance was earned by a student, Volume 5, Chapter 2 of the Federal Student Aid Handbook specifies how to calculate academic days.
Condition:
For two of the five students we reviewed who never began attendance or who withdrew from enrollment during FY 2023-24, UW-Platteville inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Platteville incorrectly determined the student began attendance because the student attended one day of the fall 2023 term. As a result, UW-Platteville failed to return $24 in federal financial assistance to the U.S. Department of Education. For the second student, UW-Platteville did not exclude a five-day break from its determination of the federal financial assistance amount the student had earned during the fall 2023 term. Although this student had earned all of the federal financial assistance prior to the student’s withdrawal from enrollment, UW-Platteville incorrectly returned $1,226. Because UW-Platteville used the same calculation for all determinations for the fall 2023 term, there may be further errors in the federal financial assistance amounts UW-Platteville determined.
Context:
UW-Platteville uses a student information system to track activity for students who withdraw from enrollment in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Platteville staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Platteville to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 5 students who had received federal financial assistance and who withdrew from UW-Platteville to determine the amount of federal financial assistance those students earned and the related amounts UW-Platteville returned to the U.S. Department of Education.
Questioned Costs:
$24, Plus an Undetermined Amount
Effect:
UW-Platteville did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Platteville did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal financial assistance to return to the federal government. After we identified the error for the student who attended only one day, UW-Platteville returned the additional $24 to the federal government in November 2024. For the fall 2023 term, UW-Platteville changed its fall break from four to five days, which required a change in the number of academic days used in the calculation of federal financial assistance earned when a student withdraws from enrollment. UW-Platteville did not have a process to review the academic calendar for purposes of its return procedures.
Recommendation:
We recommend the University of Wisconsin-Platteville review, update, and implement its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including annually reviewing the academic days used in its determinations.
Finding 2024-706: Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $24, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Platteville: The University of Wisconsin-Platteville agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Background:
UW-Whitewater receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Whitewater reported a total of $58.4 million in federal financial assistance under the SFA Cluster. UW-Whitewater is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Whitewater must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook, the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW-Whitewater is required to be returned to the U.S. Department of Education unless certain conditions are met.
Condition:
UW-Whitewater inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education for one of seven students we reviewed who withdrew from enrollment during FY 2023 24. UW-Whitewater incorrectly accounted for a disbursement to the student that occurred after the date for which UW-Whitewater later identified the student had withdrawn from enrollment as an amount that was earned by the student. As a result, UW-Whitewater failed to return $400 in federal financial assistance to the U.S. Department of Education for the spring 2024 term.
Context:
In order to determine the federal financial assistance a student earned and the amount that must be returned to the U.S. Department of Education for amounts a student did not earn, UW-Whitewater uses a student information system to track activity for students who withdraw. We discussed with UW-Whitewater staff the process used for identifying students who withdrew from enrollment. We also requested information from UW-Whitewater to identify students who withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 7 students who had received federal financial assistance and who withdrew from UW-Whitewater to determine the amount of federal financial assistance those students earned and the related amounts UW-Whitewater returned to the U.S. Department of Education.
Questioned Costs:
$400, Plus an Undetermined Amount
Effect:
UW-Whitewater did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Whitewater did not have adequate procedures to review and ensure its determination of the amount of federal assistance to return was accurate. Although UW-Whitewater disbursed federal financial assistance later than is typical to the student, the disbursement was not correctly categorized within the calculations completed by UW-Whitewater nor was the categorization error detected by other
UW-Whitewater procedures.
Recommendation:
We recommend the University of Wisconsin-Whitewater:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the student we identified.
Finding 2024-707: Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $400, Plus an Undetermined Amount
Type of Finding: Noncompliance
Response from the University of Wisconsin-Whitewater: The University of Wisconsin-Whitewater agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Madison is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to the National Student Loan Data System (NSLDS). Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Madison is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time;
-report the same effective date for a student who withdraws from enrollment as the date used in its determination of whether any federal financial assistance must be returned in accordance with
34 CFR s. 668.22;
-report a student who has completed a program with a status of “graduated” rather than “withdrawn”;
-maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed; and
-maintain the program begin date, which is the date the student first began attending the program being reported, if a student’s program of study has not changed.
Condition:
UW-Madison uses the National Student Clearinghouse (NSC) to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Madison that identify potential errors in UW-Madison’s reporting of student activities. It is the responsibility of UW-Madison to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Madison did not report to NSLDS accurate information for 12 of the 17 students we reviewed. First, UW-Madison did not accurately report a student who withdrew from enrollment without notification in a timely manner. Second, UW-Madison incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment. Third, UW-Madison incorrectly reported the program-level enrollment status effective date for two students. Fourth, UW-Madison incorrectly reported the program begin date for six students. In addition, UW Madison incorrectly reported both the program-level enrollment status effective date and program begin date for two students.
Context:
We discussed with UW-Madison staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Madison relies on data from its student information system to compile information to transmit to NSC. UW-Madison also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student that withdrew from UW-Madison and six students who graduated from UW-Madison. In addition, we selected ten additional UW-Madison students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Madison did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Madison did not report to NSLDS who had withdrawn from enrollment without notification, we found UW-Madison’s enrollment reporting procedures did not assign responsibility for communicating certain information to those staff in the registrar’s office who are responsible for NSLDS reporting. As a result, those students the financial aid office determined had withdrawn from enrollment without notification, and for which it had completed a determination of federal financial assistance the students did not earn, were not known to staff in the registrar’s office for purposes of NSLDS reporting. In addition, UW-Madison indicated that withdrawals from enrollment without notification are identified after the term ends and its student information system did not have a dedicated effective date field in order to automatically identify such student records for the required NSLDS reporting.
Second, for the student UW-Madison did not accurately report as graduated within NSLDS, we found UW‑Madison relied on a NSC process that is intended to simultaneously update a student’s enrollment status in NSLDS when UW-Madison separately updates a student’s degree as completed. UW-Madison did not complete a separate report to ensure the enrollment status for graduated students was accurately reflected in NSLDS. However, in 2022 NSC had published information that indicated reliance solely on NSC’s process may result in the incorrect status being reported under certain circumstances. Although NSC error reports identified that such errors were present, UW-Madison indicated that it did not review these errors until fall 2024 when it began implementing new U.S. Department of Education reporting requirements.
At that time, UW-Madison stated that it identified that it did not consistently and accurately report in NSLDS those students who had graduated. UW-Madison stated that it then began to work with NSC to identify the extent of the reporting inaccuracies.
Third, in 2021 NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW-Madison’s data from its student information system and had communicated error or warning codes to UW-Madison in these areas. However, UW-Madison did not sufficiently review whether the records identified by NSC as potential errors resulted in inaccurate reporting. For example, NSC used warning codes for potential errors in the program-level enrollment status effective dates. As warning codes do not prohibit submission of reporting, UW-Madison did not review the warnings.
Fourth, in 2021 NSC similarly published information on accurately reporting student program begin dates in NSLDS and NSC had also identified instances of potential inaccurate reporting in UW Madison’s data from its student information system. Although NSC had communicated error or warning codes to UW-Madison in these areas, UW-Madison had not sufficiently reviewed whether the records identified by NSC as potential errors resulted in inaccurate reporting until 2023. At that time, UW-Madison indicated that, after reviewing other NSC warnings, it identified that it did not accurately report program begin dates for students. UW-Madison indicated it then began to work to update its student information system data extraction process to identify the correct program begin date for its submissions to NSC. However, it did not implement these changes until after the audit period.
In addition, UW-Madison indicated that it had turnover in staff responsible for NSLDS reporting in 2021, which may have caused UW-Madison to have missed the NSC publications regarding reporting graduated students accurately, new warning codes, and the importance of reviewing certain warning codes to accurately complete NSLDS reporting.
Recommendation:
We recommend the University of Wisconsin-Madison:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as updating its student information system to allow for an automated identification process to communicate those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated and implement separate reporting to the National Student Clearinghouse to accurately report students who graduate;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program-level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program begin dates and update its student information system extraction process to accurately report program begin dates; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-708: Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Background:
UW-Milwaukee receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Milwaukee reported a total of $133.1 million in federal financial assistance under the SFA Cluster. UW-Milwaukee records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Milwaukee is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Milwaukee is required to maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed.
Condition:
UW-Milwaukee uses NSC to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Milwaukee that identify potential errors in UW-Milwaukee’s reporting of student activities through NSC. These errors are the responsibility of UW-Milwaukee to resolve to ensure its submissions to NSLDS are accurate and complete.
UW-Milwaukee did not report to NSLDS accurate information for the program level enrollment status effective date for five students we reviewed. In addition, based on how information from its student information system is extracted for student reporting to NSLDS, we found that the reporting inaccuracy extended to other UW-Milwaukee students.
Context:
We discussed with UW-Milwaukee staff its procedures for identifying student enrollment status changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Milwaukee relies on data from its student information system to compile information to transmit to NSC. UW-Milwaukee also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included two students who withdrew from UW-Milwaukee and four students who graduated from UW- Milwaukee. In addition, we selected ten additional UW-Milwaukee students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Milwaukee did not comply with requirements to accurately report certain student enrollment status changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
In 2021, NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW- Milwaukee’s data from its student information system and had communicated error or warning codes to UW-Milwaukee in these areas. UW-Milwaukee staff indicated that they were aware that NSC error reports included warnings to identify potential inaccurate reporting of program level enrollment status effective dates and that the errors were a known issue for Peoplesoft-based student information systems. However, UW-Milwaukee chose not to use an all-record update feature that was available to correct the program-level enrollment status effective dates for all student records simultaneously due to the risk that other reporting inaccuracies could result from the action. Further, UW-Milwaukee staff indicated that they were not aware that specific guidance on the program-level enrollment status effective date had been updated to reflect that corrections should be made to fully comply with NSLDS reporting requirements.
Recommendation:
We recommend the University of Wisconsin-Milwaukee:
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates; and
-report changes in student enrollment accurately, completely, and in a timely manner for all student changes that require reporting.
Finding 2024-709: Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Milwaukee: The University of Wisconsin-Milwaukee agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Background:
UW-Oshkosh receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Oshkosh reported a total of $45.3 million in federal financial assistance under the SFA Cluster. UW-Oshkosh records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Oshkosh is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Oshkosh is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time; and
-report a student who has completed a program with a status of “graduated” rather than “withdrawn.”
Condition:
UW-Oshkosh uses NSC to facilitate the enrollment reporting in NSLDS. NSC provides error reports to UW-Oshkosh that identify potential errors in UW Oshkosh’s reporting of student activities. It is the responsibility of UW-Oshkosh to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Oshkosh did not report to NSLDS accurate information for two of the three students we reviewed.
First, UW-Oshkosh did not report in a timely manner one student who withdrew from enrollment without notification. Second, UW-Oshkosh incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment.
Context:
We discussed with UW-Oshkosh staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and UW Oshkosh’s procedures for monitoring the reporting performed by NSC. UW-Oshkosh relies on data from its student information system to compile information to transmit to NSC. UW-Oshkosh also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve. To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023 24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student who withdrew from UW-Oshkosh and two students who graduated from UW‑Oshkosh.
Questioned Costs:
None.
Effect:
UW-Oshkosh did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Oshkosh did not report to NSLDS in a timely manner who had withdrawn from enrollment without notification, we found that UW-Oshkosh indicated that it believed it needed to report to NSLDS only when students withdrew from enrollment and had notified UW-Oshkosh of the withdrawal. As a result, students detected by UW Oshkosh through procedures completed by the financial aid office at the end of each term were not communicated to those staff in the registrar’s office who were responsible for NSLDS reporting.
Second, for the student UW-Oshkosh did not accurately report as graduated within NSLDS, we found that inaccuracies in the reporting of students who had graduated were noted on NSC error reports. However, UW-Oshkosh’s registrar’s office staff did sufficiently review the errors to correct the status in NSLDS.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as communicating those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-710: Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Background:
UW Parkside operates in a highly computerized environment and is responsible for maintaining confidential and sensitive information, such as student data. UW Parkside maintains its own student information system to administer federal student financial assistance programs under the SFA Cluster.
Criteria:
To ensure data processed and stored by UW-Parkside is protected from accidental or intentional misuse or destruction, and to provide proper internal control, information technology (IT) security policies and procedures are necessary. In addition, IT controls should be established to prevent inappropriate or inadvertent access to data. UW-Parkside is responsible for following specific requirements under the Gramm-Leach-Bliley Act (GLBA), which requires entities that administer student financial assistance programs to develop, implement, and maintain safeguards to protect the security, integrity, and confidentiality of student data.
Under GLBA, UW-Parkside is required to authenticate and permit access only to authorized users. Further, UW Board of Regents Policy 25-5 requires that UW-Parkside follow the National Institute of Standards and Technology (NIST) in establishing IT controls. NIST Special Publication (SP) 800-53, Security and Privacy Controls for Information Systems and Organizations, recommends best practices in IT controls related to user access. These best practices include developing a provisioning and deprovisioning process focused on limiting access in a manner that provides the least access based on business need; retaining documentation of provisioning and deprovisioning activities, including records of when such access was added or removed; and performing periodic reviews of access to ensure it remains appropriate.
Condition:
We found UW-Parkside did not have adequate IT controls in place during FY 2023-24 to provision, deprovision, and manage access to its student information system. First, UW-Parkside did not have a formal documented process to provision or deprovision user access to its student information system. Second, UW-Parkside did not maintain a list of provisioned users with access and was unable to generate a report of users provisioned or deprovisioned during FY 2023-24. Third, UW-Parkside did not complete a periodic review of access, which assists in ensuring its provisioning and deprovisioning processes are working as intended. Although failure in any one IT control may be detected by complementary IT controls, UW‑Parkside did not have effective IT controls in any of the three areas. As a result, UW-Parkside was at a higher risk of granting unauthorized access to its student information system.
Context:
We reviewed GLBA requirements, UW System Board of Regents policies, and NIST 800-53 guidance to identify policies and procedures for UW-Parkside’s monitoring of access granted to its student information system. We requested documentation from UW-Parkside to assess compliance with these policies.
Questioned Costs:
None.
Effect:
Ineffective general IT controls may permit controls over systems to operate improperly and may allow noncompliance to occur and not be detected. Weaknesses in IT security policies, procedures, and controls increase the risk that unauthorized or erroneous transactions could be processed or changes made to student data. In addition, failure to provide an appropriate level of protection for its student information system and data increased the risk that personally identifiable information could be accidentally or maliciously exposed.
Cause:
UW-Parkside did not have a formal policy or procedures in place to provision, deprovision, and review access to its student information system. UW-Parkside staff indicated the process for provisioning and deprovisioning access had been informally operated, such as through electronic mail and direct communication and it did not consistently retain documentation of these communications. For example,
UW-Parkside indicated access requests were accepted from a variety of UW-Parkside employees. As a result, UW-Parkside had not assessed whether a user’s access was necessary or otherwise limited the access only to specific information needed or to a specified time period. Finally, UW-Parkside also indicated that prior efforts to improve its provisioning and deprovisioning of user access were not fully completed or implemented, in part, due to staff turnover.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-develop and implement written procedures for provisioning and deprovisioning user access to its student information system, including specifying those who are authorized to request user access and assigning responsibility to staff to assess access requests to restrict the access only to data needed for a specified period of time;
-retain consistent documentation of its provisioning and deprovisioning activities;
-develop and implement written procedures for a review at least annually of access granted to its student information system; and
-complete an assessment of users who currently have access to its student information system and remove those users who no longer require the access.
Finding 2024-711: Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Dairy Business Innovation Initiatives—Cash Management
Background:
During FY 2023-24, UW-Madison expended $9.9 million in federal funds for the DBII grant, which is administered by the U.S. Department of Agriculture. This grant program was first authorized in 2018, and UW Madison has received annual awards for the program since 2019. At least one-half of each award is used for grants to farmers or dairy processors to diversify farming activities, create value-added products, or enhance dairy export programs. For each DBII award UW Madison received, it subawarded approximately 60.0 percent to a subrecipient to assist with administering the grants to farmers and dairy processors under the program.
Criteria:
Under 2 CFR s. 200.305 (b), UW-Madison is required to implement procedures to ensure that the time between payments it makes to the subrecipient and the subrecipient’s disbursement of the funds for program purposes is minimized. Under 2 CFR s. 200.305 (b) (4), UW-Madison is permitted to provide advanced payments to a subrecipient if it determines that the subrecipient lacks sufficient working capital. However, if such an advanced payment is made, the payment should be aligned to the anticipated disbursements and subsequent payments are required to be on a reimbursement basis. Finally, 2 CFR s. 200.305 (b) (12), requires that any payments UW Madison makes to a subrecipient should not result in the subrecipient retaining more than $500 in interest earnings and any interest earnings that exceed $500 should be annually remitted to the federal government.
Condition:
We noted three concerns with UW-Madison cash management procedures for advancing funds to the subrecipient. First, we identified that UW-Madison did not ensure that the time between the subrecipient receiving funds and the subrecipient disbursing the funds to grant recipients was appropriately minimized. According to the subrecipient records, the subrecipient did not begin disbursing funds it received
in June 2023 until January 2024. Second, although UW Madison provided advanced payments to the DBII subrecipient, it did not use the reimbursement method when subsequent payments were made to the subrecipient. Third, UW Madison did not adequately monitor interest that had accrued on the subrecipient’s cash balance. As a result, the subrecipient’s records identified that it had accrued $148,357 in interest earnings in excess of federal requirements from August 2022 to August 2024, and no interest had been returned to the federal government as of June 30, 2024.
Context:
UW Madison made payments totaling $6.3 million to the DBII subrecipient during FY 2023 24, which included advancing funding to the subrecipient to enable the subrecipient to make payments as requested from grant recipients. We reviewed the subrecipient’s financial information to assess UW Madison’s decision to provide advanced payments to the subrecipient on the basis of a lack of sufficient working capital. We also reviewed UW Madison’s procedures for communicating the requirements for funds it advanced to the subrecipient, monitoring the subrecipient’s payments to grant recipients, and assessing how and when to advance funds to the subrecipient based on the payments anticipated for grants awarded. Information provided by the subrecipient indicated that, on average, the subrecipient held a cash balance of $3.9 million each month during FY 2023 24.
Questioned Costs:
None.
Effect:
UW Madison did not comply with federal requirements to ensure that time was minimized between payments to its subrecipient for the DBII grant and when the subrecipient disbursed the funds to grant recipients. In addition, UW-Madison did not comply with federal requirements to return interest earned by its subrecipient in a timely manner.
Cause:
First, UW Madison’s practice of making an advanced payment to the DBII subrecipient at the time a subaward was executed did not evaluate when the subrecipient would need to make payments to grant recipients. After UW-Madison made an initial advanced payment to the subrecipient to assist the subrecipient with managing cash flow needs, it required the subrecipient to expend 80.0 percent of the funds it had advanced before UW Madison would authorize additional payments. UW Madison also made decisions on whether to make further payments to the subrecipient for each subaward rather than reviewing the subrecipient’s available cash balance across multiple subawards. This resulted in the subrecipient having larger balances over time from advanced funds it received under multiple DBII awards.
Second, UW Madison staff indicated that UW Madison did not typically provide advanced payments to a subrecipient. As a result, it did not sufficiently consider all the federal requirements, such as using the reimbursement method for payments to the subrecipient subsequent to the initial advanced payment. UW Madison also did not include all relevant information in its subrecipient agreement related to cash management requirements.
Third, the DBII subrecipient did not inform UW Madison of interest earnings it had accumulated nor did UW Madison inquire with the subrecipient about any interest earnings to assess whether any had been earned in excess of federal requirements. UW Madison did not review aggregated balances from advance payments made under multiple subawards. In July 2024, the DBII subrecipient asked UW Madison
how interest earnings it had accumulated could be expended. UW Madison determined that the funds were required to be returned to the federal government. In October 2024, the subrecipient reported its interest earnings to UW-Madison and subsequently remitted $148,357 to UW Madison. UW Madison returned these funds to the federal government in January 2025.
Recommendation:
We recommend the University of Wisconsin Madison revise and document its procedures for:
-ensuring that its disbursements to the subrecipient complies with all federal cash management requirements;
-identifying applicable federal requirements to include in its subrecipient agreements when advanced cash payments are made, including requirements for interest earnings that results from advanced payments; and
-monitoring interest earnings that accrue to the subrecipient when advanced payments are made and returning in a timely manner any interest that exceeds federal limits.
Finding 2024-713: Dairy Business Innovation Initiatives—Cash Management
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM190100XXXG079 2019
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the cash management compliance requirement.
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendations.
Dairy Business Innovation Initiatives—Subrecipient Monitoring
Background:
During FY 2023-24, UW-Madison expended $9.9 million in federal funds for the DBII grant, which is administered by the U.S. Department of Agriculture. This grant program was first authorized in 2018, and UW-Madison has received annual awards for the program since 2019. UW-Madison subawarded approximately 60.0 percent of each DBII award it received to a subrecipient. The subrecipient’s primary function was to award grants to farmers or dairy processors to diversify farming activities, create value-added products, or enhance dairy export programs.
Criteria:
Under 2 CFR s. 200.332 (e), UW-Madison is required to monitor the activities of a subrecipient as necessary to ensure the subrecipient complies with federal statutes, regulations, and the terms and conditions of the subaward. Additionally, under 2 CFR s. 200.332 (f), pass-through entities must verify that a subrecipient is audited as required by 2 CFR Part 200 Subpart F, which requires that certain entities expending $750,000
or more of federal funds during a year have a single audit performed. UW Madison’s Research and Sponsored Programs (RSP) is responsible for monitoring subrecipient audit requirements prior to entering into contracts. As part of fulfilling its requirements under 2 CFR s. 200.332 (d), RSP requires subrecipients to complete an annual audit certification and provide a copy of its single audit, if applicable.
Condition:
We identified from UW Madison’s expenditures that it made payments to the DBII subrecipient of more than $750,000 during FY 2022-23 and, therefore, the subrecipient should have been subject to a single audit. However, UW Madison did not sufficiently monitor the subrecipient during FY 2023 24 to ensure the subrecipient was audited as required by 2 CFR s. 200.332 (f). The subrecipient did not have a FY 2022-23 single audit performed.
Context:
UW Madison made payments totaling $6.3 million to the DBII subrecipient during FY 2023 24 with a similar amount provided in the prior fiscal year. We reviewed the April 2024 annual audit certification submitted by the subrecipient, which included whether the subrecipient had completed a single audit for FY 2022 23. We searched the federal audit clearinghouse to determine whether the DBII subrecipient had submitted a single audit report. After we raised the issue, UW Madison contacted the subrecipient. UW-Madison indicated to us that the subrecipient had misunderstood the requirements.
Questioned Costs:
None.
Effect:
Without adequate monitoring, there is an increased risk of unallowable costs being charged to the DBII grant, or other noncompliance with federal regulations.
Cause:
RSP did not adequately evaluate the annual audit certification provided by the DBII subrecipient or perform other procedures to identify that an audit was required for the subrecipient.
Recommendation:
We recommend the University of Wisconsin Madison update its procedures for reviewing annual audit certifications received from subrecipients to include reviewing
its expenditures with a subrecipient or other procedures to assist it in assessing subrecipient responses.
Finding 2024-701: Dairy Business Innovation Initiatives—Subrecipient Monitoring
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Dairy Business Innovation Initiatives—Federal Funding Accountability and Transparency Act Reporting
Background:
During FY 2023-24, UW-Madison expended $9.9 million in federal funds for the DBII grant, which is administered by the U.S. Department of Agriculture. This grant program was first authorized in 2018, and UW-Madison has received annual awards for the program since 2019. UW-Madison subawarded approximately 60.0 percent of each DBII award it received to a subrecipient. The subrecipient’s primary function was to award grants to farmers or dairy processors to diversify farming activities, create value-added products, or enhance dairy export programs.
Under the Federal Funding Accountability and Transparency Act (FFATA), a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
Criteria:
Under 2 CFR s. 170, UW-Madison is required to report in the FFATA Subaward Reporting System (FSRS) subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the subaward was made. For example, if the subaward was made on November 7, 2023, it must be reported in FSRS no later than December 31, 2023. DBII subawards of $30,000 or more are subject to FFATA reporting. UW Madison’s RSP is responsible for reporting subaward information to FSRS.
Condition:
Of the two subaward actions that occurred in FY 2023 24 for the DBII grant, we found UW Madison did not report one subaward action in a timely manner in FSRS. Although UW Madison completed a $250,000 subaward modification to a subrecipient in October 2023, it did not submit the information in FSRS until December 2024 after we inquired about FFATA reporting for DBII.
Context:
We discussed with RSP staff its procedures for identifying subawards that require reporting to FSRS. We reviewed subawards UW Madison executed or modified for DBII during FY 2023 24 to identify whether FFATA reporting requirements applied. We assessed whether the subaward actions were accurately and entered into FSRS in a timely manner.
Questioned Costs:
None.
Effect:
UW Madison’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov for DBII. UW Madison did not comply with FFATA requirements for the timely reporting of subawards in FSRS for DBII.
Cause:
RSP staff indicated that an error occurred during the November 2023 submission process that prevented the subaward information from being uploaded in FSRS. A subsequent monthly error report identified that the federal aid identification number was not found in FSRS, yet RSP did not resolve this error until we inquired about FFATA reporting. No other detective procedures were in place to identify that FFATA reporting had not occurred for the subaward.
Recommendation:
We recommend the University of Wisconsin Madison:
-review and update its procedures for reviewing the FFATA Subaward Reporting System (FSRS) reporting errors and taking corrective action in a timely manner on all reported errors; and
-implement other monitoring procedures to ensure FSRS reporting is accurate and completed in a timely manner.
Finding 2024-702: Dairy Business Innovation Initiatives—Federal Funding Accountability and Transparency Act Reporting
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting
Background:
The U.S. Department of Agriculture provides funding to DPI through the programs of CNC. The purpose of these programs is to:
-assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential child care institutions, and summer programs;
-foster healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary schools; and
-encourage the domestic consumption of nutritious agricultural commodities.
DPI subawards CNC funding to schools and other entities to execute the programs.
Under the Federal Funding Accountability and Transparency Act (FFATA), a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
Criteria:
Under 2 CFR s. 170, DPI is required to report in the FFATA Subaward Reporting System (FSRS) subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the subaward was made. For example, if the subaward was made on November 7, 2023, it must be reported in FSRS not later than December 31, 2023. CNC subawards of $30,000 or more are subject to FFATA reporting.
Condition:
Although DPI made subawards of $30,000 or more in CNC funding to schools and other entities in FY 2023-24, DPI did not report any CNC subawards in FSRS during FY 2023-24.
Context:
Of the $361.0 million expended during FY 2023-24 under CNC, DPI disbursed $342.4 million to schools and other entities. We interviewed DPI staff to gain an understanding of the procedures for compiling information for CNC subawards and submitting the information in FSRS.
Questioned Costs:
None.
Effect:
The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov for CNC. DPI did not comply with FFATA requirements for the timely reporting of subawards in FSRS for CNC.
Cause:
Although DPI staff completed FFATA reporting for other grant programs DPI administers, DPI staff did not identify that FFATA reporting requirements applied to CNC. As a result, DPI did not have policies or procedures to collect the required subaward information for CNC programs from DPI’s computer system. Therefore, this information was not reported in FSRS.
As a result of our inquires, DPI staff discussed the requirements with the U.S. Department of Agriculture to understand how to collect the subaward information required to be reported in FSRS for the CNC programs.
Recommendation:
We recommend the Wisconsin Department of Public Instruction:
-develop written policies and procedures for identifying when Federal Funding Accountability and Transparency Act (FFATA) reporting requirements are applicable to a federal award it administers;
-develop written policies and procedures for timely identification and reporting of Child Nutrition Cluster program subawards of $30,000 or more, including any amendments or modifications to a subaward, to the FFATA Subaward Reporting System; and
-complete monthly FFATA reporting for the Child Nutrition Cluster programs following the established policies and procedures.
Finding 2024-400: Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting
Child Nutrition Cluster (Assistance Listing numbers 10.553, 10.555, 10.556, 10.559, and 10.582)
Award Numbers Award Years
212WI063N1099 2021
212WI063N1199 2021
212WI063N8903 2021
222WI063N1099 2022
222WI063N1199 2022
222WI063N8903 2022
232WI063N1099 2023
232WI063N1199 2023
232WI063L1603 2023
242WI063N1099 2024
242WI063N1199 2024
242WI063N8903 2024
242WI063L1603 2024
Questioned Costs: None
COVID-19—National School Lunch Program (Assistance Listing number 10.555)
Award Number Award Year
232WI063N8903 2023
Questioned Costs: None
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the reporting compliance requirement.
Response from the Wisconsin Department of Public Instruction: The Wisconsin Department of Public Instruction agrees with the audit finding and recommendations.
Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting
Background:
The U.S. Department of Agriculture provides funding to DPI through the programs of CNC. The purpose of these programs is to:
-assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential child care institutions, and summer programs;
-foster healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary schools; and
-encourage the domestic consumption of nutritious agricultural commodities.
DPI subawards CNC funding to schools and other entities to execute the programs.
Under the Federal Funding Accountability and Transparency Act (FFATA), a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
Criteria:
Under 2 CFR s. 170, DPI is required to report in the FFATA Subaward Reporting System (FSRS) subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the subaward was made. For example, if the subaward was made on November 7, 2023, it must be reported in FSRS not later than December 31, 2023. CNC subawards of $30,000 or more are subject to FFATA reporting.
Condition:
Although DPI made subawards of $30,000 or more in CNC funding to schools and other entities in FY 2023-24, DPI did not report any CNC subawards in FSRS during FY 2023-24.
Context:
Of the $361.0 million expended during FY 2023-24 under CNC, DPI disbursed $342.4 million to schools and other entities. We interviewed DPI staff to gain an understanding of the procedures for compiling information for CNC subawards and submitting the information in FSRS.
Questioned Costs:
None.
Effect:
The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov for CNC. DPI did not comply with FFATA requirements for the timely reporting of subawards in FSRS for CNC.
Cause:
Although DPI staff completed FFATA reporting for other grant programs DPI administers, DPI staff did not identify that FFATA reporting requirements applied to CNC. As a result, DPI did not have policies or procedures to collect the required subaward information for CNC programs from DPI’s computer system. Therefore, this information was not reported in FSRS.
As a result of our inquires, DPI staff discussed the requirements with the U.S. Department of Agriculture to understand how to collect the subaward information required to be reported in FSRS for the CNC programs.
Recommendation:
We recommend the Wisconsin Department of Public Instruction:
-develop written policies and procedures for identifying when Federal Funding Accountability and Transparency Act (FFATA) reporting requirements are applicable to a federal award it administers;
-develop written policies and procedures for timely identification and reporting of Child Nutrition Cluster program subawards of $30,000 or more, including any amendments or modifications to a subaward, to the FFATA Subaward Reporting System; and
-complete monthly FFATA reporting for the Child Nutrition Cluster programs following the established policies and procedures.
Finding 2024-400: Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting
Child Nutrition Cluster (Assistance Listing numbers 10.553, 10.555, 10.556, 10.559, and 10.582)
Award Numbers Award Years
212WI063N1099 2021
212WI063N1199 2021
212WI063N8903 2021
222WI063N1099 2022
222WI063N1199 2022
222WI063N8903 2022
232WI063N1099 2023
232WI063N1199 2023
232WI063L1603 2023
242WI063N1099 2024
242WI063N1199 2024
242WI063N8903 2024
242WI063L1603 2024
Questioned Costs: None
COVID-19—National School Lunch Program (Assistance Listing number 10.555)
Award Number Award Year
232WI063N8903 2023
Questioned Costs: None
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the reporting compliance requirement.
Response from the Wisconsin Department of Public Instruction: The Wisconsin Department of Public Instruction agrees with the audit finding and recommendations.
Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting
Background:
The U.S. Department of Agriculture provides funding to DPI through the programs of CNC. The purpose of these programs is to:
-assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential child care institutions, and summer programs;
-foster healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary schools; and
-encourage the domestic consumption of nutritious agricultural commodities.
DPI subawards CNC funding to schools and other entities to execute the programs.
Under the Federal Funding Accountability and Transparency Act (FFATA), a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
Criteria:
Under 2 CFR s. 170, DPI is required to report in the FFATA Subaward Reporting System (FSRS) subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the subaward was made. For example, if the subaward was made on November 7, 2023, it must be reported in FSRS not later than December 31, 2023. CNC subawards of $30,000 or more are subject to FFATA reporting.
Condition:
Although DPI made subawards of $30,000 or more in CNC funding to schools and other entities in FY 2023-24, DPI did not report any CNC subawards in FSRS during FY 2023-24.
Context:
Of the $361.0 million expended during FY 2023-24 under CNC, DPI disbursed $342.4 million to schools and other entities. We interviewed DPI staff to gain an understanding of the procedures for compiling information for CNC subawards and submitting the information in FSRS.
Questioned Costs:
None.
Effect:
The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov for CNC. DPI did not comply with FFATA requirements for the timely reporting of subawards in FSRS for CNC.
Cause:
Although DPI staff completed FFATA reporting for other grant programs DPI administers, DPI staff did not identify that FFATA reporting requirements applied to CNC. As a result, DPI did not have policies or procedures to collect the required subaward information for CNC programs from DPI’s computer system. Therefore, this information was not reported in FSRS.
As a result of our inquires, DPI staff discussed the requirements with the U.S. Department of Agriculture to understand how to collect the subaward information required to be reported in FSRS for the CNC programs.
Recommendation:
We recommend the Wisconsin Department of Public Instruction:
-develop written policies and procedures for identifying when Federal Funding Accountability and Transparency Act (FFATA) reporting requirements are applicable to a federal award it administers;
-develop written policies and procedures for timely identification and reporting of Child Nutrition Cluster program subawards of $30,000 or more, including any amendments or modifications to a subaward, to the FFATA Subaward Reporting System; and
-complete monthly FFATA reporting for the Child Nutrition Cluster programs following the established policies and procedures.
Finding 2024-400: Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting
Child Nutrition Cluster (Assistance Listing numbers 10.553, 10.555, 10.556, 10.559, and 10.582)
Award Numbers Award Years
212WI063N1099 2021
212WI063N1199 2021
212WI063N8903 2021
222WI063N1099 2022
222WI063N1199 2022
222WI063N8903 2022
232WI063N1099 2023
232WI063N1199 2023
232WI063L1603 2023
242WI063N1099 2024
242WI063N1199 2024
242WI063N8903 2024
242WI063L1603 2024
Questioned Costs: None
COVID-19—National School Lunch Program (Assistance Listing number 10.555)
Award Number Award Year
232WI063N8903 2023
Questioned Costs: None
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the reporting compliance requirement.
Response from the Wisconsin Department of Public Instruction: The Wisconsin Department of Public Instruction agrees with the audit finding and recommendations.
Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting
Background:
The U.S. Department of Agriculture provides funding to DPI through the programs of CNC. The purpose of these programs is to:
-assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential child care institutions, and summer programs;
-foster healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary schools; and
-encourage the domestic consumption of nutritious agricultural commodities.
DPI subawards CNC funding to schools and other entities to execute the programs.
Under the Federal Funding Accountability and Transparency Act (FFATA), a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
Criteria:
Under 2 CFR s. 170, DPI is required to report in the FFATA Subaward Reporting System (FSRS) subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the subaward was made. For example, if the subaward was made on November 7, 2023, it must be reported in FSRS not later than December 31, 2023. CNC subawards of $30,000 or more are subject to FFATA reporting.
Condition:
Although DPI made subawards of $30,000 or more in CNC funding to schools and other entities in FY 2023-24, DPI did not report any CNC subawards in FSRS during FY 2023-24.
Context:
Of the $361.0 million expended during FY 2023-24 under CNC, DPI disbursed $342.4 million to schools and other entities. We interviewed DPI staff to gain an understanding of the procedures for compiling information for CNC subawards and submitting the information in FSRS.
Questioned Costs:
None.
Effect:
The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov for CNC. DPI did not comply with FFATA requirements for the timely reporting of subawards in FSRS for CNC.
Cause:
Although DPI staff completed FFATA reporting for other grant programs DPI administers, DPI staff did not identify that FFATA reporting requirements applied to CNC. As a result, DPI did not have policies or procedures to collect the required subaward information for CNC programs from DPI’s computer system. Therefore, this information was not reported in FSRS.
As a result of our inquires, DPI staff discussed the requirements with the U.S. Department of Agriculture to understand how to collect the subaward information required to be reported in FSRS for the CNC programs.
Recommendation:
We recommend the Wisconsin Department of Public Instruction:
-develop written policies and procedures for identifying when Federal Funding Accountability and Transparency Act (FFATA) reporting requirements are applicable to a federal award it administers;
-develop written policies and procedures for timely identification and reporting of Child Nutrition Cluster program subawards of $30,000 or more, including any amendments or modifications to a subaward, to the FFATA Subaward Reporting System; and
-complete monthly FFATA reporting for the Child Nutrition Cluster programs following the established policies and procedures.
Finding 2024-400: Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting
Child Nutrition Cluster (Assistance Listing numbers 10.553, 10.555, 10.556, 10.559, and 10.582)
Award Numbers Award Years
212WI063N1099 2021
212WI063N1199 2021
212WI063N8903 2021
222WI063N1099 2022
222WI063N1199 2022
222WI063N8903 2022
232WI063N1099 2023
232WI063N1199 2023
232WI063L1603 2023
242WI063N1099 2024
242WI063N1199 2024
242WI063N8903 2024
242WI063L1603 2024
Questioned Costs: None
COVID-19—National School Lunch Program (Assistance Listing number 10.555)
Award Number Award Year
232WI063N8903 2023
Questioned Costs: None
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the reporting compliance requirement.
Response from the Wisconsin Department of Public Instruction: The Wisconsin Department of Public Instruction agrees with the audit finding and recommendations.
Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting
Background:
The U.S. Department of Agriculture provides funding to DPI through the programs of CNC. The purpose of these programs is to:
-assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential child care institutions, and summer programs;
-foster healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary schools; and
-encourage the domestic consumption of nutritious agricultural commodities.
DPI subawards CNC funding to schools and other entities to execute the programs.
Under the Federal Funding Accountability and Transparency Act (FFATA), a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
Criteria:
Under 2 CFR s. 170, DPI is required to report in the FFATA Subaward Reporting System (FSRS) subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the subaward was made. For example, if the subaward was made on November 7, 2023, it must be reported in FSRS not later than December 31, 2023. CNC subawards of $30,000 or more are subject to FFATA reporting.
Condition:
Although DPI made subawards of $30,000 or more in CNC funding to schools and other entities in FY 2023-24, DPI did not report any CNC subawards in FSRS during FY 2023-24.
Context:
Of the $361.0 million expended during FY 2023-24 under CNC, DPI disbursed $342.4 million to schools and other entities. We interviewed DPI staff to gain an understanding of the procedures for compiling information for CNC subawards and submitting the information in FSRS.
Questioned Costs:
None.
Effect:
The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov for CNC. DPI did not comply with FFATA requirements for the timely reporting of subawards in FSRS for CNC.
Cause:
Although DPI staff completed FFATA reporting for other grant programs DPI administers, DPI staff did not identify that FFATA reporting requirements applied to CNC. As a result, DPI did not have policies or procedures to collect the required subaward information for CNC programs from DPI’s computer system. Therefore, this information was not reported in FSRS.
As a result of our inquires, DPI staff discussed the requirements with the U.S. Department of Agriculture to understand how to collect the subaward information required to be reported in FSRS for the CNC programs.
Recommendation:
We recommend the Wisconsin Department of Public Instruction:
-develop written policies and procedures for identifying when Federal Funding Accountability and Transparency Act (FFATA) reporting requirements are applicable to a federal award it administers;
-develop written policies and procedures for timely identification and reporting of Child Nutrition Cluster program subawards of $30,000 or more, including any amendments or modifications to a subaward, to the FFATA Subaward Reporting System; and
-complete monthly FFATA reporting for the Child Nutrition Cluster programs following the established policies and procedures.
Finding 2024-400: Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting
Child Nutrition Cluster (Assistance Listing numbers 10.553, 10.555, 10.556, 10.559, and 10.582)
Award Numbers Award Years
212WI063N1099 2021
212WI063N1199 2021
212WI063N8903 2021
222WI063N1099 2022
222WI063N1199 2022
222WI063N8903 2022
232WI063N1099 2023
232WI063N1199 2023
232WI063L1603 2023
242WI063N1099 2024
242WI063N1199 2024
242WI063N8903 2024
242WI063L1603 2024
Questioned Costs: None
COVID-19—National School Lunch Program (Assistance Listing number 10.555)
Award Number Award Year
232WI063N8903 2023
Questioned Costs: None
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the reporting compliance requirement.
Response from the Wisconsin Department of Public Instruction: The Wisconsin Department of Public Instruction agrees with the audit finding and recommendations.
Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting
Background:
The U.S. Department of Agriculture provides funding to DPI through the programs of CNC. The purpose of these programs is to:
-assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential child care institutions, and summer programs;
-foster healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary schools; and
-encourage the domestic consumption of nutritious agricultural commodities.
DPI subawards CNC funding to schools and other entities to execute the programs.
Under the Federal Funding Accountability and Transparency Act (FFATA), a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
Criteria:
Under 2 CFR s. 170, DPI is required to report in the FFATA Subaward Reporting System (FSRS) subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the subaward was made. For example, if the subaward was made on November 7, 2023, it must be reported in FSRS not later than December 31, 2023. CNC subawards of $30,000 or more are subject to FFATA reporting.
Condition:
Although DPI made subawards of $30,000 or more in CNC funding to schools and other entities in FY 2023-24, DPI did not report any CNC subawards in FSRS during FY 2023-24.
Context:
Of the $361.0 million expended during FY 2023-24 under CNC, DPI disbursed $342.4 million to schools and other entities. We interviewed DPI staff to gain an understanding of the procedures for compiling information for CNC subawards and submitting the information in FSRS.
Questioned Costs:
None.
Effect:
The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov for CNC. DPI did not comply with FFATA requirements for the timely reporting of subawards in FSRS for CNC.
Cause:
Although DPI staff completed FFATA reporting for other grant programs DPI administers, DPI staff did not identify that FFATA reporting requirements applied to CNC. As a result, DPI did not have policies or procedures to collect the required subaward information for CNC programs from DPI’s computer system. Therefore, this information was not reported in FSRS.
As a result of our inquires, DPI staff discussed the requirements with the U.S. Department of Agriculture to understand how to collect the subaward information required to be reported in FSRS for the CNC programs.
Recommendation:
We recommend the Wisconsin Department of Public Instruction:
-develop written policies and procedures for identifying when Federal Funding Accountability and Transparency Act (FFATA) reporting requirements are applicable to a federal award it administers;
-develop written policies and procedures for timely identification and reporting of Child Nutrition Cluster program subawards of $30,000 or more, including any amendments or modifications to a subaward, to the FFATA Subaward Reporting System; and
-complete monthly FFATA reporting for the Child Nutrition Cluster programs following the established policies and procedures.
Finding 2024-400: Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting
Child Nutrition Cluster (Assistance Listing numbers 10.553, 10.555, 10.556, 10.559, and 10.582)
Award Numbers Award Years
212WI063N1099 2021
212WI063N1199 2021
212WI063N8903 2021
222WI063N1099 2022
222WI063N1199 2022
222WI063N8903 2022
232WI063N1099 2023
232WI063N1199 2023
232WI063L1603 2023
242WI063N1099 2024
242WI063N1199 2024
242WI063N8903 2024
242WI063L1603 2024
Questioned Costs: None
COVID-19—National School Lunch Program (Assistance Listing number 10.555)
Award Number Award Year
232WI063N8903 2023
Questioned Costs: None
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the reporting compliance requirement.
Response from the Wisconsin Department of Public Instruction: The Wisconsin Department of Public Instruction agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Supplemental Nutrition Assistance Program—Subrecipient Monitoring
Background:
The USDA provides funding to DHS for the Supplemental Nutrition Assistance Program (SNAP) Cluster, which provides funding for SNAP benefits (Assistance Listing number 10.551). These SNAP benefits assist low-income households to buy the food needed for good health. The SNAP Cluster also provides funding for the State Administrative Matching Grants for SNAP (Assistance Listing number 10.561), which is used to pay administrative costs related to the provision and oversight of benefits. To administer the SNAP program, DHS contracts with ten multi-county income maintenance consortia, which are made up of county staff. These income maintenance consortia are responsible for a variety of administrative tasks, including program enrollment and caseload management, and are required to meet certain performance measures specified in the contract. DHS uses GEARS to process the reimbursement requests for these consortia, which are considered subrecipients.
Criteria:
DHS administers federal programs that are subject to Uniform Guidance. Uniform Guidance includes the following requirements related to the monitoring of subrecipients:
-2 CFR s. 200.332 (b) requires DHS to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring; and
-2 CFR s. 200.332 (d) through (f) requires DHS to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
DHS established policies requiring grant administrators to conduct a risk assessment for every subaward of federal funds and to use the risk assessment to determine the frequency and extent of monitoring. DHS policies include a subrecipient risk assessment template to assist grant administrators in completing the risk assessment and determining the risk level of the subrecipient. DHS policies also require grant administrators to monitor subrecipients based on the risk assessments. DHS policies indicate that monitoring may include providing subrecipient training and technical assistance; performing desk reviews of the subrecipient’s records; and performing on-site reviews of the subrecipient’s records and operations.
Condition:
We found DHS did not perform the required risk assessments for the income maintenance consortia in FY 2020-21, FY 2021-22, FY 2022-23, and FY 2023-24. In addition, DHS did not define the level of monitoring to be performed based on the completed risk assessments. For example, there was no documentation to indicate the level monitoring required for low-, moderate-, and high-risk subrecipients, including the reliance that could be placed on the review of subrecipient single audit reports and whether additional fiscal monitoring such as a review of financial information to assess the allowability of reimbursement requests would be needed.
DHS did perform monitoring procedures for each income maintenance consortia related to the contractual performance measures, including standards for timely processing of applications. DHS also performed annual management evaluations related to specific topics.
Context:
DHS expended $105.7 million in federal funds to administer the SNAP program during FY 2023-24, including $61.3 million that was provided to subrecipients, of which $37.5 million was provided to the income maintenance consortia agencies for program administration. We interviewed DHS staff to gain an understanding of DHS policies and procedures for processing reimbursement requests from subrecipients and its policies and procedures for monitoring subrecipients to ensure the subaward was used for authorized purposes, complied with the terms and conditions of the subaward, and achieved performance goals.
Questioned Costs:
None.
Effect:
Because its subrecipient monitoring procedures were insufficient, and because DHS did not perform any required risk assessments in the last four fiscal years, DHS is at increased risk of noncompliance with federal regulations for the SNAP program. Further, there is an increased risk of improper payments for the SNAP program.
Cause:
DHS did not complete the required risk assessments or develop and document a plan related to the monitoring necessary for each level of subrecipient risk. Although DHS performed certain monitoring related to contractual performance measures, these procedures were not part of a documented monitoring plan and there was no assessment of additional procedures that could have been determined necessary based upon the risk assessments.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-complete risk assessments for each income maintenance consortia receiving administrative funding under the Supplemental Nutrition Assistance Program;
-develop and document a written monitoring plan that includes a description of the monitoring expected for low-, moderate-, and high-risk subrecipients to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals;
-specify in the written monitoring plan how existing monitoring procedures are incorporated into the plan and assess what additional monitoring procedures may be needed; and
-implement the written monitoring plan and maintain documentation related to the monitoring performed.
Finding 2024-308: Supplemental Nutrition Assistance Program—Subrecipient Monitoring
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting
Background:
The U.S. Department of Agriculture provides funding to DPI through the programs of CNC. The purpose of these programs is to:
-assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential child care institutions, and summer programs;
-foster healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary schools; and
-encourage the domestic consumption of nutritious agricultural commodities.
DPI subawards CNC funding to schools and other entities to execute the programs.
Under the Federal Funding Accountability and Transparency Act (FFATA), a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
Criteria:
Under 2 CFR s. 170, DPI is required to report in the FFATA Subaward Reporting System (FSRS) subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the subaward was made. For example, if the subaward was made on November 7, 2023, it must be reported in FSRS not later than December 31, 2023. CNC subawards of $30,000 or more are subject to FFATA reporting.
Condition:
Although DPI made subawards of $30,000 or more in CNC funding to schools and other entities in FY 2023-24, DPI did not report any CNC subawards in FSRS during FY 2023-24.
Context:
Of the $361.0 million expended during FY 2023-24 under CNC, DPI disbursed $342.4 million to schools and other entities. We interviewed DPI staff to gain an understanding of the procedures for compiling information for CNC subawards and submitting the information in FSRS.
Questioned Costs:
None.
Effect:
The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov for CNC. DPI did not comply with FFATA requirements for the timely reporting of subawards in FSRS for CNC.
Cause:
Although DPI staff completed FFATA reporting for other grant programs DPI administers, DPI staff did not identify that FFATA reporting requirements applied to CNC. As a result, DPI did not have policies or procedures to collect the required subaward information for CNC programs from DPI’s computer system. Therefore, this information was not reported in FSRS.
As a result of our inquires, DPI staff discussed the requirements with the U.S. Department of Agriculture to understand how to collect the subaward information required to be reported in FSRS for the CNC programs.
Recommendation:
We recommend the Wisconsin Department of Public Instruction:
-develop written policies and procedures for identifying when Federal Funding Accountability and Transparency Act (FFATA) reporting requirements are applicable to a federal award it administers;
-develop written policies and procedures for timely identification and reporting of Child Nutrition Cluster program subawards of $30,000 or more, including any amendments or modifications to a subaward, to the FFATA Subaward Reporting System; and
-complete monthly FFATA reporting for the Child Nutrition Cluster programs following the established policies and procedures.
Finding 2024-400: Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting
Child Nutrition Cluster (Assistance Listing numbers 10.553, 10.555, 10.556, 10.559, and 10.582)
Award Numbers Award Years
212WI063N1099 2021
212WI063N1199 2021
212WI063N8903 2021
222WI063N1099 2022
222WI063N1199 2022
222WI063N8903 2022
232WI063N1099 2023
232WI063N1199 2023
232WI063L1603 2023
242WI063N1099 2024
242WI063N1199 2024
242WI063N8903 2024
242WI063L1603 2024
Questioned Costs: None
COVID-19—National School Lunch Program (Assistance Listing number 10.555)
Award Number Award Year
232WI063N8903 2023
Questioned Costs: None
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the reporting compliance requirement.
Response from the Wisconsin Department of Public Instruction: The Wisconsin Department of Public Instruction agrees with the audit finding and recommendations.
Summer Electronic Benefit Transfer Program for Children—Cash Management
Background:
The U.S. Department of Agriculture (USDA) provides funding to DHS for the Summer Electronic Benefit Transfer Program for Children (Summer EBT) (Assistance Listing number 10.646). This program provides food benefits during the summer months to families with children who were determined eligible for free or reduced-price school meals in the prior school year or during the summer.
This program was authorized under the Consolidated Appropriations Act of 2023, which was enacted in December 2022. DHS received approval for its Summer EBT program on March 22, 2024, and received an initial grant award on April 9, 2024. The program began operations in summer 2024. Under the program, participants received benefits of $120 for each eligible child. These benefits were issued on EBT cards that participants used to purchase food at approved retailers.
Criteria:
The Summer EBT program is subject to the requirements of 31 CFR Part 205, Subpart B, including that the State must minimize the time between the drawdown of federal funds from the federal government and the disbursement for federal program purposes. Further, the regulations state that the timing and amount of funds transferred must be as close as is administratively feasible to a state’s actual cash outlay for direct program costs. DOA, which processes federal reimbursement requests for most state agencies, has defined administratively feasible as receiving federal funds within five days of the recording of expenditures.
The USDA issued guidance defined the federal share of expenditures as disbursements for direct charges related to Summer EBT benefits. This guidance further defined the federal share of unliquidated obligations as the value of benefits that have been issued to participants, but for which no cash disbursements have been made. Based upon this guidance, expenditures or disbursements under the Summer EBT program are incurred when participants have used the issued benefits to purchase food at an approved retailer.
Summer EBT is also subject to 2 CFR Part 200, Subpart E, which provides requirements for determination of allowable costs to be charged to a federal award, including that the costs be necessary, reasonable, and adequately documented.
Condition:
DHS established the Summer EBT program through STAR, the State’s accounting system, to allow for the drawdown of federal funds once expenditures were recorded in the accounting system. On June 18, 2024, DHS recorded an expenditure in the Summer EBT program for $58.3 million that resulted in the drawdown of $58.3 million in federal Summer EBT funds. In reviewing the expenditure transaction, we found that DHS
did not base the $58.3 million transaction on actual expenditures for Summer EBT benefits. Rather, the expenditure transaction was comprised of $50.9 million in benefits that were approved to be issued on participants’ EBT cards on June 22, 2024, and $7.2 million related to benefits that were expected to be issued at a future date after certain information was received to issue benefits. Because the expenditure was not based on participants’ food purchases, federal funds were drawn in advance of program expenditures.
DHS established a separate bank account to allow for the settlement of participants’ food purchases with the retailers. On June 21, 2024, a deposit of $58.3 million was made to this account. As of June 30, 2024, $23.2 million in benefits were used by participants on food purchases, which were settled or credited to this account. A balance of $35.1 million remained in the account on June 30, 2024. In addition, the account earned interest totaling $60,212 for June 2024.
Context:
We reviewed FY 2023-24 DHS transactions recorded in June 2024 and identified a $58.3 million expenditure transaction that was coded to a new federal program: Summer EBT. We followed up with DHS on the transaction to discuss its purpose and the requirements of this program. We reviewed supporting documentation provided, including bank account statements, and reviewed the federal program requirements.
Questioned Costs:
We question at least $35,050,325, which was the balance of the federal funds drawn and not spent by participants as of June 30, 2024.
Effect:
DHS recorded program expenditures that were not supported, DHS received federal funds in advance of program expenditures for Summer EBT, and DHS did not minimize the time between the drawdown of federal funds from the federal government and the disbursement for federal program purposes, resulting in noncompliance with allowable cost and federal cash management requirements. In addition, the federal reports DHS prepared and submitted for the program inaccurately reported program expenditures based on what had been recorded in STAR, the State’s accounting system, and not the actual program expenditures.
Cause:
DHS indicated the process of drawing federal funds through STAR, the State’s accounting systemy, did not provide for the receipt of federal funds that would allow for daily settlement of participants’ food purchases. As a result, DHS developed a process that would provide sufficient cash-on-hand. However, in doing so, DHS recorded expenditures prior to participants’ food purchases, and DHS did not properly consider federal cash management requirements under which the State must minimize the time between the recording of the expenditure and the drawdown of federal funds.
Recommendation:
We recommend the Wisconsin Department of Health Services review its procedures and make updates that will:
-ensure recorded expenditures are supported by program expenditures; and
-minimize the time between the recording of expenditures and the drawdown of federal funds.
Finding 2024-301: Summer Electronic Benefit Transfer Program for Children—Cash Management
Summer Electronic Benefit Transfer Program for Children
(Assistance Listing number 10.646)
Award Number Award Year
202424N117542 2024
Questioned Costs: $35,050,325
Type of Finding: Material Weakness, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Rebuttal from the Wisconsin Legislative Audit Bureau: In its corrective action plan on page 345, the Department of Health Services agreed with the cash management concerns reported by the Bureau, but stated it did not consider the questioned costs to be inappropriate federal spending. In addition, the Department of Health Services noted that it completed a reconciliation of funds received to funds spent for children in this program and returned the unspent balance to the federal government in September 2024.
However, a questioned cost is defined by 2 CFR s. 200.1 as an amount expended or received from a federal award, that in the auditor’s judgment:
-is noncompliant or suspected noncompliant with federal statutes, regulations, or the terms and conditions of the federal award;
-lacked adequate documentation to support compliance; or
-appeared unreasonable and did not reflect the actions a prudent person would take in the circumstances.
As reported in the finding, United States Department of Agriculture guidance indicates that expenditures or disbursements under the Summer Electronic Benefit Transfer Program for Children are incurred when participants have used the issued benefits to purchase food. The amount questioned was the balance of the federal funds drawn and not spent by participants as of June 30, 2024. This amount met the criteria of a questioned cost due to noncompliance with federal regulations and a lack of adequate documentation to support compliance. In addition, the return of $14.2 million to the federal government in September 2024 further indicates that the amounts drawn in June 2024 were not supported.
Homeowner Assistance Fund—Service Organization Internal Controls
Background:
Under the American Rescue Plan Act (ARPA) of 2021, the U.S. Department of the Treasury (U.S. Treasury) provided funding to DOA’s Division of Energy, Housing and Community Resources (DEHCR) for the HAF program. This program was established to mitigate financial hardships associated with the public health emergency, including for the purpose of preventing homeowner mortgage delinquencies, defaults, foreclosures, losses of utilities or home energy services, and displacements of homeowners experiencing financial hardship after January 21, 2020.
To administer the HAF program, DOA contracted with a service organization to host and maintain a computer system to assist in determining the eligibility of individuals applying for HAF benefits, approving these benefits, storing information on HAF applicants, and for reporting HAF activities to the federal government.
During our FY 2022-23 single audit (report 24-3), we identified concerns that DOA did not have sufficient procedures in place to obtain the service organization audit report from its service organization for HAF nor to use the service organization audit report as a tool to assess the effectiveness of the internal controls for the computer system maintained by the service organization. We recommended that DOA obtain the service organization audit report for the computer system used to administer the HAF program and complete a review of this report, assess the effectiveness of the internal controls for the computer system maintained by the service organization, and review the complementary user entity controls at DOA that are required to be in place for it to rely on the service organization audit report. In addition, DOA was to document its review, and to implement user entity controls if needed (Finding 2023-101).
In its response to our recommendations, and as noted in the Summary Schedule of Prior Audit Findings, DOA requested and received the service organization audit report. In addition, DOA developed procedures to:
-review the service organization audit report;
-assess of the effectiveness of the internal controls on the computer system maintained by the service organization; and
-review the complementary user entity controls that are required to be in place for it to rely on the service organization audit report, and to implement user entity controls if needed.
DOA indicated it had completed in June 2024 a preliminary review of the service organization audit report, including the opinion, testing exceptions, and complementary user-entity controls, but DOA had not completed its assessment of the effectiveness of the internal controls on the computer system maintained by the service organization nor documented its review.
Criteria:
Under 2 CFR s. 200.303, DOA is responsible for establishing and maintaining effective internal control over federal awards to provide reasonable assurance that federal awards are managed in compliance with federal statutes, regulations, and the award terms and conditions. This includes instances in which management contracts with a service organization, which is an organization that provides services to another entity and whose services are relevant to the entity’s internal controls.
When using a service organization, the entity should gain assurances that the internal controls at the service organization are operating effectively because weaknesses in the service organization’s internal controls could affect the activity of the entity. Such assurances could be gained through a service organization audit, which includes a report on the service organization’s internal controls by an independent auditor. One type of audit that may be completed includes an opinion on the fairness of management’s description of the internal controls in place at the service organization, whether the auditor believes the service organization’s internal controls are suitably designed to achieve the internal control objectives, and whether the service organization’s internal controls are effective at achieving the internal control objectives. In addition, an entity relying on a service organization audit report should review the complementary user entity controls referenced in the report and ensure these controls or others are in place at the entity.
If an entity relying on a service organization does not obtain a service organization audit report, the entity should ensure it has assessed the work being completed by the service organization, and it has implemented procedures to ensure both the accuracy of processing completed by the service organization and the information provided by the service organization.
Condition:
In May 2024, DOA requested and received the April 2024 service organization audit report that covered the period from September 1, 2023, to February 29, 2024. We found that DOA developed procedures to review the service organization audit report, assess the effectiveness of the internal controls on the computer system maintained by the service organization, and assess the complementary user entity controls. However, DOA did not complete its review and assessment of the April 2024 service organization audit report during FY 2023-24.
Context:
During FY 2023-24, DOA expended $30.9 million in HAF funding. DOA reported that $27.8 million, or 89.9 percent of the expenditures, was for benefit payments to various entities such as mortgage and utility companies on behalf of individuals who had their eligibility determinations processed by the computer system maintained by DOA’s service organization. We reviewed and discussed with DEHCR its procedures for determining eligibility for HAF participants, including its reliance on the computer system maintained by the service organization.
Questioned Costs:
None.
Effect:
DOA and the federal government cannot be assured that the service organization controls are effective in determining eligibility or completing federal reporting for HAF.
Cause:
Although DOA developed procedures to obtain and review the service organization audit report for HAF, it did not complete its review and assessment of the service organization audit report until October 2024.
Recommendation:
We recommend the Wisconsin Department of Administration implement its new policies and procedures to review and assess the service organization audit report for the Homeowner Assistance Fund to establish and maintain effective internal control over federal awards.
Finding 2024-100: Homeowner Assistance Fund—Service Organization Internal Controls
COVID-19—Homeowner Assistance Fund (Assistance Listing number 21.026)
Award Number Award Year
None 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendation.
Coronavirus State and Local Fiscal Recovery Funds—Suspension and Debarment Requirements
Background:
The State was advanced a total of $3.0 billion under the CSLFRF program in FY 2020-21 and FY 2021-22, from the U.S. Department of the Treasury (U.S. Treasury). CSLFRF was created under the American Rescue Plan Act (ARPA), and later revised by the Consolidated Appropriations Act, 2023. CSLFRF is administered by DOA.
DOA expended funding under CSLFRF for various programs that it established. In addition, DOA entered into a memorandum of understanding (MOU) with various state agencies to administer several different programs funded by CSLFRF. In June 2022, DOA entered into an MOU with UW System Administration called the Mental Health Initiative, with the goal of making mental health resources available to students by contracting with providers, providing training to enhance the capacity of university staff to deliver mental health programming, and providing grants to UW institutions to develop mental health programs. In addition, in April 2024 UW System Administration’s Office of Business and Entrepreneurship entered into a subgrant agreement with WEDC to administer technical assistance to grantees of WEDC’s Main Street Bounceback Program using CSLFRF funding.
Criteria:
2 CFR s. 200.214 prohibits recipients of federal funding from entering into contracts with suspended or debarred parties. Further, 2 CFR s. 180.300 requires recipients of federal funding to ensure they do not enter into a contract with a suspended or debarred party by completing one of the following steps:
-reviewing the suspended and debarred parties listing on SAM.gov;
-collecting a certification from the party that they are not suspended or debarred; or
-including a clause or condition regarding suspension and debarment in the procurement contract.
Condition:
We found that UW System Administration entered into contracts with vendors to administer the Mental Health Initiative and the subgrant with WEDC. UW System Administration did not complete or document that it completed any of the required steps to ensure the parties were not suspended or debarred.
Context:
The MOU with DOA provided UW System Administration $5.0 million in CSLFRF funding for the Mental Health Initiative and, in FY 2023-24, UW System Administration expended $1.7 million. We inquired of UW System Administration staff regarding procedures for ensuring UW System Administration does not enter into a contract with a suspended or debarred party. We also reviewed payments made to vendors and reviewed contracts for two vendors, and reviewed the suspended and debarred parties listing on SAM.gov. We found one of the vendors was registered on SAM.gov and was not on the suspended and debarred parties listing. However, the other vendor was not registered on SAM.gov, so we could not determine the suspension and debarment status of this vendor.
The subgrant from WEDC provided UW System Administration $5.0 million in CSLFRF funding, of which UW System Administration expended $666,000 in FY 2023-24. We inquired of staff in UW System Administration’s Office of Business and Entrepreneurship regarding its procedures for ensuring it does not enter into a contract with a suspended or debarred party. We also reviewed payments made to vendors and reviewed contracts for two vendors, and reviewed the suspended and debarred parties listing on SAM.gov. We found the vendors for the WEDC subgrant were not registered on SAM.gov, so we could not determine the suspension and debarment status of these vendors.
Questioned Costs:
None.
Effect:
UW System Administration is at increased risk of entering into a contract with a suspended or debarred party, and is in noncompliance with federal requirements.
Cause:
UW System Administration staff administering the Mental Health Initiative were unaware of the suspension and debarment requirements, and UW System Administration did not have procedures in place to meet the federal requirements. UW System Administration staff indicated that responsibility for and debarment requirements was transitioned to UW-Madison, Research and Sponsored Programs in FY 2024-25.
Staff in UW System Administration’s Office of Business and Entrepreneurship who administer the WEDC subgrant noted that they review SAM.gov, as well as other types of vendor checks but did not maintain documentation of the review.
Recommendation:
We recommend the University of Wisconsin System Administration implement procedures to ensure the suspension and debarment requirements are met and documentation is maintained to demonstrate the requirements were met.
Finding 2024-714: Coronavirus State and Local Fiscal Recovery Funds—Suspension and Debarment Requirements
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Numbers Award Years
None 2021
Subgrant KSP FY 24-53693 2024
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendation.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
Background:
The State was advanced a total of $3.0 billion under the CSLFRF program in FY 2020-21 and FY 2021-22, from the U.S. Department of the Treasury (U.S. Treasury). CSLFRF was created under the American Rescue Plan Act (ARPA), and later revised by the Consolidated Appropriations Act, 2023. CSLFRF is administered by DOA. CSLFRF funding has certain eligible uses, including those in an eligible use category for the provision of government services to the extent revenue losses due to the public health emergency reduced revenues. CSLFRF recipients calculated lost revenues for the years 2020, 2021, 2022, and 2023 based on a formula in the 2022 Treasury final rule to determine the amount of CSLFRF funds that may be used for the provision of government services in the eligible use category.
DOA expended funding under CSLFRF for various programs that it established. In addition, DOA entered into a memorandum of understanding (MOU) with
various state agencies to administer several different programs funded by CSLFRF. In June 2022, DOA entered into an MOU with DHS related to COVID-19 vaccination distribution.
Criteria:
Under the 2022 Treasury final rule, U.S. Treasury determined that CSLFRF funding available for the provision of government services may be used to meet the non-federal match requirements of other federal programs. Further, CSLFRF funding available under other eligible use categories may not be used to meet the non-federal match requirements of other programs, unless specifically allowed by statute.
Condition:
DHS used CSLFRF funding to meet its match requirement for the Disaster Grants - Public Assistance (Presidentially Declared Disasters) (Public Assistance) (Assistance Listing number 97.036). DHS recorded a transaction of $862,677 to its COVID-19 vaccination distribution program in January 2024, and counted this transaction as part of meeting its non-federal match requirement under the Public Assistance grant. The COVID-19 vaccination distribution program is reported under the U.S. Treasury eligible use category related to responding to the public health emergency and its negative impacts. Under this eligible use category, DHS is not allowed to use CSLFRF funding as non-federal match for another federal program.
Context:
During FY 2023-24, DHS expended $39.0 million in CSLFRF funding. We interviewed DHS staff to gain an understanding of DHS’s administration of the CSLFRF funding, including how it assessed using CSLFRF funding to meet its non-federal match for other federal programs. We reviewed general ledger transactions made by DHS for the CSLFRF grant, identified the DHS transaction, and followed up with DHS regarding the purpose of the transaction. DHS is responsible for ensuring costs charged to federal grant programs meet the federal requirements.
Questioned Costs:
$862,677
Effect:
DHS is in noncompliance with federal requirements for allowable uses of CSLFRF funding and DHS did not meet its non-federal match requirements for the Public Assistance grant, because DHS used CSLFRF funding to meet the non-federal match requirement.
Cause:
DHS staff indicated they were not aware of the eligible use category for its COVID-19 vaccination distribution project funded by CSLFRF. Further, the MOU between DOA and DHS did not include information to allow DHS to understand what the eligible use category was or the restrictions related to the use of the funds to meet non-federal match for other federal grants. DOA did provide DHS with information regarding the eligible use category through quarterly reporting requirements to the U.S. Treasury. Further, DOA and DHS staff indicated regular discussions occurred between the two agencies regarding the CSLFRF funding.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-take steps to further its understanding of the Coronavirus State and Local Fiscal Recovery Funds grant it is administering to ensure it administers the grant in compliance with all federal rules; and
-review the non-federal match requirements for the Public Assistance grant and ensure it has met the non-federal match requirements.
Finding 2024-304: Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: $862,677
Type of Finding: Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services disagrees with the audit finding and recommendations.
Rebuttal from the Wisconsin Legislative Audit Bureau: In its corrective action plan on page 351, the Department of Health Services (DHS) indicated that it disagrees with the unallowable costs identified in this finding and noted that the costs are allowable in accordance with its memorandum of understanding with the Department of Administration and the 2022 Treasury final rule. As stated in the finding, DHS used $862,677 in expenditures under its COVID-19 vaccination distribution program as match for the Public Assistance grant. The 2022 Treasury final rule and the U.S. Department of the Treasury (U.S. Treasury) frequently asked questions related to the Coronavirus State Local and Fiscal Recovery Funds (CSLFRF) grant indicate that only funding under the revenue loss eligible use category may be used to meet non-federal match for another federal program. Therefore, using the expenditures for the COVID-19 vaccination distribution program as the non-federal match for the Public Assistance grant is not allowable.
DHS indicated that “given the nature of these expenditures, they would not have been unallowable, except for their misclassification on the federal report.” We note that the COVID-19 vaccination distribution program has been reported under the public health eligible use category since its inception. Therefore, no misclassification occurred on the federal report.
DHS noted that its position is supported by the fact that no accounting entries were needed to resolve the eligible use category for the purpose of federal reporting.
As we have stated, this issue relates to the unallowable use of CSLFRF funding as non-federal match for another federal program. This is not a federal reporting issue.
We note that subsequent to our questions regarding the use of these funds for non-federal match, the State created a new U.S. Treasury project called COVID-19 Vaccination Non-Federal Match with a budget of $862,677 and reported the project under the revenue loss eligible use category in its report filed for the quarter ended December 31, 2024. Although the State chose to address the finding in this manner, it does not change the fact that DHS was non-compliant with the matching requirements of the CSLFRF grant when it used the funding from the COVID-19 vaccination distribution program as non-federal match for another federal program.
Coronavirus State and Local Fiscal Recovery Funds—Suspension and Debarment Requirements
Background:
The State was advanced a total of $3.0 billion under the CSLFRF program in FY 2020-21 and FY 2021-22, from the U.S. Department of the Treasury (U.S. Treasury). CSLFRF was created under the American Rescue Plan Act (ARPA), and later revised by the Consolidated Appropriations Act, 2023. CSLFRF is administered by DOA.
DOA expended funding under CSLFRF for various programs that it established. In addition, DOA entered into a memorandum of understanding (MOU) with various state agencies to administer several different programs funded by CSLFRF. In January 2022, DOA entered into an MOU with Tourism called the Tourism Marketing Initiative. The goal of the initiative related to implementing marketing and communications initiatives to support the travel, hospitality, and adjacent industries to recover from the public health emergency.
Criteria:
2 CFR s. 200.214 prohibits recipients of federal funding from entering into contracts with suspended or debarred parties. Further, 2 CFR s. 180.300 requires recipients of federal funding to ensure they do not enter into a contract with a suspended or debarred party by completing one of the following steps:
-reviewing the suspended and debarred parties listing on SAM.gov;
-collecting a certification from the party that they are not suspended or debarred; or
-including a clause or condition regarding suspension and debarment in the procurement contract.
Condition:
Although Tourism entered into contracts with vendors to administer the Tourism Marketing Initiative, we found that Tourism completed none of the required steps to ensure the parties were not suspended or debarred.
Context:
The MOU with DOA provided Tourism $7.5 million in CSLFRF funding for the Tourism Marketing Initiative. Tourism expended $972,295 for the initiative in FY 2023-24. We inquired of Tourism staff regarding the agency’s procedures for ensuring it does not enter into a contract with a suspended or debarred party. We also reviewed payments made to vendors and reviewed contracts for five vendors, two of which were entered into during FY 2023-24 and two of which were amended during FY 2023-24.
Questioned Costs:
None.
Effect:
Tourism is at increased risk of entering into a contract with a suspended or debarred party and is in noncompliance with federal requirements.
Cause:
Tourism does not administer significant federal funding. Tourism staff indicated they were unaware of the suspension and debarment requirements and had not developed procedures sufficient and appropriate to meet the federal requirements.
Recommendation:
We recommend the Wisconsin Department of Tourism establish procedures to ensure it does not contract with suspended or debarred parties and complies fully with all applicable federal requirements for funds it administers.
Finding 2024-903: Coronavirus State and Local Fiscal Recovery Funds—Suspension and Debarment Requirements
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Tourism: The Wisconsin Department of Tourism agrees with the audit finding and recommendation.
Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
Background:
The State was advanced a total of $3.0 billion under the CSLFRF program in FY 2020-21 and FY 2021-22, from the U.S. Department of the Treasury (U.S. Treasury). CSLFRF was created under the American Rescue Plan Act (ARPA), and later revised by the Consolidated Appropriations Act, 2023. CSLFRF is administered by DOA.
DOA expended funding under CSLFRF for various programs that it established. In addition, DOA entered into a memorandum of understanding (MOU) with various state agencies to administer several different programs funded by CSLFRF. In January 2022, DOA entered into an MOU with SPD to provide assistance to SPD to hire staff to fill project positions to address its case backlog. Through position requests to DOA in 2021, 2022, and 2023, SPD received approval to create 65.0 two-year project positions to be funded by the CSLFRF grant.
Criteria:
Under 2 CFR s. 200.303, SPD is responsible for establishing and maintaining effective internal control over federal awards to provide reasonable assurance that federal awards are managed in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, SPD is required to follow U.S. Treasury guidance that requires it to maintain documentation to demonstrate that CSLFRF funding was used in accordance with federal regulations.
Condition:
We reviewed payroll records to determine whether employee time charged to the CSLFRF grant was approved by an appropriate supervisor with knowledge of the employee’s work effort. We reviewed the approvals for a selection of 15 project employees at SPD funded by the CSLFRF grant and found that time was approved by an appropriate supervisor for all but one of the employees. We found that the time for one employee was not approved in STAR HCM, the State’s payroll system. Certain amounts charged to the grant for this employee were unallowable to be charged to the grant. This employee was appointed to one of the project positions funded by the CSLFRF grant under the MOU with DOA. This employee left state service on October 6 2023, and was appointed to the project position beginning on October 9, 2023. The employee ended employment with SPD on November 17, 2023. During the three pay periods between October 9, 2023, and November 17, 2023, the employee recorded 3 days of work time and 27 days of leave. Further, on November 30, 2023, the employee was paid $86,605 for accumulated unused leave earned in their previous position.
Context:
During FY 2023-24, SPD expended $5.6 million in CSLFRF funding. We interviewed SPD staff to gain an understanding of SPD’s administration of the CSLFRF funding, including how it charged payroll costs to the CSLFRF grant. We reviewed payroll transactions made by SPD for the CSLFRF program, identified the payout for a terminated employee, and followed up with SPD regarding the purpose of the transaction.
Questioned Costs:
$107,164, which consists of $86,605 in payment for unused leave and $20,559 in leave taken during the three-week period the employee worked in the project position.
Effect:
SPD charged payroll costs to the CSLFRF grant that did not relate to the underlying project positions established in the MOU with DOA.
Cause:
SPD staff indicated that charging the CSLFRF grant for the costs related to the unused leave for the employee was an oversight. According to SPD staff, the former employee made a decision to terminate from the project position and the unused leave was inadvertently charged to the grant. SPD staff did not explain why the 27 days of leave was charged to the grant during the months of October and November of 2023, or why the employee’s time was not approved in STAR.
Recommendation:
We recommend the Wisconsin State Public Defender’s Office:
-review and update its procedures to ensure employee timesheets are appropriately approved by a supervisor with knowledge of each employee’s work effort;
-review and update its procedures to ensure costs are charged to the correct accounting codes and funding sources are appropriately used;
-take steps to ensure it administers the funding for the Coronavirus State and Local Fiscal Recovery Funds grant in compliance with the memorandum of understanding with the Department of Administration and with federal rules; and
-adjust its accounting records to use a different funding source for the leave and termination payments for unused leave for the employee identified during the audit.
Finding 2024-902: Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: $107,164
Type of Finding: Noncompliance
Response from the Wisconsin State Public Defender’s Office: The Wisconsin State Public Defender’s Office agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Coronavirus State and Local Fiscal Recovery Funds—Suspension and Debarment Requirements
Background:
The State was advanced a total of $3.0 billion under the CSLFRF program in FY 2020-21 and FY 2021-22, from the U.S. Department of the Treasury (U.S. Treasury). CSLFRF was created under the American Rescue Plan Act (ARPA), and later revised by the Consolidated Appropriations Act, 2023. CSLFRF is administered by DOA.
DOA expended funding under CSLFRF for various programs that it established. In addition, DOA entered into a memorandum of understanding (MOU) with various state agencies to administer several different programs funded by CSLFRF. In June 2022, DOA entered into an MOU with UW System Administration called the Mental Health Initiative, with the goal of making mental health resources available to students by contracting with providers, providing training to enhance the capacity of university staff to deliver mental health programming, and providing grants to UW institutions to develop mental health programs. In addition, in April 2024 UW System Administration’s Office of Business and Entrepreneurship entered into a subgrant agreement with WEDC to administer technical assistance to grantees of WEDC’s Main Street Bounceback Program using CSLFRF funding.
Criteria:
2 CFR s. 200.214 prohibits recipients of federal funding from entering into contracts with suspended or debarred parties. Further, 2 CFR s. 180.300 requires recipients of federal funding to ensure they do not enter into a contract with a suspended or debarred party by completing one of the following steps:
-reviewing the suspended and debarred parties listing on SAM.gov;
-collecting a certification from the party that they are not suspended or debarred; or
-including a clause or condition regarding suspension and debarment in the procurement contract.
Condition:
We found that UW System Administration entered into contracts with vendors to administer the Mental Health Initiative and the subgrant with WEDC. UW System Administration did not complete or document that it completed any of the required steps to ensure the parties were not suspended or debarred.
Context:
The MOU with DOA provided UW System Administration $5.0 million in CSLFRF funding for the Mental Health Initiative and, in FY 2023-24, UW System Administration expended $1.7 million. We inquired of UW System Administration staff regarding procedures for ensuring UW System Administration does not enter into a contract with a suspended or debarred party. We also reviewed payments made to vendors and reviewed contracts for two vendors, and reviewed the suspended and debarred parties listing on SAM.gov. We found one of the vendors was registered on SAM.gov and was not on the suspended and debarred parties listing. However, the other vendor was not registered on SAM.gov, so we could not determine the suspension and debarment status of this vendor.
The subgrant from WEDC provided UW System Administration $5.0 million in CSLFRF funding, of which UW System Administration expended $666,000 in FY 2023-24. We inquired of staff in UW System Administration’s Office of Business and Entrepreneurship regarding its procedures for ensuring it does not enter into a contract with a suspended or debarred party. We also reviewed payments made to vendors and reviewed contracts for two vendors, and reviewed the suspended and debarred parties listing on SAM.gov. We found the vendors for the WEDC subgrant were not registered on SAM.gov, so we could not determine the suspension and debarment status of these vendors.
Questioned Costs:
None.
Effect:
UW System Administration is at increased risk of entering into a contract with a suspended or debarred party, and is in noncompliance with federal requirements.
Cause:
UW System Administration staff administering the Mental Health Initiative were unaware of the suspension and debarment requirements, and UW System Administration did not have procedures in place to meet the federal requirements. UW System Administration staff indicated that responsibility for and debarment requirements was transitioned to UW-Madison, Research and Sponsored Programs in FY 2024-25.
Staff in UW System Administration’s Office of Business and Entrepreneurship who administer the WEDC subgrant noted that they review SAM.gov, as well as other types of vendor checks but did not maintain documentation of the review.
Recommendation:
We recommend the University of Wisconsin System Administration implement procedures to ensure the suspension and debarment requirements are met and documentation is maintained to demonstrate the requirements were met.
Finding 2024-714: Coronavirus State and Local Fiscal Recovery Funds—Suspension and Debarment Requirements
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Numbers Award Years
None 2021
Subgrant KSP FY 24-53693 2024
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendation.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Coronavirus State and Local Fiscal Recovery Funds—Suspension and Debarment Requirements
Background:
The State was advanced a total of $3.0 billion under the CSLFRF program in FY 2020-21 and FY 2021-22, from the U.S. Treasury. CSLFRF was created under ARPA, and later revised by the Consolidated Appropriations Act, 2023. CSLFRF is administered by DOA. DOA expended funding under CSLFRF for various programs that it established. In addition, DOA entered into an MOU with various state agencies to administer several different programs funded by CSLFRF. DOA entered into an MOU with DWD called the Workforce Innovation Grant (WIG) Program, which allowed DWD to provide grant funding to governments, nonprofit organizations, and tribal governments to design and innovate plans for addressing workforce challenges caused by the public health emergency. In April 2024, DWD entered into an agreement with UW-Eau Claire to administer a grant under the WIG Program.
Criteria:
2 CFR s. 200.214 prohibits recipients of federal funding from entering into contracts with suspended or debarred parties. Further, 2 CFR s. 180.300 requires recipients of federal funding to ensure they do not enter into a contract with a suspended or debarred party by completing one of the following steps:
-reviewing the suspended and debarred parties listing on SAM.gov;
-collecting a certification from the party that they are not suspended or debarred; or
-including a clause or condition regarding suspension and debarment in the procurement contract.
Condition:
We found that UW-Eau Claire entered into contracts with vendors to administer its WIG Program and, for some contracts, it did not complete or document that it completed any of the required steps to ensure the parties were not suspended or debarred.
Context:
The agreement with DWD provides UW-Eau Claire $9.4 million in CSLFRF funding for its WIG Program. We inquired of UW-Eau Claire staff regarding its procedures for ensuring it does not enter into a contract with a suspended or debarred party. We also reviewed payments made to vendors. For two of the seven vendor contracts we reviewed, we found that UW-Eau Claire did not perform procedures related to suspension and debarment. We found both vendors were registered on SAM.gov and were not on the suspended and debarred parties listing.
Questioned Costs:
None.
Effect:
UW-Eau Claire is at increased risk of entering into a contract with a suspended or debarred party, and is in noncompliance with federal requirements.
Cause:
UW-Eau Claire staff administering the grant indicated that it was not identified during the procurement process that these two contracts related to federal funding and, therefore, that a review of each vendor’s suspension and debarment status was needed.
Recommendation:
We recommend the University of Wisconsin-Eau Claire implement procedures to ensure the suspension and debarment requirements are met and documentation is maintained to support that the requirements are met.
Finding 2024-715: Coronavirus State and Local Fiscal Recovery Funds—Suspension and Debarment Requirements
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Eau Claire: The University of Wisconsin-Eau Claire agrees with the audit finding and recommendation.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Coronavirus State and Local Fiscal Recovery Funds—Suspension and Debarment Requirements
Background:
The State was advanced a total of $3.0 billion under the CSLFRF program in FY 2020-21 and FY 2021-22, from the U.S. Department of the Treasury (U.S. Treasury). CSLFRF was created under the American Rescue Plan Act (ARPA), and later revised by the Consolidated Appropriations Act, 2023. CSLFRF is administered by DOA.
DOA expended funding under CSLFRF for various programs that it established. In addition, DOA entered into a memorandum of understanding (MOU) with various state agencies to administer several different programs funded by CSLFRF. In June 2022, DOA entered into an MOU with UW System Administration called the Mental Health Initiative, with the goal of making mental health resources available to students by contracting with providers, providing training to enhance the capacity of university staff to deliver mental health programming, and providing grants to UW institutions to develop mental health programs. In addition, in April 2024 UW System Administration’s Office of Business and Entrepreneurship entered into a subgrant agreement with WEDC to administer technical assistance to grantees of WEDC’s Main Street Bounceback Program using CSLFRF funding.
Criteria:
2 CFR s. 200.214 prohibits recipients of federal funding from entering into contracts with suspended or debarred parties. Further, 2 CFR s. 180.300 requires recipients of federal funding to ensure they do not enter into a contract with a suspended or debarred party by completing one of the following steps:
-reviewing the suspended and debarred parties listing on SAM.gov;
-collecting a certification from the party that they are not suspended or debarred; or
-including a clause or condition regarding suspension and debarment in the procurement contract.
Condition:
We found that UW System Administration entered into contracts with vendors to administer the Mental Health Initiative and the subgrant with WEDC. UW System Administration did not complete or document that it completed any of the required steps to ensure the parties were not suspended or debarred.
Context:
The MOU with DOA provided UW System Administration $5.0 million in CSLFRF funding for the Mental Health Initiative and, in FY 2023-24, UW System Administration expended $1.7 million. We inquired of UW System Administration staff regarding procedures for ensuring UW System Administration does not enter into a contract with a suspended or debarred party. We also reviewed payments made to vendors and reviewed contracts for two vendors, and reviewed the suspended and debarred parties listing on SAM.gov. We found one of the vendors was registered on SAM.gov and was not on the suspended and debarred parties listing. However, the other vendor was not registered on SAM.gov, so we could not determine the suspension and debarment status of this vendor.
The subgrant from WEDC provided UW System Administration $5.0 million in CSLFRF funding, of which UW System Administration expended $666,000 in FY 2023-24. We inquired of staff in UW System Administration’s Office of Business and Entrepreneurship regarding its procedures for ensuring it does not enter into a contract with a suspended or debarred party. We also reviewed payments made to vendors and reviewed contracts for two vendors, and reviewed the suspended and debarred parties listing on SAM.gov. We found the vendors for the WEDC subgrant were not registered on SAM.gov, so we could not determine the suspension and debarment status of these vendors.
Questioned Costs:
None.
Effect:
UW System Administration is at increased risk of entering into a contract with a suspended or debarred party, and is in noncompliance with federal requirements.
Cause:
UW System Administration staff administering the Mental Health Initiative were unaware of the suspension and debarment requirements, and UW System Administration did not have procedures in place to meet the federal requirements. UW System Administration staff indicated that responsibility for and debarment requirements was transitioned to UW-Madison, Research and Sponsored Programs in FY 2024-25.
Staff in UW System Administration’s Office of Business and Entrepreneurship who administer the WEDC subgrant noted that they review SAM.gov, as well as other types of vendor checks but did not maintain documentation of the review.
Recommendation:
We recommend the University of Wisconsin System Administration implement procedures to ensure the suspension and debarment requirements are met and documentation is maintained to demonstrate the requirements were met.
Finding 2024-714: Coronavirus State and Local Fiscal Recovery Funds—Suspension and Debarment Requirements
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Numbers Award Years
None 2021
Subgrant KSP FY 24-53693 2024
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendation.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
Background:
The State was advanced a total of $3.0 billion under the CSLFRF program in FY 2020-21 and FY 2021-22, from the U.S. Department of the Treasury (U.S. Treasury). CSLFRF was created under the American Rescue Plan Act (ARPA), and later revised by the Consolidated Appropriations Act, 2023. CSLFRF is administered by DOA. CSLFRF funding has certain eligible uses, including those in an eligible use category for the provision of government services to the extent revenue losses due to the public health emergency reduced revenues. CSLFRF recipients calculated lost revenues for the years 2020, 2021, 2022, and 2023 based on a formula in the 2022 Treasury final rule to determine the amount of CSLFRF funds that may be used for the provision of government services in the eligible use category.
DOA expended funding under CSLFRF for various programs that it established. In addition, DOA entered into a memorandum of understanding (MOU) with
various state agencies to administer several different programs funded by CSLFRF. In June 2022, DOA entered into an MOU with DHS related to COVID-19 vaccination distribution.
Criteria:
Under the 2022 Treasury final rule, U.S. Treasury determined that CSLFRF funding available for the provision of government services may be used to meet the non-federal match requirements of other federal programs. Further, CSLFRF funding available under other eligible use categories may not be used to meet the non-federal match requirements of other programs, unless specifically allowed by statute.
Condition:
DHS used CSLFRF funding to meet its match requirement for the Disaster Grants - Public Assistance (Presidentially Declared Disasters) (Public Assistance) (Assistance Listing number 97.036). DHS recorded a transaction of $862,677 to its COVID-19 vaccination distribution program in January 2024, and counted this transaction as part of meeting its non-federal match requirement under the Public Assistance grant. The COVID-19 vaccination distribution program is reported under the U.S. Treasury eligible use category related to responding to the public health emergency and its negative impacts. Under this eligible use category, DHS is not allowed to use CSLFRF funding as non-federal match for another federal program.
Context:
During FY 2023-24, DHS expended $39.0 million in CSLFRF funding. We interviewed DHS staff to gain an understanding of DHS’s administration of the CSLFRF funding, including how it assessed using CSLFRF funding to meet its non-federal match for other federal programs. We reviewed general ledger transactions made by DHS for the CSLFRF grant, identified the DHS transaction, and followed up with DHS regarding the purpose of the transaction. DHS is responsible for ensuring costs charged to federal grant programs meet the federal requirements.
Questioned Costs:
$862,677
Effect:
DHS is in noncompliance with federal requirements for allowable uses of CSLFRF funding and DHS did not meet its non-federal match requirements for the Public Assistance grant, because DHS used CSLFRF funding to meet the non-federal match requirement.
Cause:
DHS staff indicated they were not aware of the eligible use category for its COVID-19 vaccination distribution project funded by CSLFRF. Further, the MOU between DOA and DHS did not include information to allow DHS to understand what the eligible use category was or the restrictions related to the use of the funds to meet non-federal match for other federal grants. DOA did provide DHS with information regarding the eligible use category through quarterly reporting requirements to the U.S. Treasury. Further, DOA and DHS staff indicated regular discussions occurred between the two agencies regarding the CSLFRF funding.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-take steps to further its understanding of the Coronavirus State and Local Fiscal Recovery Funds grant it is administering to ensure it administers the grant in compliance with all federal rules; and
-review the non-federal match requirements for the Public Assistance grant and ensure it has met the non-federal match requirements.
Finding 2024-304: Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: $862,677
Type of Finding: Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services disagrees with the audit finding and recommendations.
Rebuttal from the Wisconsin Legislative Audit Bureau: In its corrective action plan on page 351, the Department of Health Services (DHS) indicated that it disagrees with the unallowable costs identified in this finding and noted that the costs are allowable in accordance with its memorandum of understanding with the Department of Administration and the 2022 Treasury final rule. As stated in the finding, DHS used $862,677 in expenditures under its COVID-19 vaccination distribution program as match for the Public Assistance grant. The 2022 Treasury final rule and the U.S. Department of the Treasury (U.S. Treasury) frequently asked questions related to the Coronavirus State Local and Fiscal Recovery Funds (CSLFRF) grant indicate that only funding under the revenue loss eligible use category may be used to meet non-federal match for another federal program. Therefore, using the expenditures for the COVID-19 vaccination distribution program as the non-federal match for the Public Assistance grant is not allowable.
DHS indicated that “given the nature of these expenditures, they would not have been unallowable, except for their misclassification on the federal report.” We note that the COVID-19 vaccination distribution program has been reported under the public health eligible use category since its inception. Therefore, no misclassification occurred on the federal report.
DHS noted that its position is supported by the fact that no accounting entries were needed to resolve the eligible use category for the purpose of federal reporting.
As we have stated, this issue relates to the unallowable use of CSLFRF funding as non-federal match for another federal program. This is not a federal reporting issue.
We note that subsequent to our questions regarding the use of these funds for non-federal match, the State created a new U.S. Treasury project called COVID-19 Vaccination Non-Federal Match with a budget of $862,677 and reported the project under the revenue loss eligible use category in its report filed for the quarter ended December 31, 2024. Although the State chose to address the finding in this manner, it does not change the fact that DHS was non-compliant with the matching requirements of the CSLFRF grant when it used the funding from the COVID-19 vaccination distribution program as non-federal match for another federal program.
Coronavirus State and Local Fiscal Recovery Funds—Suspension and Debarment Requirements
Background:
The State was advanced a total of $3.0 billion under the CSLFRF program in FY 2020-21 and FY 2021-22, from the U.S. Department of the Treasury (U.S. Treasury). CSLFRF was created under the American Rescue Plan Act (ARPA), and later revised by the Consolidated Appropriations Act, 2023. CSLFRF is administered by DOA.
DOA expended funding under CSLFRF for various programs that it established. In addition, DOA entered into a memorandum of understanding (MOU) with various state agencies to administer several different programs funded by CSLFRF. In January 2022, DOA entered into an MOU with Tourism called the Tourism Marketing Initiative. The goal of the initiative related to implementing marketing and communications initiatives to support the travel, hospitality, and adjacent industries to recover from the public health emergency.
Criteria:
2 CFR s. 200.214 prohibits recipients of federal funding from entering into contracts with suspended or debarred parties. Further, 2 CFR s. 180.300 requires recipients of federal funding to ensure they do not enter into a contract with a suspended or debarred party by completing one of the following steps:
-reviewing the suspended and debarred parties listing on SAM.gov;
-collecting a certification from the party that they are not suspended or debarred; or
-including a clause or condition regarding suspension and debarment in the procurement contract.
Condition:
Although Tourism entered into contracts with vendors to administer the Tourism Marketing Initiative, we found that Tourism completed none of the required steps to ensure the parties were not suspended or debarred.
Context:
The MOU with DOA provided Tourism $7.5 million in CSLFRF funding for the Tourism Marketing Initiative. Tourism expended $972,295 for the initiative in FY 2023-24. We inquired of Tourism staff regarding the agency’s procedures for ensuring it does not enter into a contract with a suspended or debarred party. We also reviewed payments made to vendors and reviewed contracts for five vendors, two of which were entered into during FY 2023-24 and two of which were amended during FY 2023-24.
Questioned Costs:
None.
Effect:
Tourism is at increased risk of entering into a contract with a suspended or debarred party and is in noncompliance with federal requirements.
Cause:
Tourism does not administer significant federal funding. Tourism staff indicated they were unaware of the suspension and debarment requirements and had not developed procedures sufficient and appropriate to meet the federal requirements.
Recommendation:
We recommend the Wisconsin Department of Tourism establish procedures to ensure it does not contract with suspended or debarred parties and complies fully with all applicable federal requirements for funds it administers.
Finding 2024-903: Coronavirus State and Local Fiscal Recovery Funds—Suspension and Debarment Requirements
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Tourism: The Wisconsin Department of Tourism agrees with the audit finding and recommendation.
Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
Background:
The State was advanced a total of $3.0 billion under the CSLFRF program in FY 2020-21 and FY 2021-22, from the U.S. Department of the Treasury (U.S. Treasury). CSLFRF was created under the American Rescue Plan Act (ARPA), and later revised by the Consolidated Appropriations Act, 2023. CSLFRF is administered by DOA.
DOA expended funding under CSLFRF for various programs that it established. In addition, DOA entered into a memorandum of understanding (MOU) with various state agencies to administer several different programs funded by CSLFRF. In January 2022, DOA entered into an MOU with SPD to provide assistance to SPD to hire staff to fill project positions to address its case backlog. Through position requests to DOA in 2021, 2022, and 2023, SPD received approval to create 65.0 two-year project positions to be funded by the CSLFRF grant.
Criteria:
Under 2 CFR s. 200.303, SPD is responsible for establishing and maintaining effective internal control over federal awards to provide reasonable assurance that federal awards are managed in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, SPD is required to follow U.S. Treasury guidance that requires it to maintain documentation to demonstrate that CSLFRF funding was used in accordance with federal regulations.
Condition:
We reviewed payroll records to determine whether employee time charged to the CSLFRF grant was approved by an appropriate supervisor with knowledge of the employee’s work effort. We reviewed the approvals for a selection of 15 project employees at SPD funded by the CSLFRF grant and found that time was approved by an appropriate supervisor for all but one of the employees. We found that the time for one employee was not approved in STAR HCM, the State’s payroll system. Certain amounts charged to the grant for this employee were unallowable to be charged to the grant. This employee was appointed to one of the project positions funded by the CSLFRF grant under the MOU with DOA. This employee left state service on October 6 2023, and was appointed to the project position beginning on October 9, 2023. The employee ended employment with SPD on November 17, 2023. During the three pay periods between October 9, 2023, and November 17, 2023, the employee recorded 3 days of work time and 27 days of leave. Further, on November 30, 2023, the employee was paid $86,605 for accumulated unused leave earned in their previous position.
Context:
During FY 2023-24, SPD expended $5.6 million in CSLFRF funding. We interviewed SPD staff to gain an understanding of SPD’s administration of the CSLFRF funding, including how it charged payroll costs to the CSLFRF grant. We reviewed payroll transactions made by SPD for the CSLFRF program, identified the payout for a terminated employee, and followed up with SPD regarding the purpose of the transaction.
Questioned Costs:
$107,164, which consists of $86,605 in payment for unused leave and $20,559 in leave taken during the three-week period the employee worked in the project position.
Effect:
SPD charged payroll costs to the CSLFRF grant that did not relate to the underlying project positions established in the MOU with DOA.
Cause:
SPD staff indicated that charging the CSLFRF grant for the costs related to the unused leave for the employee was an oversight. According to SPD staff, the former employee made a decision to terminate from the project position and the unused leave was inadvertently charged to the grant. SPD staff did not explain why the 27 days of leave was charged to the grant during the months of October and November of 2023, or why the employee’s time was not approved in STAR.
Recommendation:
We recommend the Wisconsin State Public Defender’s Office:
-review and update its procedures to ensure employee timesheets are appropriately approved by a supervisor with knowledge of each employee’s work effort;
-review and update its procedures to ensure costs are charged to the correct accounting codes and funding sources are appropriately used;
-take steps to ensure it administers the funding for the Coronavirus State and Local Fiscal Recovery Funds grant in compliance with the memorandum of understanding with the Department of Administration and with federal rules; and
-adjust its accounting records to use a different funding source for the leave and termination payments for unused leave for the employee identified during the audit.
Finding 2024-902: Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: $107,164
Type of Finding: Noncompliance
Response from the Wisconsin State Public Defender’s Office: The Wisconsin State Public Defender’s Office agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to Federal Funding Accountability and Transparency Act (FFATA) reporting for certain grant programs administered by the State. During FY 2023-24, DOA’s Division of Executive Budget and Finance was responsible for uploading required FFATA information into the FFATA Subaward Reporting System (FSRS) based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DOA also provided guidance and technical assistance to agencies on FFATA reporting requirements.
During our FY 2022-23 single audit (report 24-3), we identified concerns that DOA’s method of reporting modifications to subawards in FSRS resulted in an overstatement of the subaward information in FSRS and on USAspending.gov. In report 24-3, we recommended that DOA alter its approach and report only the amount of subaward modifications, update guidance to agencies, and provide training to state agencies on appropriate reporting (Finding 2023-106). We also recommended that DOA maintain its current approach of reporting cumulative amounts with subaward modifications only if it received specific guidance from the Office of Management and Budget (OMB) that its current reporting was appropriate. DOA agreed with our recommendations. Further, in January 2025 the U.S. Department of Health and Human Services sustained the audit finding and recommended that DOA revise and resubmit any reports that contained inaccurate data.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance on FSRS.gov indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Further, guidance posted on the U.S. General Services Administration (GSA) website in spring 2024 provided clarification that when a subaward is modified, the preparer should update the original entry in FSRS. The guidance also indicated that if information for a subaward changes, the preparer is to update the original report in FSRS.
Condition:
In response to our prior year recommendation, DOA contacted OMB for clarification on the FFATA reporting requirements. OMB’s response indicated that DOA should “use the total amount after adjusted,” in reporting subaward modifications in FSRS. DOA interpreted this guidance to mean it would continue its established process for reporting subaward modifications by reporting the cumulative amount of the subaward, not just the modification, in FSRS. Therefore, DOA did not alter its reporting of subaward modifications in FSRS for FY 2023-24. For example, in reviewing subaward information on USAspending.gov for a subaward related to the Temporary Assistance for Needy Families grant (Assistance Listing number 93.558), we found that the total subaward was overstated on USAspending.gov because DOA reported cumulative amounts for each modification.
Context:
DOA staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including the departments of Children and Families and Natural Resources. We discussed DOA’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov, and the updated guidance on the GSA website. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2023-24 for which FFATA reporting was subject to audit and for which DOA was responsible for FFATA reporting. We also followed up on the status of the prior year audit finding and the steps DOA took to address the finding.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USAspending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
In our prior audit, DOA indicated that it relied on guidance from an OMB official who indicated that cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. In our current audit, DOA relied on its March 2024 inquiries of OMB subsequent to our recommendations in March 2024, which DOA interpreted as a requirement to continue its current procedures.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report subaward modifications as an adjustment to the original subaward record in the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission in FSRS; and
-provide training to state agencies to ensure consistent reporting across state agencies.
Finding 2024-101: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02393 2018
00E02349 2018
00E02456 2019
00E02824 2020
00E03252 2022
00E03490 2023
Questioned Costs: None
Temporary Assistance for Needy Families (Assistance Listing number 93.558)
Award Number Award Year
2301WITANF 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Geographic Programs - Great Lakes Restoration Initiative—Federal Financial Reporting
Background:
The DNR receives federal funding from the U.S. Environmental Protection Agency (EPA) for the GLRI program. The objective of the GLRI program is to advance protection and restoration of the Great Lakes Basin Ecosystem through the funding of various projects.
Criteria:
Under 2 CFR s. 200.328, and at least annually, DNR must submit the Federal Financial Report (FFR) to the EPA for each project of the GLRI program. DNR is required to submit annual FFRs no later than 90 calendar days after the project’s reporting period and final FFRs no later than 120 calendar days after the conclusion of the project’s period of performance. The EPA may grant extension of reporting due dates when requested and justified by the recipient.
Condition:
DNR did not submit FFRs in a timely manner for six of the nine annual FFR reports we tested for the GLRI program, and DNR did not request an extension of reporting due dates from the EPA. The six annual FFRs we tested were completed between 17 and 219 calendar days past the due date. For example, four FFRs we tested had a reporting period end date of March 31, 2024, and a report due date of June 29, 2024. DNR filed the annual FFRs on November 1, 2024, which was 125 days past the due date. For five of the six annual FFRs we tested that were late, we noted that DNR submitted the FFRs after our inquiry and request to review the FFRs. For each of the six FFRs, we found that DNR retained documentation to support the amounts included in the reports and the information in the FFRs was accurate.
Context:
During FY 2023-24, DNR expended $15.5 million under the GLRI program. We interviewed DNR staff to gain an understanding of its procedures for preparing FFRs for GLRI projects. During FY 2023-24, DNR was required to submit 20 annual FFRs and 2 final FFRs for GLRI projects to the EPA. We reviewed nine of the annual FFRs and the 2 final FFRs. We requested DNR’s documentation to support the information reported in the FFRs.
Questioned Costs:
None.
Effect:
The EPA did not have timely financial reports to assess DNR’s management of GLRI projects.
Cause:
DNR did not have sufficient procedures in place to track when annual FFRs were required to be submitted for GLRI projects. Although DNR’s procedures require the GLRI program’s grant accountant to monitor FFR due dates, that position was vacant during FY 2023-24 and filled in FY 2024-25. DNR indicated that other grant accountants completed some reporting for the GLRI program, but not all reporting was completed until after we made inquiries of DNR staff in October 2024. DNR staff indicated that they began to implement changes in October 2024 to more effectively track FFR due dates by having DNR’s Management and Grant Accounting Section Chief monitor the FFR reporting schedule.
Recommendation:
We recommend the Wisconsin Department of Natural Resources develop and implement policies and procedures for tracking and submitting timely federal financial reports for the Geographic Programs - Great Lakes Restoration Initiative program.
Finding 2024-800: Geographic Programs - Great Lakes Restoration Initiative—Federal Financial Reporting
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02393 2018
00E02456 2019
00E02487 2019
00E02824 2020
00E02979 2021
00E02975 2021
00E03010 2021
00E03068 2021
03E00712 2022
01E03010 2022
00E03149 2022
00E03187 2022
00E03188 2022
00E03250 2022
00E03252 2022
00E03589 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Natural Resources: The Wisconsin Department of Natural Resources agrees with the audit finding and recommendation.
Geographic Programs - Great Lakes Restoration Initiative—Subrecipient Monitoring
Background:
DNR receives federal funding from the EPA for the GLRI program. The objective of the GLRI program is to advance protection and restoration of the Great Lakes Basin Ecosystem through the funding of various projects. To administer the GLRI program, DNR contracts with subrecipients located around the State, including counties, cities, and sewage districts.
During our FY 2022-23 single audit (report 24-3), we identified that DNR did not perform subrecipient risk assessments or have a plan to monitor subrecipients for the GLRI program based on the risk assessments. Further, DNR did not have sufficient procedures in place to ensure all GLRI subrecipient single audit reports were being obtained and reviewed. We recommended that DNR develop a written monitoring plan for the GLRI program that includes policies and procedures for:
-completing risk assessments for each subrecipient;
-the specific monitoring steps that are required based on the level of subrecipient risk identified in a risk assessment;
-independently identifying and reviewing subrecipient single audit reports, if applicable; and
-maintaining documentation of all subrecipient monitoring activities (Finding 2023-800).
During FY 2023-24, and in response to our recommendations, DNR developed policies and procedures for monitoring and performing risk assessments of the GLRI subrecipients. In addition, DNR developed procedures to ensure GLRI subrecipient single audit reports were being obtained and reviewed. DNR completed its review of these reports in May 2024.
Criteria:
DNR administers federal programs that are subject to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Uniform Guidance includes three requirements related to the monitoring of subrecipients. First, 2 CFR s. 200.332 (a) (1) requires DNR to communicate certain award information to subrecipients at the time of the subaward. Second, 2 CFR s. 200.332 (b) requires DNR to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring. Finally, 2 CFR s. 200.332 (d) through (f) requires DNR to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
An EPA subaward policy further clarifies that the Uniform Guidance provisions are applicable to its grant programs, including a requirement for DNR to establish and follow a system for evaluating the risks of subrecipient noncompliance with laws, regulations, and the terms and conditions of the subaward, as required by 2 CFR ss. 200.332 (b) and (d). This policy also requires DNR to document its evaluations. In addition, EPA’s policy requires that DNR establish and follow a process for deciding whether to impose additional requirements on subrecipients based on the risk assessments.
Condition:
In response to our FY 2023-24 recommendation, in June 2024 DNR developed policies and procedures for monitoring GLRI subrecipients, including procedures for completing a risk assessment for each GLRI subrecipient and ranking each subrecipient based on the risk assessment to determine the level of monitoring needed. However, DNR did not complete risk assessments for any of its GLRI subrecipients during FY 2023-24.
Context:
DNR expended $15.5 million under the GLRI program during FY 2023-24, including $4.0 million that it provided to 21 subrecipients. We interviewed DNR staff to gain an understanding of its procedures for monitoring subrecipients. We reviewed the agreements between DNR and the subrecipients to identify whether DNR had communicated the required award information to them. We also reviewed monitoring activities DNR performed for the GLRI program, including DNR’s process to review subrecipient single audit reports and DNR’s monitoring of subrecipients through progress reporting and reimbursement requests. Finally, we reviewed and discussed with DNR staff the new procedures for completing subrecipient risk assessments.
Questioned Costs:
None.
Effect:
Because DNR did not comply with all subrecipient monitoring compliance requirements for the GLRI program, there is a higher risk that DNR and its GLRI subrecipients are not in compliance with all federal requirements.
Cause:
Although DNR developed policies and procedures for monitoring and performing risk assessments for the GLRI subrecipients, it did not complete risk assessments for the GLRI subrecipients during FY 2023-24. DNR indicated it would implement its policies and procedures for monitoring and performing risk assessments for the GLRI subrecipients as new subawards are created in FY 2024-25. However, DNR should also perform risk assessments for existing GLRI subrecipients to ensure its monitoring of the activities for ongoing GLRI projects is appropriate.
Recommendation:
We recommend the Wisconsin Department of Natural Resources implement its new monitoring policies and procedures for completing risk assessments for each subrecipient of the Geographic Programs - Great Lakes Restoration Initiative program, including for all its existing subrecipients for ongoing projects.
Finding 2024-801: Geographic Programs - Great Lakes Restoration Initiative—Subrecipient Monitoring
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02393 2018
00E02456 2019
00E02490 2019
00E02824 2020
00E02975 2021
00E02979 2021
00E03010 2021
03E00712 2022
01E03010 2022
00E03149 2022
00E03250 2022
00E03252 2022
00E03490 2023
00E03486 2023
00E03589 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Natural Resources: The Wisconsin Department of Natural Resources agrees with the audit finding and recommendation.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Background:
DHHS provides funding to DHS for SABG, the ELC grant, the Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response, which DHS refers to as the Public Health Emergency Response grant, and the Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises program, which DHS refers to as the Health Disparities grant. These grants have various health-related purposes. To fulfill the purpose of each grant, DHS subawards funds to various entities, including counties, tribal governments, and other nonprofit organizations. In addition, under the SABG grant, amounts are provided by DHS to DCF and the University of Wisconsin-Madison (UW-Madison), which further subgrant to various entities.
Under FFATA, a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
In our FY 2022-23 audit (report 24-3), we identified that DHS had not accurately reported information in FSRS for several grants. We recommended DHS improve its procedures to accurately report required award information in a timely manner, including the date the subaward agreement was signed, and develop procedures to identify and report subawards made by state agencies to which it had transferred federal funding (Finding 2023-304).
Criteria:
Under 2 CFR s. 170, and as the prime grant awardee for these grants, DHS has overall responsibility for FFATA reporting and is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2023, it must be reported no later than January 31, 2024. The information required to be reported in FSRS includes several key data elements such as information about the recipient, the amount of the award, the project description, and the date the subaward agreement was signed.
Condition:
We selected a total of 34 subawards made by DHS under these grants during FY 2023-24 for testing, and we identified that 28 of the 34 subawards were not reported in a timely manner. We found that 14 of the 20 SABG subawards were not reported in a timely manner. For example, under the SABG grant, ten subawards were reported in August 2024, which was between seven to ten months after the date of the subaward.
In addition, we identified the obligation date was not accurate to within 10 days of the date the subaward agreement was signed for two subawards made under the SABG grant. We also found that none of the ELC, Public Health Emergency Response, and Health Disparities subawards we tested were reported in a timely manner. In addition, we found the project description was not completed accurately for ten subawards, including three for SABG subawards, two for ELC subawards, two for Public Health Emergency Response subawards, and three for Health Disparities subawards. Finally, we found that DHS did not report in FSRS any of the seven subawards DCF made under the SABG grant. DHS also did not report in FSRS the one subaward UW-Madison made under the SABG grant.
Context:
During FY 2023-24, DHS expended:
-$35.1 million under the SABG grant, of which $31.1 million was provided to subrecipients;
-$46.9 million under the ELC grant, of which $9.1 million was provided to subrecipients;
-$14.7 million under the Public Health Emergency Response grant, of which $8.3 million was provided to subrecipients; and
-$7.9 million under the Health Disparities grant, of which $2.6 million was provided to subrecipients.
Under the SABG grant, DCF expended $2.9 million, that was provided to subrecipients. Under the SABG grant, UW-Madison expended $0.2 million that was provided to subrecipients.
We reviewed 20 subawards for the SABG grant, two subawards for the ELC grant, nine for the Public Health Emergency Response grant, and three subawards for the Health Disparities grant that were made by DHS during FY 2023-24. We interviewed DHS staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. To assess if the subawards were reported in an accurate and timely manner, we requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed. We further followed up on the status of our prior audit recommendations.
Questioned Costs:
None.
Effect:
DHS did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS. The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov.
Cause:
In report 24-3, we noted that there were issues with the queries used to obtain information for reporting and procedures did not include obtaining information related to subawards made by other state agencies. During FY 2023-24, queries to retrieve information were established in a new system. However, the procedures in place to review the data produced by the queries and to determine what to report in FSRS were insufficient to ensure accurate and timely reporting. In response to our prior audit finding, DHS reported that it updated its FFATA reporting procedures. However, since the updates were not implemented until late in FY 2023-24, issues continued to be identified in our current audit.
Recommendation:
We recommend the Wisconsin Department of Health Services continue its efforts to implement updated procedures and make future revisions to these procedures for Federal Funding Accountability and Transparency Act reporting to ensure reporting is accurate, complete, and submitted in a timely manner.
Finding 2024-309: Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
COVID-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response (Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response
(Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises
(Assistance Listing number 93.391)
Award Numbers Award Years
1 NH75OT000039-01-00 2021
6 NH75OT000039-01-03 2023
6 NH75OT000039-01-05 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
COVID-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Year
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)—Subrecipient Monitoring
Background:
The U.S. Department of Health and Human Services, Centers for Disease Control and Prevention (CDC) provides funding to DHS under the ELC grant. The ELC grant provides financial support and technical assistance to the State to detect, prevent, respond to, and control emerging infectious diseases.
To administer the award under the ELC grant, DHS contracted with a variety of subrecipients, including local and tribal public health agencies and nonprofit entities. DHS uses GEARS to process the reimbursement requests for the majority of subrecipients.
Criteria:
DHS administers federal programs that are subject to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Uniform Guidance includes the following requirements related to the monitoring of subrecipients:
-2 CFR s. 200.332 (b) requires DHS to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring; and
-2 CFR s. 200.332 (d) through (f) requires DHS to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
DHS established policies requiring grant administrators to conduct a risk assessment for every subaward of federal funds and to use the risk assessment to determine the frequency and extent of monitoring. DHS policies include a subrecipient risk assessment template to assist grant administrators in completing the risk assessment and determining the risk level of the subrecipient.
DHS policies also require grant administrators to monitor subrecipients based on the risk assessments. DHS policies indicate that monitoring may include providing subrecipient training and technical assistance; performing desk reviews of the subrecipient’s records; and performing on-site reviews of the subrecipient’s records and operations. Finally, DHS policies in the Division of Public Health Bureau of Operations Contract Management Manual suggest that when GEARS is used to process reimbursement requests, grant administrators should use enhanced expenditure reporting from subrecipients to ensure expenditures are allowable. These policies note that additional verification may be performed by reviewing subrecipient financial records through a desk review or an on-site visit.
Condition:
DHS did not complete subrecipient risk assessments for two tribal governments that were subrecipients of the ELC grant. In addition, DHS did not define the level of monitoring to be performed based on the completed risk assessments. There was no documentation to indicate the level of monitoring required for low-, moderate-, and high-risk subrecipients, such as when DHS would be required to review subrecipient invoices through a desk review or an on-site visit. Further, DHS did not develop procedures for assessing and documenting desk reviews of subrecipient invoices, for assessing and documenting the reliance that can be placed on review of subrecipient single audit reports, and for documenting management oversight of the monitoring plan.
Context:
DHS expended $46.9 million under the ELC grant during FY 2023-24, including $9.1 million that was provided to subrecipients. Of the $9.1 million provided to subrecipients, $4.8 million was processed through GEARS. In FY 2023-24 DHS provided funding to 73 subrecipients to administer the program, including six tribal governments. We interviewed DHS staff to gain an understanding of DHS policies and procedures for processing reimbursement requests from subrecipients, including its use of GEARS and DHS policies and procedures for monitoring subrecipients.
Questioned Costs:
None.
Effect:
Because its subrecipient monitoring procedures are insufficient, DHS is at increased risk of noncompliance with federal regulations for the ELC grant. There is also an increased risk of improper payments for the ELC grant.
Cause:
DHS staff noted that turnover in staff responsible for completion of risk assessments for tribal public health departments contributed to the risk assessments not being completed.
DHS Division of Public Health established an internal control checklist for subrecipient monitoring in order to help guide staff in completing subrecipient monitoring, including prompts for staff to establish monitoring steps required for low-, moderate-, and high-risk subrecipients. However, this checklist was not implemented until July 2024.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-develop a written monitoring plan for the Epidemiology and Laboratory Capacity for Infectious Diseases grant that includes a description of the subrecipient monitoring expected for low-, moderate-, and high-risk subrecipients; procedures for completing and documenting desk reviews of subrecipient invoices; and procedures for assessing and documenting the reliance that can be placed on review of subrecipient single audit reports;
-provide training on the monitoring plan to staff with responsibilities for subrecipient monitoring activities; and
-develop and implement management oversight procedures to ensure monitoring is being completed and documented.
Finding 2024-305: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)—Subrecipient Monitoring
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing number 93.323)
Award Number Award Years
NU50CK000534 2019-2024
Questioned Costs: None
COVID-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing number 93.323)
Award Number Award Years
NU50CK000534 2019-2024
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Background:
DHHS provides funding to DHS for SABG, the ELC grant, the Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response, which DHS refers to as the Public Health Emergency Response grant, and the Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises program, which DHS refers to as the Health Disparities grant. These grants have various health-related purposes. To fulfill the purpose of each grant, DHS subawards funds to various entities, including counties, tribal governments, and other nonprofit organizations. In addition, under the SABG grant, amounts are provided by DHS to DCF and the University of Wisconsin-Madison (UW-Madison), which further subgrant to various entities.
Under FFATA, a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
In our FY 2022-23 audit (report 24-3), we identified that DHS had not accurately reported information in FSRS for several grants. We recommended DHS improve its procedures to accurately report required award information in a timely manner, including the date the subaward agreement was signed, and develop procedures to identify and report subawards made by state agencies to which it had transferred federal funding (Finding 2023-304).
Criteria:
Under 2 CFR s. 170, and as the prime grant awardee for these grants, DHS has overall responsibility for FFATA reporting and is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2023, it must be reported no later than January 31, 2024. The information required to be reported in FSRS includes several key data elements such as information about the recipient, the amount of the award, the project description, and the date the subaward agreement was signed.
Condition:
We selected a total of 34 subawards made by DHS under these grants during FY 2023-24 for testing, and we identified that 28 of the 34 subawards were not reported in a timely manner. We found that 14 of the 20 SABG subawards were not reported in a timely manner. For example, under the SABG grant, ten subawards were reported in August 2024, which was between seven to ten months after the date of the subaward.
In addition, we identified the obligation date was not accurate to within 10 days of the date the subaward agreement was signed for two subawards made under the SABG grant. We also found that none of the ELC, Public Health Emergency Response, and Health Disparities subawards we tested were reported in a timely manner. In addition, we found the project description was not completed accurately for ten subawards, including three for SABG subawards, two for ELC subawards, two for Public Health Emergency Response subawards, and three for Health Disparities subawards. Finally, we found that DHS did not report in FSRS any of the seven subawards DCF made under the SABG grant. DHS also did not report in FSRS the one subaward UW-Madison made under the SABG grant.
Context:
During FY 2023-24, DHS expended:
-$35.1 million under the SABG grant, of which $31.1 million was provided to subrecipients;
-$46.9 million under the ELC grant, of which $9.1 million was provided to subrecipients;
-$14.7 million under the Public Health Emergency Response grant, of which $8.3 million was provided to subrecipients; and
-$7.9 million under the Health Disparities grant, of which $2.6 million was provided to subrecipients.
Under the SABG grant, DCF expended $2.9 million, that was provided to subrecipients. Under the SABG grant, UW-Madison expended $0.2 million that was provided to subrecipients.
We reviewed 20 subawards for the SABG grant, two subawards for the ELC grant, nine for the Public Health Emergency Response grant, and three subawards for the Health Disparities grant that were made by DHS during FY 2023-24. We interviewed DHS staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. To assess if the subawards were reported in an accurate and timely manner, we requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed. We further followed up on the status of our prior audit recommendations.
Questioned Costs:
None.
Effect:
DHS did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS. The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov.
Cause:
In report 24-3, we noted that there were issues with the queries used to obtain information for reporting and procedures did not include obtaining information related to subawards made by other state agencies. During FY 2023-24, queries to retrieve information were established in a new system. However, the procedures in place to review the data produced by the queries and to determine what to report in FSRS were insufficient to ensure accurate and timely reporting. In response to our prior audit finding, DHS reported that it updated its FFATA reporting procedures. However, since the updates were not implemented until late in FY 2023-24, issues continued to be identified in our current audit.
Recommendation:
We recommend the Wisconsin Department of Health Services continue its efforts to implement updated procedures and make future revisions to these procedures for Federal Funding Accountability and Transparency Act reporting to ensure reporting is accurate, complete, and submitted in a timely manner.
Finding 2024-309: Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
COVID-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response (Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response
(Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises
(Assistance Listing number 93.391)
Award Numbers Award Years
1 NH75OT000039-01-00 2021
6 NH75OT000039-01-03 2023
6 NH75OT000039-01-05 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
COVID-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Year
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)—Subrecipient Monitoring
Background:
The U.S. Department of Health and Human Services, Centers for Disease Control and Prevention (CDC) provides funding to DHS under the ELC grant. The ELC grant provides financial support and technical assistance to the State to detect, prevent, respond to, and control emerging infectious diseases.
To administer the award under the ELC grant, DHS contracted with a variety of subrecipients, including local and tribal public health agencies and nonprofit entities. DHS uses GEARS to process the reimbursement requests for the majority of subrecipients.
Criteria:
DHS administers federal programs that are subject to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Uniform Guidance includes the following requirements related to the monitoring of subrecipients:
-2 CFR s. 200.332 (b) requires DHS to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring; and
-2 CFR s. 200.332 (d) through (f) requires DHS to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
DHS established policies requiring grant administrators to conduct a risk assessment for every subaward of federal funds and to use the risk assessment to determine the frequency and extent of monitoring. DHS policies include a subrecipient risk assessment template to assist grant administrators in completing the risk assessment and determining the risk level of the subrecipient.
DHS policies also require grant administrators to monitor subrecipients based on the risk assessments. DHS policies indicate that monitoring may include providing subrecipient training and technical assistance; performing desk reviews of the subrecipient’s records; and performing on-site reviews of the subrecipient’s records and operations. Finally, DHS policies in the Division of Public Health Bureau of Operations Contract Management Manual suggest that when GEARS is used to process reimbursement requests, grant administrators should use enhanced expenditure reporting from subrecipients to ensure expenditures are allowable. These policies note that additional verification may be performed by reviewing subrecipient financial records through a desk review or an on-site visit.
Condition:
DHS did not complete subrecipient risk assessments for two tribal governments that were subrecipients of the ELC grant. In addition, DHS did not define the level of monitoring to be performed based on the completed risk assessments. There was no documentation to indicate the level of monitoring required for low-, moderate-, and high-risk subrecipients, such as when DHS would be required to review subrecipient invoices through a desk review or an on-site visit. Further, DHS did not develop procedures for assessing and documenting desk reviews of subrecipient invoices, for assessing and documenting the reliance that can be placed on review of subrecipient single audit reports, and for documenting management oversight of the monitoring plan.
Context:
DHS expended $46.9 million under the ELC grant during FY 2023-24, including $9.1 million that was provided to subrecipients. Of the $9.1 million provided to subrecipients, $4.8 million was processed through GEARS. In FY 2023-24 DHS provided funding to 73 subrecipients to administer the program, including six tribal governments. We interviewed DHS staff to gain an understanding of DHS policies and procedures for processing reimbursement requests from subrecipients, including its use of GEARS and DHS policies and procedures for monitoring subrecipients.
Questioned Costs:
None.
Effect:
Because its subrecipient monitoring procedures are insufficient, DHS is at increased risk of noncompliance with federal regulations for the ELC grant. There is also an increased risk of improper payments for the ELC grant.
Cause:
DHS staff noted that turnover in staff responsible for completion of risk assessments for tribal public health departments contributed to the risk assessments not being completed.
DHS Division of Public Health established an internal control checklist for subrecipient monitoring in order to help guide staff in completing subrecipient monitoring, including prompts for staff to establish monitoring steps required for low-, moderate-, and high-risk subrecipients. However, this checklist was not implemented until July 2024.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-develop a written monitoring plan for the Epidemiology and Laboratory Capacity for Infectious Diseases grant that includes a description of the subrecipient monitoring expected for low-, moderate-, and high-risk subrecipients; procedures for completing and documenting desk reviews of subrecipient invoices; and procedures for assessing and documenting the reliance that can be placed on review of subrecipient single audit reports;
-provide training on the monitoring plan to staff with responsibilities for subrecipient monitoring activities; and
-develop and implement management oversight procedures to ensure monitoring is being completed and documented.
Finding 2024-305: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)—Subrecipient Monitoring
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing number 93.323)
Award Number Award Years
NU50CK000534 2019-2024
Questioned Costs: None
COVID-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing number 93.323)
Award Number Award Years
NU50CK000534 2019-2024
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Background:
DHHS provides funding to DHS for SABG, the ELC grant, the Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response, which DHS refers to as the Public Health Emergency Response grant, and the Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises program, which DHS refers to as the Health Disparities grant. These grants have various health-related purposes. To fulfill the purpose of each grant, DHS subawards funds to various entities, including counties, tribal governments, and other nonprofit organizations. In addition, under the SABG grant, amounts are provided by DHS to DCF and the University of Wisconsin-Madison (UW-Madison), which further subgrant to various entities.
Under FFATA, a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
In our FY 2022-23 audit (report 24-3), we identified that DHS had not accurately reported information in FSRS for several grants. We recommended DHS improve its procedures to accurately report required award information in a timely manner, including the date the subaward agreement was signed, and develop procedures to identify and report subawards made by state agencies to which it had transferred federal funding (Finding 2023-304).
Criteria:
Under 2 CFR s. 170, and as the prime grant awardee for these grants, DHS has overall responsibility for FFATA reporting and is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2023, it must be reported no later than January 31, 2024. The information required to be reported in FSRS includes several key data elements such as information about the recipient, the amount of the award, the project description, and the date the subaward agreement was signed.
Condition:
We selected a total of 34 subawards made by DHS under these grants during FY 2023-24 for testing, and we identified that 28 of the 34 subawards were not reported in a timely manner. We found that 14 of the 20 SABG subawards were not reported in a timely manner. For example, under the SABG grant, ten subawards were reported in August 2024, which was between seven to ten months after the date of the subaward.
In addition, we identified the obligation date was not accurate to within 10 days of the date the subaward agreement was signed for two subawards made under the SABG grant. We also found that none of the ELC, Public Health Emergency Response, and Health Disparities subawards we tested were reported in a timely manner. In addition, we found the project description was not completed accurately for ten subawards, including three for SABG subawards, two for ELC subawards, two for Public Health Emergency Response subawards, and three for Health Disparities subawards. Finally, we found that DHS did not report in FSRS any of the seven subawards DCF made under the SABG grant. DHS also did not report in FSRS the one subaward UW-Madison made under the SABG grant.
Context:
During FY 2023-24, DHS expended:
-$35.1 million under the SABG grant, of which $31.1 million was provided to subrecipients;
-$46.9 million under the ELC grant, of which $9.1 million was provided to subrecipients;
-$14.7 million under the Public Health Emergency Response grant, of which $8.3 million was provided to subrecipients; and
-$7.9 million under the Health Disparities grant, of which $2.6 million was provided to subrecipients.
Under the SABG grant, DCF expended $2.9 million, that was provided to subrecipients. Under the SABG grant, UW-Madison expended $0.2 million that was provided to subrecipients.
We reviewed 20 subawards for the SABG grant, two subawards for the ELC grant, nine for the Public Health Emergency Response grant, and three subawards for the Health Disparities grant that were made by DHS during FY 2023-24. We interviewed DHS staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. To assess if the subawards were reported in an accurate and timely manner, we requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed. We further followed up on the status of our prior audit recommendations.
Questioned Costs:
None.
Effect:
DHS did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS. The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov.
Cause:
In report 24-3, we noted that there were issues with the queries used to obtain information for reporting and procedures did not include obtaining information related to subawards made by other state agencies. During FY 2023-24, queries to retrieve information were established in a new system. However, the procedures in place to review the data produced by the queries and to determine what to report in FSRS were insufficient to ensure accurate and timely reporting. In response to our prior audit finding, DHS reported that it updated its FFATA reporting procedures. However, since the updates were not implemented until late in FY 2023-24, issues continued to be identified in our current audit.
Recommendation:
We recommend the Wisconsin Department of Health Services continue its efforts to implement updated procedures and make future revisions to these procedures for Federal Funding Accountability and Transparency Act reporting to ensure reporting is accurate, complete, and submitted in a timely manner.
Finding 2024-309: Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
COVID-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response (Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response
(Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises
(Assistance Listing number 93.391)
Award Numbers Award Years
1 NH75OT000039-01-00 2021
6 NH75OT000039-01-03 2023
6 NH75OT000039-01-05 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
COVID-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Year
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response—Subrecipient Monitoring
Background:
The CDC provides funding to DHS under the Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response grant, which DHS refers to as the Public Health Emergency Response grant. The Public Health Emergency Response grant is intended to provide funding to rapidly respond to public health emergencies as identified by the CDC. DHS received three awards from the CDC to be funded by the Public Health Emergency Response grant: COVID Crisis Response, which ended during FY 2022-23; COVID Public Health Workforce; and Monkey Pox Crisis Response.
Under the COVID Public Health Workforce award, DHS contracted with subrecipients, including local and tribal public health agencies and cooperative educational service agencies (CESAs), to administer the award. DHS uses GEARS to process the reimbursement requests for the local and tribal public health agencies. Reimbursement requests for CESAs are processed directly through STAR, the State’s accounting system, based upon review and approval of detailed invoices. Under the Monkey Pox Crisis Response award, DHS contracted with a nonprofit organization and local public health agencies to administer the award, and used GEARS to process reimbursement requests from the subrecipients.
During our FY 2022-23 audit (report 24-3), we identified concerns with subrecipient monitoring for the Public Health Emergency Response grant and recommended DHS review the tracking spreadsheets and complete its assessment of progress and fiscal reports and consideration of unallowable costs, and return funding to the federal government for unallowable costs identified; develop a monitoring plan; develop a central location to maintain monitoring documentation; and provide sufficient training to staff administering the Public Health Emergency Response grant (Finding 2023-306). DHS agreed with our recommendations and noted specific steps in its corrective action plan to address the concerns.
Criteria:
DHS administers federal programs that are subject to Uniform Guidance, which includes the following requirements related to the monitoring of subrecipients:
-2 CFR s. 200.332 (b) requires DHS to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring; and
-2 CFR s. 200.332 (d) through (f) requires DHS to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
DHS established policies requiring grant administrators to conduct a risk assessment for every subaward of federal funds and to use the risk assessment to determine the frequency and extent of monitoring. DHS policies include a subrecipient risk assessment template to assist grant administrators in completing the risk assessment and determining the risk level of the subrecipient.
DHS policies also require grant administrators to monitor subrecipients based on the risk assessments. DHS policies indicate that monitoring may include providing subrecipient training and technical assistance; performing desk reviews of the subrecipient’s records; and performing on-site reviews of the subrecipient’s records and operations. Finally, DHS policies in the Division of Public Health Bureau of Operations Contract Management Manual suggest that when GEARS is used to process reimbursement requests, grant administrators should use enhanced expenditure reporting from subrecipients to ensure expenditures are allowable. These policies note that additional verification may be performed by reviewing subrecipient financial records through a desk review or an on-site visit.
Condition:
In response to our prior year recommendation, DHS developed an internal control checklist for subrecipient monitoring, established a central location for filing monitoring documentation, and provided training to remind staff of their responsibilities related to subrecipient monitoring. However, the internal control checklist was implemented through a DHS, Division of Health, Bureau of Operations policy in July 2024, and we continued to identify concerns with subrecipient monitoring during FY 2023-24. We found that DHS did not provide documentation that it completed subrecipient risk assessments for three local public health agencies and seven tribal public health agencies that were subrecipients under the Public Health Emergency Response grant and had a contract modification in FY 2023-24. Further, DHS staff indicated that subrecipient risk assessments were not completed for seven of the nine tribal public health agencies when they were first subgranted funding in FY 2021-22.
In addition, DHS did not define the level of monitoring to be performed based on the completed risk assessments. For example, there was no documentation to indicate the level of monitoring required for low-, moderate-, and high-risk subrecipients, such as when it would be required to review subrecipient invoices through a desk review or an on-site visit. Further, DHS did not develop procedures for assessing and documenting desk reviews of subrecipient invoices, for assessing and documenting the reliance that can be placed on review of subrecipient single audit reports, and for documenting management oversight of the monitoring plan. Finally, DHS did not address the prior year recommendation regarding incomplete information and the identification of potential unallowable costs on the FY 2022-23 tracking spreadsheets.
Context:
DHS expended $14.7 million under the Public Health Emergency Response grant during FY 2023-24, including $8.3 million that was provided to subrecipients. Of the $8.3 million provided to subrecipients, $3.5 million was processed through GEARS. We interviewed DHS staff to gain an understanding of DHS policies and procedures for processing reimbursement requests from subrecipients, including its use of GEARS; DHS policies and procedures for monitoring subrecipients; and the steps taken to address our prior year recommendations. For the COVID Public Health Workforce award, DHS contracted with 79 local and tribal public health agencies and 12 CESAs to administer the award. For the Monkey Pox Crisis Response award, DHS contracted with three subrecipients to administer the award.
Questioned Costs:
None.
Effect:
Because its subrecipient monitoring procedures are insufficient, DHS is at increased risk of noncompliance with federal regulations for the Public Health Emergency Response grant. There is also an increased risk of improper payments for the Public Health Emergency Response grant.
Cause:
Although DHS implemented some new subrecipient monitoring procedures and provided training to staff on subrecipient monitoring activities, it continued to have deficiencies in its procedures and monitoring of subrecipients for the Public Health Emergency Response grant during FY 2023-24. DHS indicated it continued to review and update its procedures in FY 2024-25.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-complete its review of the FY 2022-23 subrecipient tracking spreadsheets and complete the assessment of the progress and fiscal reports and consideration of unallowable costs, document the conclusion, and return funding to the federal government if costs were determined to be unallowable;
-complete risk assessments for the three local and seven tribal public health agencies receiving funding under the Public Health Emergency Response grant during FY 2023-24 and adjust subrecipient monitoring appropriately;
-continue to develop a written monitoring plan for the Public Health Emergency Response grant that includes a description of the subrecipient monitoring expected for low-, moderate-, and high-risk subrecipients; procedures for completing and documenting desk reviews of subrecipient invoices; and procedures for assessing and documenting the reliance that can be placed on review of subrecipient single audit reports;
-provide training on the monitoring plan to staff with responsibilities for subrecipient monitoring activities; and
-develop and implement management oversight procedures to ensure monitoring is being completed and documented.
Finding 2024-307: Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response—Subrecipient Monitoring
Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response (Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922227-01 2023
Questioned Costs: None
COVID-19—Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response
(Assistance Listing number 93.354)
Award Numbers Award Years
6 NU90TP922078-01 2020
6 NU90TP922132-01 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Background:
DHHS provides funding to DHS for SABG, the ELC grant, the Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response, which DHS refers to as the Public Health Emergency Response grant, and the Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises program, which DHS refers to as the Health Disparities grant. These grants have various health-related purposes. To fulfill the purpose of each grant, DHS subawards funds to various entities, including counties, tribal governments, and other nonprofit organizations. In addition, under the SABG grant, amounts are provided by DHS to DCF and the University of Wisconsin-Madison (UW-Madison), which further subgrant to various entities.
Under FFATA, a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
In our FY 2022-23 audit (report 24-3), we identified that DHS had not accurately reported information in FSRS for several grants. We recommended DHS improve its procedures to accurately report required award information in a timely manner, including the date the subaward agreement was signed, and develop procedures to identify and report subawards made by state agencies to which it had transferred federal funding (Finding 2023-304).
Criteria:
Under 2 CFR s. 170, and as the prime grant awardee for these grants, DHS has overall responsibility for FFATA reporting and is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2023, it must be reported no later than January 31, 2024. The information required to be reported in FSRS includes several key data elements such as information about the recipient, the amount of the award, the project description, and the date the subaward agreement was signed.
Condition:
We selected a total of 34 subawards made by DHS under these grants during FY 2023-24 for testing, and we identified that 28 of the 34 subawards were not reported in a timely manner. We found that 14 of the 20 SABG subawards were not reported in a timely manner. For example, under the SABG grant, ten subawards were reported in August 2024, which was between seven to ten months after the date of the subaward.
In addition, we identified the obligation date was not accurate to within 10 days of the date the subaward agreement was signed for two subawards made under the SABG grant. We also found that none of the ELC, Public Health Emergency Response, and Health Disparities subawards we tested were reported in a timely manner. In addition, we found the project description was not completed accurately for ten subawards, including three for SABG subawards, two for ELC subawards, two for Public Health Emergency Response subawards, and three for Health Disparities subawards. Finally, we found that DHS did not report in FSRS any of the seven subawards DCF made under the SABG grant. DHS also did not report in FSRS the one subaward UW-Madison made under the SABG grant.
Context:
During FY 2023-24, DHS expended:
-$35.1 million under the SABG grant, of which $31.1 million was provided to subrecipients;
-$46.9 million under the ELC grant, of which $9.1 million was provided to subrecipients;
-$14.7 million under the Public Health Emergency Response grant, of which $8.3 million was provided to subrecipients; and
-$7.9 million under the Health Disparities grant, of which $2.6 million was provided to subrecipients.
Under the SABG grant, DCF expended $2.9 million, that was provided to subrecipients. Under the SABG grant, UW-Madison expended $0.2 million that was provided to subrecipients.
We reviewed 20 subawards for the SABG grant, two subawards for the ELC grant, nine for the Public Health Emergency Response grant, and three subawards for the Health Disparities grant that were made by DHS during FY 2023-24. We interviewed DHS staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. To assess if the subawards were reported in an accurate and timely manner, we requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed. We further followed up on the status of our prior audit recommendations.
Questioned Costs:
None.
Effect:
DHS did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS. The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov.
Cause:
In report 24-3, we noted that there were issues with the queries used to obtain information for reporting and procedures did not include obtaining information related to subawards made by other state agencies. During FY 2023-24, queries to retrieve information were established in a new system. However, the procedures in place to review the data produced by the queries and to determine what to report in FSRS were insufficient to ensure accurate and timely reporting. In response to our prior audit finding, DHS reported that it updated its FFATA reporting procedures. However, since the updates were not implemented until late in FY 2023-24, issues continued to be identified in our current audit.
Recommendation:
We recommend the Wisconsin Department of Health Services continue its efforts to implement updated procedures and make future revisions to these procedures for Federal Funding Accountability and Transparency Act reporting to ensure reporting is accurate, complete, and submitted in a timely manner.
Finding 2024-309: Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
COVID-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response (Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response
(Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises
(Assistance Listing number 93.391)
Award Numbers Award Years
1 NH75OT000039-01-00 2021
6 NH75OT000039-01-03 2023
6 NH75OT000039-01-05 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
COVID-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Year
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response—Subrecipient Monitoring
Background:
The CDC provides funding to DHS under the Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response grant, which DHS refers to as the Public Health Emergency Response grant. The Public Health Emergency Response grant is intended to provide funding to rapidly respond to public health emergencies as identified by the CDC. DHS received three awards from the CDC to be funded by the Public Health Emergency Response grant: COVID Crisis Response, which ended during FY 2022-23; COVID Public Health Workforce; and Monkey Pox Crisis Response.
Under the COVID Public Health Workforce award, DHS contracted with subrecipients, including local and tribal public health agencies and cooperative educational service agencies (CESAs), to administer the award. DHS uses GEARS to process the reimbursement requests for the local and tribal public health agencies. Reimbursement requests for CESAs are processed directly through STAR, the State’s accounting system, based upon review and approval of detailed invoices. Under the Monkey Pox Crisis Response award, DHS contracted with a nonprofit organization and local public health agencies to administer the award, and used GEARS to process reimbursement requests from the subrecipients.
During our FY 2022-23 audit (report 24-3), we identified concerns with subrecipient monitoring for the Public Health Emergency Response grant and recommended DHS review the tracking spreadsheets and complete its assessment of progress and fiscal reports and consideration of unallowable costs, and return funding to the federal government for unallowable costs identified; develop a monitoring plan; develop a central location to maintain monitoring documentation; and provide sufficient training to staff administering the Public Health Emergency Response grant (Finding 2023-306). DHS agreed with our recommendations and noted specific steps in its corrective action plan to address the concerns.
Criteria:
DHS administers federal programs that are subject to Uniform Guidance, which includes the following requirements related to the monitoring of subrecipients:
-2 CFR s. 200.332 (b) requires DHS to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring; and
-2 CFR s. 200.332 (d) through (f) requires DHS to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
DHS established policies requiring grant administrators to conduct a risk assessment for every subaward of federal funds and to use the risk assessment to determine the frequency and extent of monitoring. DHS policies include a subrecipient risk assessment template to assist grant administrators in completing the risk assessment and determining the risk level of the subrecipient.
DHS policies also require grant administrators to monitor subrecipients based on the risk assessments. DHS policies indicate that monitoring may include providing subrecipient training and technical assistance; performing desk reviews of the subrecipient’s records; and performing on-site reviews of the subrecipient’s records and operations. Finally, DHS policies in the Division of Public Health Bureau of Operations Contract Management Manual suggest that when GEARS is used to process reimbursement requests, grant administrators should use enhanced expenditure reporting from subrecipients to ensure expenditures are allowable. These policies note that additional verification may be performed by reviewing subrecipient financial records through a desk review or an on-site visit.
Condition:
In response to our prior year recommendation, DHS developed an internal control checklist for subrecipient monitoring, established a central location for filing monitoring documentation, and provided training to remind staff of their responsibilities related to subrecipient monitoring. However, the internal control checklist was implemented through a DHS, Division of Health, Bureau of Operations policy in July 2024, and we continued to identify concerns with subrecipient monitoring during FY 2023-24. We found that DHS did not provide documentation that it completed subrecipient risk assessments for three local public health agencies and seven tribal public health agencies that were subrecipients under the Public Health Emergency Response grant and had a contract modification in FY 2023-24. Further, DHS staff indicated that subrecipient risk assessments were not completed for seven of the nine tribal public health agencies when they were first subgranted funding in FY 2021-22.
In addition, DHS did not define the level of monitoring to be performed based on the completed risk assessments. For example, there was no documentation to indicate the level of monitoring required for low-, moderate-, and high-risk subrecipients, such as when it would be required to review subrecipient invoices through a desk review or an on-site visit. Further, DHS did not develop procedures for assessing and documenting desk reviews of subrecipient invoices, for assessing and documenting the reliance that can be placed on review of subrecipient single audit reports, and for documenting management oversight of the monitoring plan. Finally, DHS did not address the prior year recommendation regarding incomplete information and the identification of potential unallowable costs on the FY 2022-23 tracking spreadsheets.
Context:
DHS expended $14.7 million under the Public Health Emergency Response grant during FY 2023-24, including $8.3 million that was provided to subrecipients. Of the $8.3 million provided to subrecipients, $3.5 million was processed through GEARS. We interviewed DHS staff to gain an understanding of DHS policies and procedures for processing reimbursement requests from subrecipients, including its use of GEARS; DHS policies and procedures for monitoring subrecipients; and the steps taken to address our prior year recommendations. For the COVID Public Health Workforce award, DHS contracted with 79 local and tribal public health agencies and 12 CESAs to administer the award. For the Monkey Pox Crisis Response award, DHS contracted with three subrecipients to administer the award.
Questioned Costs:
None.
Effect:
Because its subrecipient monitoring procedures are insufficient, DHS is at increased risk of noncompliance with federal regulations for the Public Health Emergency Response grant. There is also an increased risk of improper payments for the Public Health Emergency Response grant.
Cause:
Although DHS implemented some new subrecipient monitoring procedures and provided training to staff on subrecipient monitoring activities, it continued to have deficiencies in its procedures and monitoring of subrecipients for the Public Health Emergency Response grant during FY 2023-24. DHS indicated it continued to review and update its procedures in FY 2024-25.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-complete its review of the FY 2022-23 subrecipient tracking spreadsheets and complete the assessment of the progress and fiscal reports and consideration of unallowable costs, document the conclusion, and return funding to the federal government if costs were determined to be unallowable;
-complete risk assessments for the three local and seven tribal public health agencies receiving funding under the Public Health Emergency Response grant during FY 2023-24 and adjust subrecipient monitoring appropriately;
-continue to develop a written monitoring plan for the Public Health Emergency Response grant that includes a description of the subrecipient monitoring expected for low-, moderate-, and high-risk subrecipients; procedures for completing and documenting desk reviews of subrecipient invoices; and procedures for assessing and documenting the reliance that can be placed on review of subrecipient single audit reports;
-provide training on the monitoring plan to staff with responsibilities for subrecipient monitoring activities; and
-develop and implement management oversight procedures to ensure monitoring is being completed and documented.
Finding 2024-307: Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response—Subrecipient Monitoring
Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response (Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922227-01 2023
Questioned Costs: None
COVID-19—Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response
(Assistance Listing number 93.354)
Award Numbers Award Years
6 NU90TP922078-01 2020
6 NU90TP922132-01 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Background:
DHHS provides funding to DHS for SABG, the ELC grant, the Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response, which DHS refers to as the Public Health Emergency Response grant, and the Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises program, which DHS refers to as the Health Disparities grant. These grants have various health-related purposes. To fulfill the purpose of each grant, DHS subawards funds to various entities, including counties, tribal governments, and other nonprofit organizations. In addition, under the SABG grant, amounts are provided by DHS to DCF and the University of Wisconsin-Madison (UW-Madison), which further subgrant to various entities.
Under FFATA, a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
In our FY 2022-23 audit (report 24-3), we identified that DHS had not accurately reported information in FSRS for several grants. We recommended DHS improve its procedures to accurately report required award information in a timely manner, including the date the subaward agreement was signed, and develop procedures to identify and report subawards made by state agencies to which it had transferred federal funding (Finding 2023-304).
Criteria:
Under 2 CFR s. 170, and as the prime grant awardee for these grants, DHS has overall responsibility for FFATA reporting and is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2023, it must be reported no later than January 31, 2024. The information required to be reported in FSRS includes several key data elements such as information about the recipient, the amount of the award, the project description, and the date the subaward agreement was signed.
Condition:
We selected a total of 34 subawards made by DHS under these grants during FY 2023-24 for testing, and we identified that 28 of the 34 subawards were not reported in a timely manner. We found that 14 of the 20 SABG subawards were not reported in a timely manner. For example, under the SABG grant, ten subawards were reported in August 2024, which was between seven to ten months after the date of the subaward.
In addition, we identified the obligation date was not accurate to within 10 days of the date the subaward agreement was signed for two subawards made under the SABG grant. We also found that none of the ELC, Public Health Emergency Response, and Health Disparities subawards we tested were reported in a timely manner. In addition, we found the project description was not completed accurately for ten subawards, including three for SABG subawards, two for ELC subawards, two for Public Health Emergency Response subawards, and three for Health Disparities subawards. Finally, we found that DHS did not report in FSRS any of the seven subawards DCF made under the SABG grant. DHS also did not report in FSRS the one subaward UW-Madison made under the SABG grant.
Context:
During FY 2023-24, DHS expended:
-$35.1 million under the SABG grant, of which $31.1 million was provided to subrecipients;
-$46.9 million under the ELC grant, of which $9.1 million was provided to subrecipients;
-$14.7 million under the Public Health Emergency Response grant, of which $8.3 million was provided to subrecipients; and
-$7.9 million under the Health Disparities grant, of which $2.6 million was provided to subrecipients.
Under the SABG grant, DCF expended $2.9 million, that was provided to subrecipients. Under the SABG grant, UW-Madison expended $0.2 million that was provided to subrecipients.
We reviewed 20 subawards for the SABG grant, two subawards for the ELC grant, nine for the Public Health Emergency Response grant, and three subawards for the Health Disparities grant that were made by DHS during FY 2023-24. We interviewed DHS staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. To assess if the subawards were reported in an accurate and timely manner, we requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed. We further followed up on the status of our prior audit recommendations.
Questioned Costs:
None.
Effect:
DHS did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS. The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov.
Cause:
In report 24-3, we noted that there were issues with the queries used to obtain information for reporting and procedures did not include obtaining information related to subawards made by other state agencies. During FY 2023-24, queries to retrieve information were established in a new system. However, the procedures in place to review the data produced by the queries and to determine what to report in FSRS were insufficient to ensure accurate and timely reporting. In response to our prior audit finding, DHS reported that it updated its FFATA reporting procedures. However, since the updates were not implemented until late in FY 2023-24, issues continued to be identified in our current audit.
Recommendation:
We recommend the Wisconsin Department of Health Services continue its efforts to implement updated procedures and make future revisions to these procedures for Federal Funding Accountability and Transparency Act reporting to ensure reporting is accurate, complete, and submitted in a timely manner.
Finding 2024-309: Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
COVID-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response (Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response
(Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises
(Assistance Listing number 93.391)
Award Numbers Award Years
1 NH75OT000039-01-00 2021
6 NH75OT000039-01-03 2023
6 NH75OT000039-01-05 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
COVID-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Year
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises—Subrecipient Monitoring
Background:
The CDC provides funding to DHS under the Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises grant, which DHS refers to as the Health Disparities grant. The grant is intended to address health disparities for high-risk and underserved populations to address COVID-19 related health disparities and advance health equity.
To administer the award under the Health Disparities grant, DHS contracted with a variety of subrecipients, including local and tribal public health agencies and nonprofit entities. DHS uses GEARS to process the reimbursement requests for the majority of its subrecipients. During our FY 2022-23 audit (report 24-3), we identified concerns with subrecipient monitoring for the Health Disparities grant and recommended DHS develop a monitoring plan, develop a central location to maintain monitoring documentation, and provide sufficient training to staff administering the Health Disparities grant (Finding 2023-305). DHS agreed with our recommendation and noted specific steps in its corrective action plan to address the concerns.
Criteria:
DHS administers federal programs that are subject to Uniform Guidance, which includes the following requirements related to the monitoring of subrecipients:
-2 CFR s. 200.332 (b) requires DHS to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring; and
-2 CFR s. 200.332 (d) through (f) requires DHS to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
DHS established policies requiring grant administrators to conduct a risk assessment for every subaward of federal funds and to use the risk assessment to determine the frequency and extent of monitoring. DHS policies include a subrecipient risk assessment template to assist grant administrators in completing the risk assessment and determining the risk level of the subrecipient.
DHS policies also require grant administrators to monitor subrecipients based on the risk assessments. DHS policies indicate that monitoring may include providing subrecipient training and technical assistance; performing desk reviews of the subrecipient’s records; and performing on-site reviews of the subrecipient’s records and operations. Finally, DHS policies in the Division of Public Health Bureau of Operations Contract Management Manual suggest that when GEARS is used to process reimbursement requests, grant administrators should use enhanced expenditure reporting from subrecipients to ensure expenditures are allowable. These policies note that additional verification may be performed by reviewing subrecipient financial records through a desk review or an on-site visit.
Condition:
In response to our prior year recommendation, DHS developed an internal control checklist for subrecipient monitoring, established a central location for filing monitoring documentation, and provided training to remind staff of their responsibilities related to subrecipient monitoring. However, the internal control checklist was implemented through a DHS, Division of Public Health, Bureau of Operations policy in July 2024, and we continued to identify concerns with subrecipient monitoring during FY 2023-24. We found that DHS did not define the level of monitoring to be performed based on the completed risk assessments. For example, there was no documentation to indicate the level of monitoring required for low-, moderate-, and high-risk subrecipients, such as when it would be required to review subrecipient invoices through a desk review or an on-site visit. Further, DHS did not develop procedures for assessing and documenting desk reviews of subrecipient invoices, for assessing and documenting the reliance that can be placed on review of subrecipient single audit reports, and for documenting management oversight of the monitoring plan.
Context:
DHS expended $7.9 million under the Health Disparities grant during FY 2023-24, including $2.6 million that was provided to subrecipients. Of the $2.6 million provided to subrecipients, $2.4 million was processed through GEARS. DHS contracted with 87 subrecipients to administer the grant. We interviewed DHS staff to gain an understanding of DHS policies and procedures for processing reimbursement requests from subrecipients, including its use of GEARS; DHS policies and procedures for monitoring subrecipients; and the steps taken to address our prior year recommendations.
Questioned Costs:
None.
Effect:
Because its subrecipient monitoring procedures are insufficient, DHS is at increased risk of noncompliance with federal regulations for the Health Disparities grant. There is also an increased risk of improper payments for the Health Disparities grant.
Cause:
Although DHS implemented some new subrecipient monitoring procedures and provided training to staff on subrecipient monitoring activities, it continued to have deficiencies in its procedures and monitoring of subrecipients for the Health Disparities grant during FY 2023-24. DHS indicated it continued to review and update its procedures in FY 2024-25.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-continue to develop a written monitoring plan for the Health Disparities grant that includes a description of the subrecipient monitoring expected for low-, moderate-, and high-risk subrecipients; procedures for completing and documenting desk reviews of subrecipient invoices; and procedures for assessing and documenting the reliance that can be placed on review of subrecipient single audit reports;
-provide training on the monitoring plan to staff with responsibilities for subrecipient monitoring activities; and
-develop and implement management oversight procedures to ensure monitoring is being completed and documented.
Finding 2024-306: Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises—Subrecipient Monitoring
COVID-19—Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises
(Assistance Listing number 93.391)
Award Numbers Award Years
1 NH75OT000039-01-00 2021
6 NH75OT000039-01-03 2023
6 NH75OT000039-01-05 2024
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Background:
DHHS provides funding to DHS for SABG, the ELC grant, the Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response, which DHS refers to as the Public Health Emergency Response grant, and the Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises program, which DHS refers to as the Health Disparities grant. These grants have various health-related purposes. To fulfill the purpose of each grant, DHS subawards funds to various entities, including counties, tribal governments, and other nonprofit organizations. In addition, under the SABG grant, amounts are provided by DHS to DCF and the University of Wisconsin-Madison (UW-Madison), which further subgrant to various entities.
Under FFATA, a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
In our FY 2022-23 audit (report 24-3), we identified that DHS had not accurately reported information in FSRS for several grants. We recommended DHS improve its procedures to accurately report required award information in a timely manner, including the date the subaward agreement was signed, and develop procedures to identify and report subawards made by state agencies to which it had transferred federal funding (Finding 2023-304).
Criteria:
Under 2 CFR s. 170, and as the prime grant awardee for these grants, DHS has overall responsibility for FFATA reporting and is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2023, it must be reported no later than January 31, 2024. The information required to be reported in FSRS includes several key data elements such as information about the recipient, the amount of the award, the project description, and the date the subaward agreement was signed.
Condition:
We selected a total of 34 subawards made by DHS under these grants during FY 2023-24 for testing, and we identified that 28 of the 34 subawards were not reported in a timely manner. We found that 14 of the 20 SABG subawards were not reported in a timely manner. For example, under the SABG grant, ten subawards were reported in August 2024, which was between seven to ten months after the date of the subaward.
In addition, we identified the obligation date was not accurate to within 10 days of the date the subaward agreement was signed for two subawards made under the SABG grant. We also found that none of the ELC, Public Health Emergency Response, and Health Disparities subawards we tested were reported in a timely manner. In addition, we found the project description was not completed accurately for ten subawards, including three for SABG subawards, two for ELC subawards, two for Public Health Emergency Response subawards, and three for Health Disparities subawards. Finally, we found that DHS did not report in FSRS any of the seven subawards DCF made under the SABG grant. DHS also did not report in FSRS the one subaward UW-Madison made under the SABG grant.
Context:
During FY 2023-24, DHS expended:
-$35.1 million under the SABG grant, of which $31.1 million was provided to subrecipients;
-$46.9 million under the ELC grant, of which $9.1 million was provided to subrecipients;
-$14.7 million under the Public Health Emergency Response grant, of which $8.3 million was provided to subrecipients; and
-$7.9 million under the Health Disparities grant, of which $2.6 million was provided to subrecipients.
Under the SABG grant, DCF expended $2.9 million, that was provided to subrecipients. Under the SABG grant, UW-Madison expended $0.2 million that was provided to subrecipients.
We reviewed 20 subawards for the SABG grant, two subawards for the ELC grant, nine for the Public Health Emergency Response grant, and three subawards for the Health Disparities grant that were made by DHS during FY 2023-24. We interviewed DHS staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. To assess if the subawards were reported in an accurate and timely manner, we requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed. We further followed up on the status of our prior audit recommendations.
Questioned Costs:
None.
Effect:
DHS did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS. The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov.
Cause:
In report 24-3, we noted that there were issues with the queries used to obtain information for reporting and procedures did not include obtaining information related to subawards made by other state agencies. During FY 2023-24, queries to retrieve information were established in a new system. However, the procedures in place to review the data produced by the queries and to determine what to report in FSRS were insufficient to ensure accurate and timely reporting. In response to our prior audit finding, DHS reported that it updated its FFATA reporting procedures. However, since the updates were not implemented until late in FY 2023-24, issues continued to be identified in our current audit.
Recommendation:
We recommend the Wisconsin Department of Health Services continue its efforts to implement updated procedures and make future revisions to these procedures for Federal Funding Accountability and Transparency Act reporting to ensure reporting is accurate, complete, and submitted in a timely manner.
Finding 2024-309: Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
COVID-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response (Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response
(Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises
(Assistance Listing number 93.391)
Award Numbers Award Years
1 NH75OT000039-01-00 2021
6 NH75OT000039-01-03 2023
6 NH75OT000039-01-05 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
COVID-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Year
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Waivers for State Innovation for Section 1332 of the Patient Protection and Affordable Care Act—Financial Reporting
Background:
Section 1332 of the federal Patient Protection and Affordable Care Act of 2010 (Affordable Care Act) permits a state to apply for a waiver to pursue innovative strategies for providing residents with access to high quality, affordable health insurance while retaining the basic protections of the Affordable Care Act. 2017 Wisconsin Act 138 created the Wisconsin Healthcare Stability Plan (WIHSP), under which the State covers a portion of the financial risk of health insurers. Act 138 required OCI to implement WIHSP if Wisconsin’s waiver plan was approved by the federal government. OCI applied for a waiver, which was approved by the U.S. Department of Health and Human Services (DHHS) in July 2018. Under the approved waiver, a health insurance carrier in the healthcare insurance exchange may be reimbursed a portion of the claims it incurred in the prior calendar year.
In 2019, DHHS awarded OCI funding under the 1332 State Innovation Waivers program to administer WIHSP for the period January 1, 2019, through December 31, 2023. OCI received an extension of the federal funding in 2022, covering the period January 1, 2024, through December 31, 2028. From the inception of the program and through June 30, 2024, OCI expended $680.8 million under the 1332 State Innovation Waivers program. The federal funding is used, along with state appropriations, to reimburse insurance carriers participating in the healthcare insurance exchange for a portion of enrollee claims. Insurance carriers submit various attestations and enrollee claim information to OCI.
Criteria:
2 CFR s. 200.303 requires OCI to establish and maintain effective internal control over its federal programs and to provide reasonable assurance that the federal programs are administered in compliance with federal statutes, regulations, and the terms and conditions of its federal awards. Under the terms and conditions for the 1332 State Innovation Waivers grant award, OCI is required to report expenditures annually using the Standard Form 425 (SF-425) Federal Financial Report.
Condition:
We found OCI did not complete all required lines of the SF-425 Federal Financial Report filed for the year ended December 31, 2023. OCI reported zero expenditures in line 10e (federal share of expenditures) when OCI should have reported $680,759,297 in line 10e. As a result, line 10h, which is a calculated field, incorrectly indicated that OCI had an unobligated balance of federal funds of $894,224,285, when the unobligated balance should have been reported as $213,464,988.
Context:
OCI expended $208.3 million in federal funds under the 1332 State Innovations Waivers program in FY 2023-24. We reviewed OCI’s written procedures for federal reporting and interviewed the WIHSP Administrator and OCI finance staff to gain an understanding of the reporting procedures. We tested the SF-425 Federal Financial Report submitted by OCI for calendar year 2023 and compared the amounts reported to the accounting records.
Questioned Costs:
None.
Effect:
OCI reported inaccurate information in its federal financial report filed in FY 2023-24, which resulted in inaccurate information being provided to the federal awarding agency.
Cause:
OCI staff indicated they believed the prepopulated fields were not editable and that they only signed and certified the report. We also note OCI did not have procedures in place to require a secondary review and sign off on the report prior to submission.
Recommendation:
We recommend the Wisconsin Office of the Commissioner of Insurance:
-develop written procedures to require a secondary review of the annual Standard Form 425 Federal Financial Report that include steps for conducting and documenting the secondary review; and
-work with the U.S. Department of Health and Human Services to determine whether the Standard Form 425 Federal Financial Report for calendar year 2023 needs to be corrected and refiled.
Finding 2024-900: Waivers for State Innovation for Section 1332 of the Patient Protection and Affordable Care Act—Financial Reporting
Waivers for State Innovation for Section 1332 of the Patient Protection and Affordable Care Act (PPACA) (Assistance Listing number 93.423)
Award Numbers Award Years
SIWIW190008-03 2021
SIWIW190008-04 2022
SIWIW190008-05 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Office of the Commissioner of Insurance: The Wisconsin Office of the Commissioner of Insurance agrees with the audit finding and recommendations.
Waivers for State Innovation for Section 1332 of the Patient Protection and Affordable Care Act—Verification Audits
Background:
Section 1332 of the Affordable Care Act permits a state to apply for a waiver to pursue innovative strategies for providing residents with access to high quality, affordable health insurance while retaining the basic protections of the Affordable Care Act. 2017 Wisconsin Act 138 created WIHSP, under which the State covers a portion of the financial risk of health insurance carriers. Act 138 required OCI to implement WIHSP
if Wisconsin’s waiver plan was approved by the federal government. OCI applied for a waiver, which was approved by DHHS in July 2018. Under the approved waiver, a health insurance carrier in the healthcare insurance exchange may be reimbursed a portion of the claims it incurred in the prior calendar year.
In 2019, DHHS awarded OCI funding under the 1332 State Innovation Waivers program to administer WIHSP for the period January 1, 2019, through December 31, 2023. OCI received an extension of the federal funding in 2022, covering the period January 1, 2024, through December 31, 2028. From the inception of the program and through June 30, 2024, OCI expended $680.8 million under the 1332 State Innovation Waivers program. The federal funding is used, along with state appropriations, to reimburse insurance carriers participating in the healthcare insurance exchange for a portion of enrollee claims. Insurance carriers submit various attestations and enrollee claim information to OCI.
Criteria:
2 CFR s. 200.303 requires OCI to establish and maintain effective internal control over its federal programs and to provide reasonable assurance that the federal programs are administered in compliance with federal statutes, regulations, and the terms and conditions of its federal awards.
OCI is also responsible for ensuring costs charged to federal grant programs it administers are allowable under federal statutes, federal regulations, and the terms and conditions of the federal award. To ensure the attestations were completed, and to assess the validity of the enrollee claims submitted by the insurance carriers, the WIHSP Administrator and finance staff at OCI conducted a verification audit. OCI’s written procedures for conducting the verification audit required OCI to:
-test a random sample of at least 60 enrollees across all the participating insurance carriers for the phase I audit, including ensuring claims for these enrollees were incurred in the benefit year and paid prior to the established deadline of April 30 of the calendar year following the applicable benefit year;
-randomly sample and review proof of payment for two claims for each enrollee sampled during the phase I audit; and
-have a secondary reviewer review a portion of the audit documents and initial review results for the phase I and II audits.
Condition:
We identified two concerns with OCI’s administration of the verification audits it performed related to its 1332 State Innovation Waivers program. First, in the phase I audit conducted for benefit year 2022, OCI did not detect that one insurance carrier reported in the audit response spreadsheet that it had paid two claims for two enrollees after April 30, which was the established deadline for claims. This was not detected by OCI during either the initial or secondary review of the claims information in the audit response spreadsheet. After we identified this issue, OCI followed up with the insurance carrier and determined that the payment dates for these claims had been inaccurately reported and obtained documentation from the insurance carrier to support that the claims had been paid prior to the April 30 deadline.
Second, for the phase II audit conducted for benefit year 2022, the proof of payment for 9 of the 130 claims tested included the claim date but did not include documentation of the payment date. After we identified this issue, OCI followed up with the insurance carriers and obtained documentation to support that the claims were paid prior to the April 30 deadline.
Context:
OCI expended $208.3 million in federal funds under the 1332 State Innovations Waiver program in FY 2023-24. We reviewed OCI’s written procedures and interviewed the WIHSP Administrator and OCI finance staff to gain an understanding of the phase I and phase II verification audits. We reviewed the documentation related to the verification audits completed for benefit year 2022, which supported payments made to insurance carriers in FY 2023-24. For all 65 enrollees that OCI sampled for phase I of the verification audits, we tested whether documentation matched between the claims report and the amounts included in the insurance carriers audit response spreadsheet. For the 65 enrollees in phase II of the verification audit, we also tested the claims documentation provided by the insurance carriers. During our FY 2020-21 single
audit (report 22-5), we identified concerns with OCI’s audit process and made recommendations to OCI.
Questioned Costs:
None.
Effect:
OCI may not have identified claims that did not meet eligibility requirements or lacked appropriate supporting documentation, which could result in unallowable costs.
Cause:
OCI staff did not correctly follow the verification audit written procedures, which require the initial and secondary reviewer to verify that sampled claims were paid prior to the established deadline. Further, OCI’s audit response spreadsheet does not restrict insurance carriers from entering claims incurred or paid outside of the allowable periods.
OCI staff relied on the claim date in completing the phase II audit and did not request the payment date information from the insurance carriers. Further, the instructions OCI provided insurers for submitting proof of payment for the phase II audit did not explicitly direct insurance carriers to include the payment date on the documentation submitted to support the claims.
Recommendation:
We recommend the Wisconsin Office of the Commissioner of Insurance:
-review and update the audit response spreadsheet to restrict insurance carriers from entering claims service and payment dates outside of the allowable periods;
-update instructions and guidance provided to insurance carriers to clearly indicate that claims documentation submitted to the Office of the Commissioner of Insurance should include the claim payment date; and
-follow its written procedures for conducting verification audits, including reviewing to ensure the claims documentation supports that claims have been paid before the established deadline.
Finding 2024-901: Waivers for State Innovation for Section 1332 of the Patient Protection and Affordable Care Act—Verification Audits
Waivers for State Innovation for Section 1332 of the Patient Protection and Affordable Care Act (PPACA) (Assistance Listing number 93.423)
Award Numbers Award Years
SIWIW190008-03 2021
SIWIW190008-04 2022
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Office of the Commissioner of Insurance: The Wisconsin Office of the Commissioner of Insurance agrees with the audit finding and recommendations.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to Federal Funding Accountability and Transparency Act (FFATA) reporting for certain grant programs administered by the State. During FY 2023-24, DOA’s Division of Executive Budget and Finance was responsible for uploading required FFATA information into the FFATA Subaward Reporting System (FSRS) based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DOA also provided guidance and technical assistance to agencies on FFATA reporting requirements.
During our FY 2022-23 single audit (report 24-3), we identified concerns that DOA’s method of reporting modifications to subawards in FSRS resulted in an overstatement of the subaward information in FSRS and on USAspending.gov. In report 24-3, we recommended that DOA alter its approach and report only the amount of subaward modifications, update guidance to agencies, and provide training to state agencies on appropriate reporting (Finding 2023-106). We also recommended that DOA maintain its current approach of reporting cumulative amounts with subaward modifications only if it received specific guidance from the Office of Management and Budget (OMB) that its current reporting was appropriate. DOA agreed with our recommendations. Further, in January 2025 the U.S. Department of Health and Human Services sustained the audit finding and recommended that DOA revise and resubmit any reports that contained inaccurate data.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance on FSRS.gov indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Further, guidance posted on the U.S. General Services Administration (GSA) website in spring 2024 provided clarification that when a subaward is modified, the preparer should update the original entry in FSRS. The guidance also indicated that if information for a subaward changes, the preparer is to update the original report in FSRS.
Condition:
In response to our prior year recommendation, DOA contacted OMB for clarification on the FFATA reporting requirements. OMB’s response indicated that DOA should “use the total amount after adjusted,” in reporting subaward modifications in FSRS. DOA interpreted this guidance to mean it would continue its established process for reporting subaward modifications by reporting the cumulative amount of the subaward, not just the modification, in FSRS. Therefore, DOA did not alter its reporting of subaward modifications in FSRS for FY 2023-24. For example, in reviewing subaward information on USAspending.gov for a subaward related to the Temporary Assistance for Needy Families grant (Assistance Listing number 93.558), we found that the total subaward was overstated on USAspending.gov because DOA reported cumulative amounts for each modification.
Context:
DOA staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including the departments of Children and Families and Natural Resources. We discussed DOA’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov, and the updated guidance on the GSA website. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2023-24 for which FFATA reporting was subject to audit and for which DOA was responsible for FFATA reporting. We also followed up on the status of the prior year audit finding and the steps DOA took to address the finding.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USAspending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
In our prior audit, DOA indicated that it relied on guidance from an OMB official who indicated that cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. In our current audit, DOA relied on its March 2024 inquiries of OMB subsequent to our recommendations in March 2024, which DOA interpreted as a requirement to continue its current procedures.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report subaward modifications as an adjustment to the original subaward record in the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission in FSRS; and
-provide training to state agencies to ensure consistent reporting across state agencies.
Finding 2024-101: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02393 2018
00E02349 2018
00E02456 2019
00E02824 2020
00E03252 2022
00E03490 2023
Questioned Costs: None
Temporary Assistance for Needy Families (Assistance Listing number 93.558)
Award Number Award Year
2301WITANF 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Temporary Assistance for Needy Families—Work Verification Plan
Background:
DCF receives funding from the U.S. Department of Health and Human Services (DHHS) under the TANF grant, which is used to administer Wisconsin’s W-2 program.
Criteria:
Under 45 CFR s. 261.20, a state administering TANF must meet certain work participation rates and submit work participation data to DHHS that allows DHHS to measure the state’s success in requiring work-eligible individuals to participate in the 12 countable work activities specified in 45 CFR s. 261.30. Under 45 CFR s. 261.62, a state is required to implement procedures to ensure the accuracy of the data submitted to DHHS, including by developing a work verification plan for approval by DHHS. The work verification plan is required to include a description of the documentation used to monitor work participation and to ensure that the actual hours of participation are reported, and a description of the internal controls implemented by the state to ensure consistent measurement of work participation rates, including quality assurance and monitoring processes. If a state modifies its approved work verification procedures or internal controls, 45 CFR s. 261.63 requires the state to submit an amended work verification plan for approval.
Condition:
During our FY 2023-24 audit, we found that DCF did not complete the monitoring of local agencies that administer the W-2 program as described in its work verification plan, which was approved by DHHS in 2008. For example, the approved work verification plan indicated that on a monthly basis DCF staff would conduct case file reviews of 125 randomly selected W-2 cases. As described in the approved work verification plan, these case file reviews should include ensuring that the work activity recorded in DCF’s case management system is supported by documentation that is required to be maintained by the local agencies. Although DCF staff continued to perform case file reviews as part of quarterly monitoring of local agencies that administer the W-2 program, DCF staff indicated that these reviews no longer included reviewing attendance tracking documentation for all types of work activities. For two of the five participants for which we reviewed work participation data, we found that the work activity reported in DCF’s case management system was not supported by documentation maintained by the local agencies.
In addition, we found that DCF did not submit an amended work verification plan to DHHS for approval.
Context:
For FY 2023-24, DCF reported TANF expenditures of $203.6 million. We reviewed DCF’s work verification plan and interviewed DCF staff to gain an understanding of DCF’s procedures for complying with its work verification plan. We obtained and reviewed attendance tracking documentation for five participants for which work participation data was submitted to DHHS during FY 2023-24.
Questioned Costs:
None.
Effect:
DCF is not in compliance with the work verification plan approved by DHHS. Under 45 CFR s. 262.1 (a) (15), DHHS may penalize a state by an amount not less than 1.0 percent and not more than 5.0 percent of the basic TANF block grant allocated to the state for failure to establish or comply with work participation verification procedures.
Cause:
DCF staff indicated that they stopped performing case file reviews as described in the approved work verification plan in 2022 because they determined less monitoring was needed based on prior monitoring results and because of a reduction in the work participation rates that DCF was required to meet. In addition, DCF staff indicated that they were unaware that changes to work verification procedures and related internal controls required an amended work verification plan be submitted to DHHS for approval.
Recommendation:
We recommend the Wisconsin Department of Children and Families:
-review its approved work verification plan and determine if amendments are needed;
-submit the amended work verification plan to the U.S. Department of Health and Human services for approval; and
-complete and document monitoring of work participation information in accordance with the approved work verification plan.
Finding 2024-200: Temporary Assistance for Needy Families—Work Verification Plan
Temporary Assistance for Needy Families (Assistance Listing number 93.558)
Award Numbers Award Years
2101WITANF 2021
2201WITANF 2022
2301WITANF 2023
2401WITANF 2024
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Children and Families: The Wisconsin Department of Children and Families agrees with the audit finding and recommendations.
Temporary Assistance for Needy Families—Federal Funding Accountability and Transparency Act Reporting
Background:
DHHS provides funding to DCF under the TANF grant, which is used to administer Wisconsin’s W-2 program. DCF subawards TANF funds to various entities, including counties, tribes, and other organizations.
Under the Federal Funding Accountability and Transparency Act (FFATA), a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
As part of our FY 2022-23 audit (report 24-3), we identified that DCF did not report in a timely manner its subaward information in the FFATA Subaward Reporting System (FSRS) for two grants. We recommended DCF review the query used to determine subawards and review and make adjustments to its procedures to ensure all original subaward agreements and amendments are input and updated in a timely manner. (Finding 2023-202).
Criteria:
Under 2 CFR s. 170, DCF is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2023, it must be reported no later than January 31, 2024. Several key data elements are required to be reported in FSRS, including information about the recipient, the amount of the award, the project description, and the date the subaward agreement was signed.
Condition:
We found that 18 of 33 TANF subawards, including new subawards and amendments to existing subawards, made by DCF during FY 2023-24 were not reported in a timely manner. Of these 18 subawards, four were not reported at all. In addition, we identified four subawards for which the amount of the award was not reported accurately.
Context:
During FY 2023-24, DCF expended $203.6 million under the TANF grant, of which $34.8 million was provided to subrecipients. We reviewed 33 new and amended subawards for the TANF grant that were made by DCF during FY 2023-24. We interviewed DCF staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. To assess if the subaward was reported in an accurate and timely manner, we requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed. We further followed up on the status of our prior audit recommendation.
Questioned Costs:
None.
Effect:
DCF did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS. The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov for the TANF grant.
Cause:
In report 24-3, we noted that there were issues with the queries used to obtain information for reporting and that DCF staff did not consistently input the subawards into the subaward tracking system within the same month the subaward was signed. During FY 2023-24, DCF implemented procedures to address our prior audit concerns. However, since the updates were not implemented until late in FY 2023-24, issues continued to be identified during our current audit.
Recommendation:
We recommend the Wisconsin Department of Children and Families continue its efforts to implement updated procedures and consider whether further updates are needed for Federal Funding Accountability and Transparency Act reporting to ensure this reporting is accurate, complete, and submitted in a timely manner.
Finding 2024-201: Temporary Assistance for Needy Families—Federal Funding Accountability and Transparency Act Reporting
Temporary Assistance for Needy Families (Assistance Listing number 93.558)
Award Numbers Award Years
2201WITANF 2022
2301WITANF 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Children and Families: The Wisconsin Department of Children and Families agrees with the audit finding and recommendation.
Social Services Block Grant—Subrecipient Contracts
Background:
DHHS provides funding to DHS for SSBG. This program provides flexible financial assistance to states that allows them to tailor social services programs to the needs of their populations. In addition, a state may transfer funds received under the Temporary Assistance for Needy Families (TANF) program (Assistance Listing number 93.558) to the SSBG program for use under this program. During FY 2023-24, $14.7 million was transferred from the TANF program to the SSBG program. DHS uses the SSBG funding, including the amounts transferred from the TANF program and general purpose revenue, to provide funding for the community aids program, and more specifically, amounts designated within this program as the “basic county allocation” that can be used by counties to support any eligible service.
DHS contracts with each county for the administration of the community aids program. Because DHS provides funding to counties to carry out the purpose of a federal program, DHS is considered a pass-through entity, and the counties are considered subrecipients. DHS uses its Grant Enrollment, Application and Reporting System (GEARS) and establishes GEARS profiles to designate the program, the purpose of the program, the types of costs that will be reimbursed, and the federal programs that are used in funding the amount of the contract. The information provided to the counties for a GEARS profile will include the federal assistance listing number, as appropriate, and other required information. The counties use the GEARS profile established for the basic county allocation when determining the costs that can be funded and in requesting reimbursement for costs incurred.
As part of our FY 2022-23 audit (report 24-3), we reported that DHS identified both the SSBG and TANF programs as providing funding for the basic county allocation. Because the TANF funds transferred to SSBG are subject to the SSBG requirements, the information DHS provided to the counties inaccurately identified the TANF program as a funding source for the basic county allocation. We recommended DHS update its procedures for contract development to ensure the information provided in its subrecipient contracts identified SSBG as the federal funding source for the basic county allocation of the community aids program related to the transferred TANF funds (Finding 2023-301).
Criteria:
Under 2 CFR s. 200.332, the pass-through entity is required to clearly identify to the subrecipient certain information that allows the subrecipient to understand the federal requirements related to the funding provided. This information includes providing the federal assistance listing number and the amount being provided under the assistance listing number. Under 42 USC s. 604, the transfer of funds from the TANF program to the SSBG program is allowed. Once transferred, the funding is no longer considered TANF funding and is subject to the SSBG requirements. The expenditures incurred with the transferred TANF funds would be considered an expenditure of SSBG.
Condition:
For calendar year 2024 contracts with each county for the administration of the community aids program, DHS identified that both the SSBG and TANF programs were being used to provide funding for the basic county allocation. Although the TANF funds transferred to SSBG are subject to the SSBG requirements, the information DHS provided to the counties, which included the assistance listing number, inaccurately identified the TANF program as a funding source for the basic county allocation.
Because the contracts for calendar year 2024 were entered into prior to the communication of our finding for FY 2022-23 (Finding 2023-301), it was not unexpected to find contracts that continued to identify the incorrect assistance listing number.
Context:
During FY 2023-24, DHS expended $33.3 million in SSBG funds, which included transferred TANF funds, and subawarded $32.3 million. We reviewed 8 of the 72 county contracts that were executed during FY 2023-24 and discussed with DHS staff the steps taken in response to our finding for FY 2022-23 (Finding 2023-301).
Questioned Costs:
None.
Effect:
Because the contracts with the counties did not accurately identify the transferred TANF funds as those from the SSBG program, the counties were not aware of the full amount of SSBG funds received and, as a result, may not be aware of the federal requirements related to this funding. This could result in the counties not complying with federal requirements related to the SSBG funding.
Cause:
In contract development, DHS separately identified the SSBG and transferred TANF funds used in funding the basic county allocation. This separation resulted in the error in identifying TANF as a funding source in the contracts with the counties for the basic county allocation. DHS indicated it has implemented our recommendation from FY 2022-23 (Finding 2023-301) and has updated procedures for contract development to ensure information provided in its subrecipient contracts identify SSBG as the federal funding source for the basic county allocation of the community aids program related to the transferred TANF funds. However, DHS did not complete contract amendments for the calendar year 2024 contracts.
Recommendation:
We recommend the Wisconsin Department of Health Services implement its updated procedures for contract development to ensure information provided in its subrecipient contracts correctly identifies the Social Services Block Grant as the federal funding source for the basic county allocation of the community aids program related to the transferred Temporary Assistance for Needy Families funds.
Finding 2024-302: Social Services Block Grant—Subrecipient Contracts
Social Services Block Grant (Assistance Listing number 93.667)
Award Numbers Award Years
2401WISOSR 2024
2301WISOSR 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Social Services Block Grant—Federal Funding Accountability and Transparency Act Reporting
Background:
DHHS provides funding to DHS for SSBG. This program provides flexible financial assistance to states that allows states to tailor social services programs to the needs of their populations. In addition to general purpose revenue, DHS uses the SSBG funds for the basic county allocation of the community aids program, and it subawards amounts to each county for the administration of this program. DHS also transfers SSBG funds to the Wisconsin Department of Children and Families (DCF). DCF uses the SSBG funds, in addition to other federal funds and general purpose revenue, for the children and family aids program, and it subawards amounts to each county for the administration of this program.
Under the Federal Funding Accountability and Transparency Act (FFATA), a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
As part of our FY 2022-23 audit (report 24-3) we identified that no SSBG-funded subawards had been reported by DHS in the FFATA Subaward Reporting System (FSRS). We recommended that DHS revise its procedures to ensure that all subawards funded by federal grants were included in reports used to identify subawards for reporting, and develop procedures to identify and report subawards made by state agencies to which it had transferred federal funding (Finding 2023-302).
Criteria:
Under 2 CFR s. 170, and as the prime grant awardee for the SSBG program, DHS has overall responsibility for FFATA reporting and is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2023, it must be reported no later than January 31, 2024.
Condition:
During FY 2023-24, both DHS and DCF made subawards of $30,000 or more in SSBG funds to counties. DHS did not report any SSBG-funded subawards in FSRS.
Context:
During FY 2023-24, DHS expended $33.3 million in SSBG funds of which $32.3 million was provided to subrecipients. During FY 2023-24, DCF expended $9.5 million in SSBG funds, of which $7.3 million was provided to subrecipients. We interviewed DHS staff to gain an understanding of the SSBG program, the use of the funds, procedures for compiling and reviewing subaward information, and procedures for submitting this information in FSRS. We further followed up on the status of our prior audit recommendations.
Questioned Costs:
None.
Effect:
As DHS did not comply with FFATA requirements for the reporting of subawards in FSRS for the SSBG program, the State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov for the SSBG program.
Cause:
In report 24-3, we noted that for the subgrants provided under the basic county allocation of the community aids program, DHS initially recorded payments of the amounts it subawarded to counties to a general purpose revenue appropriation. As a result, these subawards were not identified in the reports DHS used to determine FFATA reporting. In addition, DHS did not have procedures in place to obtain information related to the subgrants provided by DCF or to determine whether responsibility for FFATA reporting could be delegated to DCF. In response to our prior audit findings, DHS indicated it updated its procedures related to FFATA reporting. However, reporting of SSBG subawards in FSRS made by both DHS and DCF was not completed in FY 2023-24.
Recommendation:
We recommend the Wisconsin Department of Health Services continue its effort to implement its updated procedures for Federal Funding Accountability and Transparency Act reporting to ensure all Social Services Block Grant subawards are identified and reported.
Finding 2024-303: Social Services Block Grant—Federal Funding Accountability and Transparency Act Reporting
Social Services Block Grant (Assistance Listing number 93.667)
Award Numbers Award Years
2401WISOSR 2024
2301WISOSR 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Rebuttal from the Wisconsin Legislative Audit Bureau: In its corrective action plan on page 349, the Department of Health Services noted that it had adjusted its prior year corrective action plan and successfully submitted all the FY 2023-24 Social Services Block Grant (SSBG) awards to the federal website in July 2024. To assist the reader in understanding the corrective action plan, we offer the following clarification: The July 2024 submission was not timely for amounts awarded under SSBG that were obligated through agreements signed in fall 2023.
Eligibility for the Children’s Health Insurance Program
Background:
The U.S. Department of Health and Human Services (DHHS) provides funding to DHS for CHIP. Funding under this program provides financial assistance to states in maintaining and expanding healthcare coverage to children residing in low-income families. CHIP is funded by both the state and federal government, with the federal portion determined by the enhanced Federal Medical Assistance Percentage (FMAP) rate. Under CHIP, Wisconsin has a separate CHIP program (SCHIP) that provides health insurance to uninsured low-income children as well as certain pregnant women through a postpartum period. Also under CHIP, Wisconsin has a Medicaid expansion program (MCHIP) that expands the State’s MA program and provides enhanced federal participation for targeted low-income children.
DHS partners with local agency caseworkers who are responsible for verifying that CHIP participants meet program eligibility requirements. Caseworkers perform eligibility determination functions, such as obtaining information from the parents or guardians of children applying for health care benefits that is then recorded into the Client Assistance for Reemployment and Economic Support (CARES) system. DHS relies on the CARES system to manage CHIP cases to ensure only eligible participants receive CHIP benefits. Information from the CARES system related to eligible participants is then used by the Medicaid Management Information System (MMIS) to process payments to providers and managed care organizations. During the public health emergency, the federal government required a continuous eligibility period for MA participants.
As part of our FY 2022-23 audit (report 24-3) we identified that DHS maintained continuous eligibility for SCHIP participants who were over age 19, which was not in compliance with federal requirements for this program. We recommended that DHS work with the federal government to resolve these improper payments, including the determination of the total amount of improper payments, and return these amounts to the federal government, as appropriate (Finding 2023-300).
Criteria:
Title XXI of the Social Security Act permits states to establish certain eligibility criteria for CHIP. Per 42 CFR s. 457.320, and following guidelines set forth in 42 USC s. 1397bb (b), DHS established age criteria that permits children under 19 years of age to participate in SCHIP. As a condition of receiving a temporary increase to federal participation under the Families First Coronavirus Response Act, states were required to maintain enrollment of nearly all eligible MA participants. Although this requirement applied to participants determined eligible for MCHIP, it did not apply to SCHIP participants. In guidance issued in January 2021, the Centers for Medicare and Medicaid Services (CMS) further specified that states should not continue to provide coverage under a SCHIP program to participants who did not meet age requirements. At the time a participant reaches age 19, the guidance specifies that states should transition the participant from SCHIP coverage to MA coverage, if eligible.
In response to the public health emergency, DHS also received approval from CMS on August 19, 2020, for an amendment to SCHIP that allowed the State to delay acting on certain changes, beginning March 1, 2020. However, the amendment further stated that changes in circumstances described in 42 CFR s. 457.342 (a) and cross-referenced to 42 CFR s. 935.926 (d) should continue to be acted on, including the circumstance of a child attaining the age of 19.
Condition:
During the public health emergency, and in conflict with federal requirements and the approved state plan, DHS maintained continuous eligibility for SCHIP participants who were over age 19.
The unwinding period, which began on April 1, 2023, is the period after the expiration of the continuous enrollment condition authorized by the Families First Coronavirus Response Act, and includes the process of resuming to normal operations, including restarting full MA and CHIP eligibility renewals and terminations of coverage for ineligible individuals. Throughout FY 2023-24, DHS implemented its unwinding plan and performed redeterminations of eligibility for MA and CHIP participants, including those that exceeded the age requirement for the SCHIP program. The unwinding period ended in June 2024 and DHS resumed normal operations.
Given the number of SCHIP participants identified in the prior audit as exceeding the age requirement, and because the unwinding process was ongoing throughout FY 2023-24, we anticipated that we would continue to identify SCHIP participants who were age 19 and older during FY 2023-24 and that continued to be eligible to receive benefits. During our audit, we identified 4,510 SCHIP participants in the CARES system who were age 19 prior to July 1, 2023. In reviewing ten participants, we note that redeterminations were performed in July or August 2023 for nine of these participants. In each case, eligibility for SCHIP ended. The remaining participant’s eligibility was removed in March 2024. Further, we identified 3,499 participants who turned age 19 between July 1, 2023, and May 31, 2024. We reviewed ten of these participants. For six of the ten reviewed, we found that a timely redetermination was completed and that eligibility was appropriately ended at the end of the month that the participant turned age 19. For the remaining four participants, a redetermination was not completed in a timely manner and eligibility was not removed until a time period after the end of the month that the participant turned age 19.
Context:
During FY 2023-24, DHS expended $224.3 million in federal funds under CHIP, including approximately $121.5 million in federal funds expended to provide benefits to participants under SCHIP.
DHS provided a listing of 102,678 participants identified in the CARES system as an open case in SCHIP between July 1, 2023, and June 30, 2024. Using the birthdate DHS provided, we calculated each participant’s age as of July 1, 2023, and identified a population of those participants who were age 19 prior to FY 2023-24. We further identified a population of participants who turned age 19 during FY 2023-24. We randomly selected ten participants from each population and reviewed CARES information to identify the redetermination date and the date eligibility for SCHIP ended.
Questioned Costs:
Undetermined.
In response to Finding 2023-300, CMS communicated to DHS that CMS can only pursue recovery of costs for eligibility errors when identified under CMS’ Payment Error Rate Measurement program. Therefore, CMS would not pursue recovery associated with the questioned costs we identified for the FY 2022-23 audit finding. Given this response from CMS, we did not calculate questioned costs for the ineligible SCHIP participants for FY 2023-24.
Effect:
DHS maintained eligibility for participants that were not eligible for the SCHIP program, which resulted in improper payments and federal reimbursement for participants who were ineligible.
Cause:
To comply with continuous eligibility requirements, DHS indicated that various changes were made to the CARES system at the start of the public health emergency to ensure that changes in circumstances did not result in terminations unless the member passed away, moved out of state, or voluntarily requested disenrollment. These changes were applied to all MA programs, including programs funded through CHIP. DHS indicated that it chose to maintain continuous eligibility for participants in SCHIP to prioritize and protect the health and safety of the children covered by the program from the loss of access to coverage. DHS indicated that further changes to the CARES system were not pursued in response to the January 2021 CMS guidance.
DHS indicated that as the public health emergency continued, it focused on preparing for the end of the public health emergency. In addition, DHS informed us that discussions with CMS in May 2022 related to concerns with compliance and system limitations did not result in further follow-up from CMS and did not result in system changes to CARES.
During FY 2023-24, DHS performed redeterminations of MA and CHIP participants as part of its unwinding plan. DHS reported that participants who did not meet the age requirements were prioritized in this process.
Recommendation:
We recommend the Wisconsin Department of Health Services continue with efforts to perform redeterminations of eligibility and remove eligibility for Children’s Health Insurance Program participants who exceed the age requirement.
Finding 2024-300: Eligibility for the Children’s Health Insurance Program
Children’s Health Insurance Program (Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: Undetermined
COVID-19—Children’s Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: Undetermined
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the activities allowed or unallowed, allowable costs/cost principles, and eligibility compliance requirements.
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Eligibility for the Children’s Health Insurance Program
Background:
The U.S. Department of Health and Human Services (DHHS) provides funding to DHS for CHIP. Funding under this program provides financial assistance to states in maintaining and expanding healthcare coverage to children residing in low-income families. CHIP is funded by both the state and federal government, with the federal portion determined by the enhanced Federal Medical Assistance Percentage (FMAP) rate. Under CHIP, Wisconsin has a separate CHIP program (SCHIP) that provides health insurance to uninsured low-income children as well as certain pregnant women through a postpartum period. Also under CHIP, Wisconsin has a Medicaid expansion program (MCHIP) that expands the State’s MA program and provides enhanced federal participation for targeted low-income children.
DHS partners with local agency caseworkers who are responsible for verifying that CHIP participants meet program eligibility requirements. Caseworkers perform eligibility determination functions, such as obtaining information from the parents or guardians of children applying for health care benefits that is then recorded into the Client Assistance for Reemployment and Economic Support (CARES) system. DHS relies on the CARES system to manage CHIP cases to ensure only eligible participants receive CHIP benefits. Information from the CARES system related to eligible participants is then used by the Medicaid Management Information System (MMIS) to process payments to providers and managed care organizations. During the public health emergency, the federal government required a continuous eligibility period for MA participants.
As part of our FY 2022-23 audit (report 24-3) we identified that DHS maintained continuous eligibility for SCHIP participants who were over age 19, which was not in compliance with federal requirements for this program. We recommended that DHS work with the federal government to resolve these improper payments, including the determination of the total amount of improper payments, and return these amounts to the federal government, as appropriate (Finding 2023-300).
Criteria:
Title XXI of the Social Security Act permits states to establish certain eligibility criteria for CHIP. Per 42 CFR s. 457.320, and following guidelines set forth in 42 USC s. 1397bb (b), DHS established age criteria that permits children under 19 years of age to participate in SCHIP. As a condition of receiving a temporary increase to federal participation under the Families First Coronavirus Response Act, states were required to maintain enrollment of nearly all eligible MA participants. Although this requirement applied to participants determined eligible for MCHIP, it did not apply to SCHIP participants. In guidance issued in January 2021, the Centers for Medicare and Medicaid Services (CMS) further specified that states should not continue to provide coverage under a SCHIP program to participants who did not meet age requirements. At the time a participant reaches age 19, the guidance specifies that states should transition the participant from SCHIP coverage to MA coverage, if eligible.
In response to the public health emergency, DHS also received approval from CMS on August 19, 2020, for an amendment to SCHIP that allowed the State to delay acting on certain changes, beginning March 1, 2020. However, the amendment further stated that changes in circumstances described in 42 CFR s. 457.342 (a) and cross-referenced to 42 CFR s. 935.926 (d) should continue to be acted on, including the circumstance of a child attaining the age of 19.
Condition:
During the public health emergency, and in conflict with federal requirements and the approved state plan, DHS maintained continuous eligibility for SCHIP participants who were over age 19.
The unwinding period, which began on April 1, 2023, is the period after the expiration of the continuous enrollment condition authorized by the Families First Coronavirus Response Act, and includes the process of resuming to normal operations, including restarting full MA and CHIP eligibility renewals and terminations of coverage for ineligible individuals. Throughout FY 2023-24, DHS implemented its unwinding plan and performed redeterminations of eligibility for MA and CHIP participants, including those that exceeded the age requirement for the SCHIP program. The unwinding period ended in June 2024 and DHS resumed normal operations.
Given the number of SCHIP participants identified in the prior audit as exceeding the age requirement, and because the unwinding process was ongoing throughout FY 2023-24, we anticipated that we would continue to identify SCHIP participants who were age 19 and older during FY 2023-24 and that continued to be eligible to receive benefits. During our audit, we identified 4,510 SCHIP participants in the CARES system who were age 19 prior to July 1, 2023. In reviewing ten participants, we note that redeterminations were performed in July or August 2023 for nine of these participants. In each case, eligibility for SCHIP ended. The remaining participant’s eligibility was removed in March 2024. Further, we identified 3,499 participants who turned age 19 between July 1, 2023, and May 31, 2024. We reviewed ten of these participants. For six of the ten reviewed, we found that a timely redetermination was completed and that eligibility was appropriately ended at the end of the month that the participant turned age 19. For the remaining four participants, a redetermination was not completed in a timely manner and eligibility was not removed until a time period after the end of the month that the participant turned age 19.
Context:
During FY 2023-24, DHS expended $224.3 million in federal funds under CHIP, including approximately $121.5 million in federal funds expended to provide benefits to participants under SCHIP.
DHS provided a listing of 102,678 participants identified in the CARES system as an open case in SCHIP between July 1, 2023, and June 30, 2024. Using the birthdate DHS provided, we calculated each participant’s age as of July 1, 2023, and identified a population of those participants who were age 19 prior to FY 2023-24. We further identified a population of participants who turned age 19 during FY 2023-24. We randomly selected ten participants from each population and reviewed CARES information to identify the redetermination date and the date eligibility for SCHIP ended.
Questioned Costs:
Undetermined.
In response to Finding 2023-300, CMS communicated to DHS that CMS can only pursue recovery of costs for eligibility errors when identified under CMS’ Payment Error Rate Measurement program. Therefore, CMS would not pursue recovery associated with the questioned costs we identified for the FY 2022-23 audit finding. Given this response from CMS, we did not calculate questioned costs for the ineligible SCHIP participants for FY 2023-24.
Effect:
DHS maintained eligibility for participants that were not eligible for the SCHIP program, which resulted in improper payments and federal reimbursement for participants who were ineligible.
Cause:
To comply with continuous eligibility requirements, DHS indicated that various changes were made to the CARES system at the start of the public health emergency to ensure that changes in circumstances did not result in terminations unless the member passed away, moved out of state, or voluntarily requested disenrollment. These changes were applied to all MA programs, including programs funded through CHIP. DHS indicated that it chose to maintain continuous eligibility for participants in SCHIP to prioritize and protect the health and safety of the children covered by the program from the loss of access to coverage. DHS indicated that further changes to the CARES system were not pursued in response to the January 2021 CMS guidance.
DHS indicated that as the public health emergency continued, it focused on preparing for the end of the public health emergency. In addition, DHS informed us that discussions with CMS in May 2022 related to concerns with compliance and system limitations did not result in further follow-up from CMS and did not result in system changes to CARES.
During FY 2023-24, DHS performed redeterminations of MA and CHIP participants as part of its unwinding plan. DHS reported that participants who did not meet the age requirements were prioritized in this process.
Recommendation:
We recommend the Wisconsin Department of Health Services continue with efforts to perform redeterminations of eligibility and remove eligibility for Children’s Health Insurance Program participants who exceed the age requirement.
Finding 2024-300: Eligibility for the Children’s Health Insurance Program
Children’s Health Insurance Program (Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: Undetermined
COVID-19—Children’s Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: Undetermined
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the activities allowed or unallowed, allowable costs/cost principles, and eligibility compliance requirements.
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Background:
DHHS provides funding to DHS for SABG, the ELC grant, the Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response, which DHS refers to as the Public Health Emergency Response grant, and the Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises program, which DHS refers to as the Health Disparities grant. These grants have various health-related purposes. To fulfill the purpose of each grant, DHS subawards funds to various entities, including counties, tribal governments, and other nonprofit organizations. In addition, under the SABG grant, amounts are provided by DHS to DCF and the University of Wisconsin-Madison (UW-Madison), which further subgrant to various entities.
Under FFATA, a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
In our FY 2022-23 audit (report 24-3), we identified that DHS had not accurately reported information in FSRS for several grants. We recommended DHS improve its procedures to accurately report required award information in a timely manner, including the date the subaward agreement was signed, and develop procedures to identify and report subawards made by state agencies to which it had transferred federal funding (Finding 2023-304).
Criteria:
Under 2 CFR s. 170, and as the prime grant awardee for these grants, DHS has overall responsibility for FFATA reporting and is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2023, it must be reported no later than January 31, 2024. The information required to be reported in FSRS includes several key data elements such as information about the recipient, the amount of the award, the project description, and the date the subaward agreement was signed.
Condition:
We selected a total of 34 subawards made by DHS under these grants during FY 2023-24 for testing, and we identified that 28 of the 34 subawards were not reported in a timely manner. We found that 14 of the 20 SABG subawards were not reported in a timely manner. For example, under the SABG grant, ten subawards were reported in August 2024, which was between seven to ten months after the date of the subaward.
In addition, we identified the obligation date was not accurate to within 10 days of the date the subaward agreement was signed for two subawards made under the SABG grant. We also found that none of the ELC, Public Health Emergency Response, and Health Disparities subawards we tested were reported in a timely manner. In addition, we found the project description was not completed accurately for ten subawards, including three for SABG subawards, two for ELC subawards, two for Public Health Emergency Response subawards, and three for Health Disparities subawards. Finally, we found that DHS did not report in FSRS any of the seven subawards DCF made under the SABG grant. DHS also did not report in FSRS the one subaward UW-Madison made under the SABG grant.
Context:
During FY 2023-24, DHS expended:
-$35.1 million under the SABG grant, of which $31.1 million was provided to subrecipients;
-$46.9 million under the ELC grant, of which $9.1 million was provided to subrecipients;
-$14.7 million under the Public Health Emergency Response grant, of which $8.3 million was provided to subrecipients; and
-$7.9 million under the Health Disparities grant, of which $2.6 million was provided to subrecipients.
Under the SABG grant, DCF expended $2.9 million, that was provided to subrecipients. Under the SABG grant, UW-Madison expended $0.2 million that was provided to subrecipients.
We reviewed 20 subawards for the SABG grant, two subawards for the ELC grant, nine for the Public Health Emergency Response grant, and three subawards for the Health Disparities grant that were made by DHS during FY 2023-24. We interviewed DHS staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. To assess if the subawards were reported in an accurate and timely manner, we requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed. We further followed up on the status of our prior audit recommendations.
Questioned Costs:
None.
Effect:
DHS did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS. The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov.
Cause:
In report 24-3, we noted that there were issues with the queries used to obtain information for reporting and procedures did not include obtaining information related to subawards made by other state agencies. During FY 2023-24, queries to retrieve information were established in a new system. However, the procedures in place to review the data produced by the queries and to determine what to report in FSRS were insufficient to ensure accurate and timely reporting. In response to our prior audit finding, DHS reported that it updated its FFATA reporting procedures. However, since the updates were not implemented until late in FY 2023-24, issues continued to be identified in our current audit.
Recommendation:
We recommend the Wisconsin Department of Health Services continue its efforts to implement updated procedures and make future revisions to these procedures for Federal Funding Accountability and Transparency Act reporting to ensure reporting is accurate, complete, and submitted in a timely manner.
Finding 2024-309: Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
COVID-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response (Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response
(Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises
(Assistance Listing number 93.391)
Award Numbers Award Years
1 NH75OT000039-01-00 2021
6 NH75OT000039-01-03 2023
6 NH75OT000039-01-05 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
COVID-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Year
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Background:
DHHS provides funding to DHS for SABG, the ELC grant, the Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response, which DHS refers to as the Public Health Emergency Response grant, and the Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises program, which DHS refers to as the Health Disparities grant. These grants have various health-related purposes. To fulfill the purpose of each grant, DHS subawards funds to various entities, including counties, tribal governments, and other nonprofit organizations. In addition, under the SABG grant, amounts are provided by DHS to DCF and the University of Wisconsin-Madison (UW-Madison), which further subgrant to various entities.
Under FFATA, a publicly available website was created with searchable information on each federal award, including subaward information. This website is known as USAspending.gov. The intent of FFATA is to provide information about federal awards to allow the public access to the information to hold the government accountable for decisions.
In our FY 2022-23 audit (report 24-3), we identified that DHS had not accurately reported information in FSRS for several grants. We recommended DHS improve its procedures to accurately report required award information in a timely manner, including the date the subaward agreement was signed, and develop procedures to identify and report subawards made by state agencies to which it had transferred federal funding (Finding 2023-304).
Criteria:
Under 2 CFR s. 170, and as the prime grant awardee for these grants, DHS has overall responsibility for FFATA reporting and is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2023, it must be reported no later than January 31, 2024. The information required to be reported in FSRS includes several key data elements such as information about the recipient, the amount of the award, the project description, and the date the subaward agreement was signed.
Condition:
We selected a total of 34 subawards made by DHS under these grants during FY 2023-24 for testing, and we identified that 28 of the 34 subawards were not reported in a timely manner. We found that 14 of the 20 SABG subawards were not reported in a timely manner. For example, under the SABG grant, ten subawards were reported in August 2024, which was between seven to ten months after the date of the subaward.
In addition, we identified the obligation date was not accurate to within 10 days of the date the subaward agreement was signed for two subawards made under the SABG grant. We also found that none of the ELC, Public Health Emergency Response, and Health Disparities subawards we tested were reported in a timely manner. In addition, we found the project description was not completed accurately for ten subawards, including three for SABG subawards, two for ELC subawards, two for Public Health Emergency Response subawards, and three for Health Disparities subawards. Finally, we found that DHS did not report in FSRS any of the seven subawards DCF made under the SABG grant. DHS also did not report in FSRS the one subaward UW-Madison made under the SABG grant.
Context:
During FY 2023-24, DHS expended:
-$35.1 million under the SABG grant, of which $31.1 million was provided to subrecipients;
-$46.9 million under the ELC grant, of which $9.1 million was provided to subrecipients;
-$14.7 million under the Public Health Emergency Response grant, of which $8.3 million was provided to subrecipients; and
-$7.9 million under the Health Disparities grant, of which $2.6 million was provided to subrecipients.
Under the SABG grant, DCF expended $2.9 million, that was provided to subrecipients. Under the SABG grant, UW-Madison expended $0.2 million that was provided to subrecipients.
We reviewed 20 subawards for the SABG grant, two subawards for the ELC grant, nine for the Public Health Emergency Response grant, and three subawards for the Health Disparities grant that were made by DHS during FY 2023-24. We interviewed DHS staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. To assess if the subawards were reported in an accurate and timely manner, we requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed. We further followed up on the status of our prior audit recommendations.
Questioned Costs:
None.
Effect:
DHS did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS. The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USAspending.gov.
Cause:
In report 24-3, we noted that there were issues with the queries used to obtain information for reporting and procedures did not include obtaining information related to subawards made by other state agencies. During FY 2023-24, queries to retrieve information were established in a new system. However, the procedures in place to review the data produced by the queries and to determine what to report in FSRS were insufficient to ensure accurate and timely reporting. In response to our prior audit finding, DHS reported that it updated its FFATA reporting procedures. However, since the updates were not implemented until late in FY 2023-24, issues continued to be identified in our current audit.
Recommendation:
We recommend the Wisconsin Department of Health Services continue its efforts to implement updated procedures and make future revisions to these procedures for Federal Funding Accountability and Transparency Act reporting to ensure reporting is accurate, complete, and submitted in a timely manner.
Finding 2024-309: Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
COVID-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response (Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response
(Assistance Listing number 93.354)
Award Number Award Year
6 NU90TP922132-01 2023
Questioned Costs: None
COVID-19—Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises
(Assistance Listing number 93.391)
Award Numbers Award Years
1 NH75OT000039-01-00 2021
6 NH75OT000039-01-03 2023
6 NH75OT000039-01-05 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
COVID-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Year
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Geographic Programs - Great Lakes Restoration Initiative—Federal Financial Reporting
Background:
The DNR receives federal funding from the U.S. Environmental Protection Agency (EPA) for the GLRI program. The objective of the GLRI program is to advance protection and restoration of the Great Lakes Basin Ecosystem through the funding of various projects.
Criteria:
Under 2 CFR s. 200.328, and at least annually, DNR must submit the Federal Financial Report (FFR) to the EPA for each project of the GLRI program. DNR is required to submit annual FFRs no later than 90 calendar days after the project’s reporting period and final FFRs no later than 120 calendar days after the conclusion of the project’s period of performance. The EPA may grant extension of reporting due dates when requested and justified by the recipient.
Condition:
DNR did not submit FFRs in a timely manner for six of the nine annual FFR reports we tested for the GLRI program, and DNR did not request an extension of reporting due dates from the EPA. The six annual FFRs we tested were completed between 17 and 219 calendar days past the due date. For example, four FFRs we tested had a reporting period end date of March 31, 2024, and a report due date of June 29, 2024. DNR filed the annual FFRs on November 1, 2024, which was 125 days past the due date. For five of the six annual FFRs we tested that were late, we noted that DNR submitted the FFRs after our inquiry and request to review the FFRs. For each of the six FFRs, we found that DNR retained documentation to support the amounts included in the reports and the information in the FFRs was accurate.
Context:
During FY 2023-24, DNR expended $15.5 million under the GLRI program. We interviewed DNR staff to gain an understanding of its procedures for preparing FFRs for GLRI projects. During FY 2023-24, DNR was required to submit 20 annual FFRs and 2 final FFRs for GLRI projects to the EPA. We reviewed nine of the annual FFRs and the 2 final FFRs. We requested DNR’s documentation to support the information reported in the FFRs.
Questioned Costs:
None.
Effect:
The EPA did not have timely financial reports to assess DNR’s management of GLRI projects.
Cause:
DNR did not have sufficient procedures in place to track when annual FFRs were required to be submitted for GLRI projects. Although DNR’s procedures require the GLRI program’s grant accountant to monitor FFR due dates, that position was vacant during FY 2023-24 and filled in FY 2024-25. DNR indicated that other grant accountants completed some reporting for the GLRI program, but not all reporting was completed until after we made inquiries of DNR staff in October 2024. DNR staff indicated that they began to implement changes in October 2024 to more effectively track FFR due dates by having DNR’s Management and Grant Accounting Section Chief monitor the FFR reporting schedule.
Recommendation:
We recommend the Wisconsin Department of Natural Resources develop and implement policies and procedures for tracking and submitting timely federal financial reports for the Geographic Programs - Great Lakes Restoration Initiative program.
Finding 2024-800: Geographic Programs - Great Lakes Restoration Initiative—Federal Financial Reporting
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02393 2018
00E02456 2019
00E02487 2019
00E02824 2020
00E02979 2021
00E02975 2021
00E03010 2021
00E03068 2021
03E00712 2022
01E03010 2022
00E03149 2022
00E03187 2022
00E03188 2022
00E03250 2022
00E03252 2022
00E03589 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Natural Resources: The Wisconsin Department of Natural Resources agrees with the audit finding and recommendation.
Geographic Programs - Great Lakes Restoration Initiative—Subrecipient Monitoring
Background:
DNR receives federal funding from the EPA for the GLRI program. The objective of the GLRI program is to advance protection and restoration of the Great Lakes Basin Ecosystem through the funding of various projects. To administer the GLRI program, DNR contracts with subrecipients located around the State, including counties, cities, and sewage districts.
During our FY 2022-23 single audit (report 24-3), we identified that DNR did not perform subrecipient risk assessments or have a plan to monitor subrecipients for the GLRI program based on the risk assessments. Further, DNR did not have sufficient procedures in place to ensure all GLRI subrecipient single audit reports were being obtained and reviewed. We recommended that DNR develop a written monitoring plan for the GLRI program that includes policies and procedures for:
-completing risk assessments for each subrecipient;
-the specific monitoring steps that are required based on the level of subrecipient risk identified in a risk assessment;
-independently identifying and reviewing subrecipient single audit reports, if applicable; and
-maintaining documentation of all subrecipient monitoring activities (Finding 2023-800).
During FY 2023-24, and in response to our recommendations, DNR developed policies and procedures for monitoring and performing risk assessments of the GLRI subrecipients. In addition, DNR developed procedures to ensure GLRI subrecipient single audit reports were being obtained and reviewed. DNR completed its review of these reports in May 2024.
Criteria:
DNR administers federal programs that are subject to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Uniform Guidance includes three requirements related to the monitoring of subrecipients. First, 2 CFR s. 200.332 (a) (1) requires DNR to communicate certain award information to subrecipients at the time of the subaward. Second, 2 CFR s. 200.332 (b) requires DNR to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring. Finally, 2 CFR s. 200.332 (d) through (f) requires DNR to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
An EPA subaward policy further clarifies that the Uniform Guidance provisions are applicable to its grant programs, including a requirement for DNR to establish and follow a system for evaluating the risks of subrecipient noncompliance with laws, regulations, and the terms and conditions of the subaward, as required by 2 CFR ss. 200.332 (b) and (d). This policy also requires DNR to document its evaluations. In addition, EPA’s policy requires that DNR establish and follow a process for deciding whether to impose additional requirements on subrecipients based on the risk assessments.
Condition:
In response to our FY 2023-24 recommendation, in June 2024 DNR developed policies and procedures for monitoring GLRI subrecipients, including procedures for completing a risk assessment for each GLRI subrecipient and ranking each subrecipient based on the risk assessment to determine the level of monitoring needed. However, DNR did not complete risk assessments for any of its GLRI subrecipients during FY 2023-24.
Context:
DNR expended $15.5 million under the GLRI program during FY 2023-24, including $4.0 million that it provided to 21 subrecipients. We interviewed DNR staff to gain an understanding of its procedures for monitoring subrecipients. We reviewed the agreements between DNR and the subrecipients to identify whether DNR had communicated the required award information to them. We also reviewed monitoring activities DNR performed for the GLRI program, including DNR’s process to review subrecipient single audit reports and DNR’s monitoring of subrecipients through progress reporting and reimbursement requests. Finally, we reviewed and discussed with DNR staff the new procedures for completing subrecipient risk assessments.
Questioned Costs:
None.
Effect:
Because DNR did not comply with all subrecipient monitoring compliance requirements for the GLRI program, there is a higher risk that DNR and its GLRI subrecipients are not in compliance with all federal requirements.
Cause:
Although DNR developed policies and procedures for monitoring and performing risk assessments for the GLRI subrecipients, it did not complete risk assessments for the GLRI subrecipients during FY 2023-24. DNR indicated it would implement its policies and procedures for monitoring and performing risk assessments for the GLRI subrecipients as new subawards are created in FY 2024-25. However, DNR should also perform risk assessments for existing GLRI subrecipients to ensure its monitoring of the activities for ongoing GLRI projects is appropriate.
Recommendation:
We recommend the Wisconsin Department of Natural Resources implement its new monitoring policies and procedures for completing risk assessments for each subrecipient of the Geographic Programs - Great Lakes Restoration Initiative program, including for all its existing subrecipients for ongoing projects.
Finding 2024-801: Geographic Programs - Great Lakes Restoration Initiative—Subrecipient Monitoring
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02393 2018
00E02456 2019
00E02490 2019
00E02824 2020
00E02975 2021
00E02979 2021
00E03010 2021
03E00712 2022
01E03010 2022
00E03149 2022
00E03250 2022
00E03252 2022
00E03490 2023
00E03486 2023
00E03589 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Natural Resources: The Wisconsin Department of Natural Resources agrees with the audit finding and recommendation.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Monthly Reconciliations
Background:
UW institutions receive funding for several grant and loan programs, such as Federal Direct Student Loans (Assistance Listing number 84.268) and the Federal Pell Grant Program (Assistance Listing number 84.063), from the U.S. Department of Education that are administered under the SFA Cluster. UW Oshkosh is required to comply with U.S. Department of Education requirements for disbursing funds to students under the Direct Student Loans and Pell Grant programs. This includes reporting disbursement activity in a U.S. Department of Education system in a timely manner. For FY 2023-24, UW-Oshkosh reported federal financial assistance of $29.7 million in Direct Student Loans and $10.3 million in Pell Grants.
Criteria:
Pursuant to 34 CFR s. 685.300 (b) (5), UW-Oshkosh is required to perform monthly reconciliations between U.S. Department of Education systems and its financial and business systems for all Direct Student Loans activity. The monthly reconciliations include two components:
-an external review between UW Oshkosh’s disbursements in its student information system compared to data in a U.S. Department of Education reporting system; and
-an internal reconciliation between UW Oshkosh’s student information system and its accounting system.
In addition, U.S. Department of Education guidance included in Volume 4, Chapter 5, of the Federal Student Aid Handbook, recommends that UW Oshkosh similarly complete monthly reconciliations for Pell Grant activity.
Condition:
Although UW-Oshkosh provided documentation for the external component of reconciliations it completed for the two months we selected to review for the Direct Student Loans and Pell Grant reconciliations during FY 2023 24, it did not provide documentation for the internal component of these reconciliations.
Context:
We reviewed and discussed UW Oshkosh’s procedures for performing monthly reconciliations for Direct Student Loans and Pell Grant disbursements. We selected two monthly Direct Student Loans and Pell Grant reconciliations and reviewed the internal and external reconciliation components for each month.
Questioned Costs:
None.
Effect:
Without documentation, UW-Oshkosh cannot be assured that it accurately completed the required reconciliations to identify whether Direct Student Loans or Pell Grant disbursements were properly reported to the U.S. Department of Education and other federal requirements were being met.
Cause:
UW-Oshkosh indicated that it was unable to locate documentation for the internal component of the reconciliation for the months we requested because the documentation was not retained in a shared folder. In addition, UW Oshkosh indicated that there had been staff turnover in the position that completed the reconciliations.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-ensure all required monthly reconciliations are completed in a timely manner; and
-retain documentation to support all monthly reconciliations it completes.
Finding 2024-700: Student Financial Assistance Cluster—UW-Oshkosh Monthly Reconciliations
Federal Pell Grant Program (Assistance Listing number 84.063)
Award Numbers Award Years
Various Various
Questioned Costs: None
Federal Direct Student Loans (Assistance Listing number 84.268)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-Madison must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. For students that begin attending classes, but who later withdraw from enrollment, 34 CFR s. 668.22 requires that UW-Madison must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In order not to consider a student to have withdrawn from enrollment under certain circumstances, which permits a student to retain federal financial assistance that otherwise would need to be returned to the federal government, 34 CFR s. 668.22 (a) (2) (ii) provides certain exemptions to students.
Condition:
For four students, we found that UW-Madison did not accurately determine the amount of federal financial assistance it disbursed that should have been returned to the U.S. Department of Education. First, we found that UW-Madison did not return all federal financial assistance it disbursed to two students that did not begin attendance and to one student who only attended one day during FY 2023-24. For these three students, UW-Madison determined it failed to return $16,403 in federal financial assistance it disbursed during FY 2023-24. Second, we found that UW-Madison did not accurately determine the federal financial assistance that should be returned after a student withdrew from enrollment during the summer 2023 term. For this student, UW-Madison incorrectly applied an exemption, which led to UW-Madison failing to return $584 in federal financial assistance to the U.S. Department of Education.
Context:
UW-Madison uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Madison staff its process for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Madison to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. When reviewing the data UW-Madison provided, we noted potential errors in the amount of aid returned for students identified as never attending.
Separately, as part of a UW systemwide sample of 60 students, we selected 6 students who had received federal financial assistance and who withdrew from enrollment from UW-Madison to determine the amount of federal financial assistance those students earned and the related amounts UW-Madison returned to the U.S. Department of Education.
Questioned Costs:
$16,987, Plus an Undetermined Amount
Effect:
UW-Madison did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Madison identified that the errors in determining the amount of the federal financial assistance that should have been returned to the federal government for the four students we identified were manual errors in the withdrawal procedures and calculations completed during and at the end of each term. These errors were not detected by any other review procedures. Although UW-Madison correctly identified the status of the two students who never attended and the need to return all disbursed federal financial assistance, it did not follow through on the actual repayment.
For the student who had an exemption applied, the exemption was incorrectly selected when UW-Madison completed a determination, and the error was not detected in UW-Madison’s review process. UW-Madison indicated that its automated review processes conducted at the end of each term did not specifically address the matters we identified for the four students.
After we identified these errors in the determination of the amount of federal financial assistance to return to the federal government, UW-Madison returned in fall 2024 the unearned federal financial assistance for the three students who never attended or withdrew from enrollment after attending one day. In addition, UW Madison returned the additional $584 in February 2025 for the student who withdrew from enrollment and did not meet the criteria for a withdrawal exemption.
Recommendation:
We recommend the University of Wisconsin-Madison review, update, and implement its procedures to improve the accuracy and follow-through for making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including thoroughly reviewing applied exemptions, and returning federal financial assistance in a timely manner to the federal government.
Finding 2024-703: Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,987, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Background:
UW-River Falls receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-River Falls reported a total of $23.6 million in federal financial assistance under the SFA Cluster. UW-River Falls is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-River Falls must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. Under Volume 5, Chapter 1 of the Federal Student Aid Handbook, when a student begins attendance in at least one course but does not begin attendance in all courses the student was scheduled to attend, the school must determine if it is necessary to recalculate the student’s eligibility for the Pell Grant based on a revised enrollment status and the cost of education pursuant to 34 CFR s. 690.80. If the student withdraws, this recalculation must be performed before determining whether to return federal financial assistance pursuant to 34 CFR s. 668.22.
Condition:
We found that UW-River Falls did not return $16,010 in federal financial assistance for four students that did not begin attendance in all enrolled courses during FY 2023-24. This included two students who never began attendance in any enrolled courses for whom all disbursed federal financial assistance was required to be returned. This also included two students who began at least one course but not all courses for which the students had enrolled. UW-River Falls did not perform the required recalculation of Pell Grant eligibility or an assessment of federal financial assistance it had disbursed that these students had not earned.
Context:
UW-River Falls uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-River Falls the process used for identifying students who did not begin attending all enrolled courses or withdrew from enrollment, and we requested a list of such students during FY 2023-24. UW-River Falls did not have a complete list readily available of students who did not begin attending all enrolled courses.
Questioned Costs:
$16,010, Plus an Undetermined Amount
Effect:
UW-River Falls did not comply with all requirements to return federal financial assistance for students who never attended or did not begin attending all enrolled courses during FY 2023-24.
Cause:
UW-River Falls did not have procedures to identify from its student information system, or other sources, those students for whom it disbursed federal financial assistance, yet the students did not attend at least one course during the term or begin all courses enrolled. Depending on whether a student dropped any of their courses, UW-River Falls indicated that the procedures to evaluate attendance may not have identified all students who would ultimately be determined as never attending for the academic term.
After we requested a list of students who did not begin attending all enrolled courses, UW-River Falls identified two students who did not begin at least one course but for whom it had disbursed federal financial assistance. For the other two students who began at least one course, UW-River Falls completed the required Pell Grant recalculation for the students. UW-River Falls also determined the amount of federal financial assistance to return for all four students, as applicable, to the U.S. Department of Education in September 2024.
Recommendation:
We recommend the University of Wisconsin-River Falls review, update, and implement procedures to:
-identify students after the start of each academic term for whom it disbursed federal financial assistance and the students did not begin all enrolled courses;
-complete required recalculations for Pell Grant eligibility and a determination of federal financial assistance that was not earned by the students, as applicable; and
-return amounts to the federal government in a timely manner.
Finding 2024-704: Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,010, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-River Falls: The University of Wisconsin-River Falls agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Background:
UW-Parkside receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Parkside reported a total of $21.3 million in federal financial assistance under the SFA Cluster. UW-Parkside is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22, requires that UW-Parkside must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW Parkside should be returned to the U.S. Department of Education unless certain conditions are met. In determining whether federal financial assistance was earned by a student, the Federal Student Aid Handbook provides guidance on how to calculate applicable institution charges and academic days under different circumstances.
Condition:
For two of three students we reviewed who withdrew from enrollment during FY 2023-24, UW-Parkside inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Parkside incorrectly accounted for a disbursement that occurred after the student’s withdrawal from enrollment as an amount that was earned by the student for the fall 2023 term. As a result, UW Parkside returned $548 less than what should have been returned to the U.S. Department of Education. For the second student, UW-Parkside incorrectly identified the end date of the spring 2024 term and did not include the correct institutional charges in its determination. As a result, UW-Parkside returned $1,190 less than should have been returned to the U.S. Department of Education.
Context:
UW-Parkside uses a student information system to track activity for students that withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Parkside staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from
UW-Parkside to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 3 students who had received federal financial assistance and withdrew from UW-Parkside to determine the amount of federal financial assistance those students earned and the related amounts UW-Parkside returned to the U.S. Department of Education.
Questioned Costs:
$1,738, Plus an Undetermined Amount
Effect:
UW-Parkside did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Parkside did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal assistance to return. Although UW-Parkside disbursed federal financial assistance later than is typical to one student, the disbursement was not correctly categorized within the calculations completed by UW-Parkside to determine that the entire amount of the federal financial assistance was required to be returned to the federal government.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the students we identified.
Finding 2024-705: Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $1,738, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Background:
UW-Platteville receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Platteville reported a total of $29.1 million in federal financial assistance under the SFA Cluster. UW-Platteville is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Under 34 CFR s. 668.21, UW-Platteville must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. In addition, when a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Platteville must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In determining whether federal financial assistance was earned by a student, Volume 5, Chapter 2 of the Federal Student Aid Handbook specifies how to calculate academic days.
Condition:
For two of the five students we reviewed who never began attendance or who withdrew from enrollment during FY 2023-24, UW-Platteville inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Platteville incorrectly determined the student began attendance because the student attended one day of the fall 2023 term. As a result, UW-Platteville failed to return $24 in federal financial assistance to the U.S. Department of Education. For the second student, UW-Platteville did not exclude a five-day break from its determination of the federal financial assistance amount the student had earned during the fall 2023 term. Although this student had earned all of the federal financial assistance prior to the student’s withdrawal from enrollment, UW-Platteville incorrectly returned $1,226. Because UW-Platteville used the same calculation for all determinations for the fall 2023 term, there may be further errors in the federal financial assistance amounts UW-Platteville determined.
Context:
UW-Platteville uses a student information system to track activity for students who withdraw from enrollment in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Platteville staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Platteville to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 5 students who had received federal financial assistance and who withdrew from UW-Platteville to determine the amount of federal financial assistance those students earned and the related amounts UW-Platteville returned to the U.S. Department of Education.
Questioned Costs:
$24, Plus an Undetermined Amount
Effect:
UW-Platteville did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Platteville did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal financial assistance to return to the federal government. After we identified the error for the student who attended only one day, UW-Platteville returned the additional $24 to the federal government in November 2024. For the fall 2023 term, UW-Platteville changed its fall break from four to five days, which required a change in the number of academic days used in the calculation of federal financial assistance earned when a student withdraws from enrollment. UW-Platteville did not have a process to review the academic calendar for purposes of its return procedures.
Recommendation:
We recommend the University of Wisconsin-Platteville review, update, and implement its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including annually reviewing the academic days used in its determinations.
Finding 2024-706: Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $24, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Platteville: The University of Wisconsin-Platteville agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Background:
UW-Whitewater receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Whitewater reported a total of $58.4 million in federal financial assistance under the SFA Cluster. UW-Whitewater is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Whitewater must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook, the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW-Whitewater is required to be returned to the U.S. Department of Education unless certain conditions are met.
Condition:
UW-Whitewater inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education for one of seven students we reviewed who withdrew from enrollment during FY 2023 24. UW-Whitewater incorrectly accounted for a disbursement to the student that occurred after the date for which UW-Whitewater later identified the student had withdrawn from enrollment as an amount that was earned by the student. As a result, UW-Whitewater failed to return $400 in federal financial assistance to the U.S. Department of Education for the spring 2024 term.
Context:
In order to determine the federal financial assistance a student earned and the amount that must be returned to the U.S. Department of Education for amounts a student did not earn, UW-Whitewater uses a student information system to track activity for students who withdraw. We discussed with UW-Whitewater staff the process used for identifying students who withdrew from enrollment. We also requested information from UW-Whitewater to identify students who withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 7 students who had received federal financial assistance and who withdrew from UW-Whitewater to determine the amount of federal financial assistance those students earned and the related amounts UW-Whitewater returned to the U.S. Department of Education.
Questioned Costs:
$400, Plus an Undetermined Amount
Effect:
UW-Whitewater did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Whitewater did not have adequate procedures to review and ensure its determination of the amount of federal assistance to return was accurate. Although UW-Whitewater disbursed federal financial assistance later than is typical to the student, the disbursement was not correctly categorized within the calculations completed by UW-Whitewater nor was the categorization error detected by other
UW-Whitewater procedures.
Recommendation:
We recommend the University of Wisconsin-Whitewater:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the student we identified.
Finding 2024-707: Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $400, Plus an Undetermined Amount
Type of Finding: Noncompliance
Response from the University of Wisconsin-Whitewater: The University of Wisconsin-Whitewater agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Madison is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to the National Student Loan Data System (NSLDS). Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Madison is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time;
-report the same effective date for a student who withdraws from enrollment as the date used in its determination of whether any federal financial assistance must be returned in accordance with
34 CFR s. 668.22;
-report a student who has completed a program with a status of “graduated” rather than “withdrawn”;
-maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed; and
-maintain the program begin date, which is the date the student first began attending the program being reported, if a student’s program of study has not changed.
Condition:
UW-Madison uses the National Student Clearinghouse (NSC) to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Madison that identify potential errors in UW-Madison’s reporting of student activities. It is the responsibility of UW-Madison to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Madison did not report to NSLDS accurate information for 12 of the 17 students we reviewed. First, UW-Madison did not accurately report a student who withdrew from enrollment without notification in a timely manner. Second, UW-Madison incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment. Third, UW-Madison incorrectly reported the program-level enrollment status effective date for two students. Fourth, UW-Madison incorrectly reported the program begin date for six students. In addition, UW Madison incorrectly reported both the program-level enrollment status effective date and program begin date for two students.
Context:
We discussed with UW-Madison staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Madison relies on data from its student information system to compile information to transmit to NSC. UW-Madison also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student that withdrew from UW-Madison and six students who graduated from UW-Madison. In addition, we selected ten additional UW-Madison students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Madison did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Madison did not report to NSLDS who had withdrawn from enrollment without notification, we found UW-Madison’s enrollment reporting procedures did not assign responsibility for communicating certain information to those staff in the registrar’s office who are responsible for NSLDS reporting. As a result, those students the financial aid office determined had withdrawn from enrollment without notification, and for which it had completed a determination of federal financial assistance the students did not earn, were not known to staff in the registrar’s office for purposes of NSLDS reporting. In addition, UW-Madison indicated that withdrawals from enrollment without notification are identified after the term ends and its student information system did not have a dedicated effective date field in order to automatically identify such student records for the required NSLDS reporting.
Second, for the student UW-Madison did not accurately report as graduated within NSLDS, we found UW‑Madison relied on a NSC process that is intended to simultaneously update a student’s enrollment status in NSLDS when UW-Madison separately updates a student’s degree as completed. UW-Madison did not complete a separate report to ensure the enrollment status for graduated students was accurately reflected in NSLDS. However, in 2022 NSC had published information that indicated reliance solely on NSC’s process may result in the incorrect status being reported under certain circumstances. Although NSC error reports identified that such errors were present, UW-Madison indicated that it did not review these errors until fall 2024 when it began implementing new U.S. Department of Education reporting requirements.
At that time, UW-Madison stated that it identified that it did not consistently and accurately report in NSLDS those students who had graduated. UW-Madison stated that it then began to work with NSC to identify the extent of the reporting inaccuracies.
Third, in 2021 NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW-Madison’s data from its student information system and had communicated error or warning codes to UW-Madison in these areas. However, UW-Madison did not sufficiently review whether the records identified by NSC as potential errors resulted in inaccurate reporting. For example, NSC used warning codes for potential errors in the program-level enrollment status effective dates. As warning codes do not prohibit submission of reporting, UW-Madison did not review the warnings.
Fourth, in 2021 NSC similarly published information on accurately reporting student program begin dates in NSLDS and NSC had also identified instances of potential inaccurate reporting in UW Madison’s data from its student information system. Although NSC had communicated error or warning codes to UW-Madison in these areas, UW-Madison had not sufficiently reviewed whether the records identified by NSC as potential errors resulted in inaccurate reporting until 2023. At that time, UW-Madison indicated that, after reviewing other NSC warnings, it identified that it did not accurately report program begin dates for students. UW-Madison indicated it then began to work to update its student information system data extraction process to identify the correct program begin date for its submissions to NSC. However, it did not implement these changes until after the audit period.
In addition, UW-Madison indicated that it had turnover in staff responsible for NSLDS reporting in 2021, which may have caused UW-Madison to have missed the NSC publications regarding reporting graduated students accurately, new warning codes, and the importance of reviewing certain warning codes to accurately complete NSLDS reporting.
Recommendation:
We recommend the University of Wisconsin-Madison:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as updating its student information system to allow for an automated identification process to communicate those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated and implement separate reporting to the National Student Clearinghouse to accurately report students who graduate;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program-level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program begin dates and update its student information system extraction process to accurately report program begin dates; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-708: Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Background:
UW-Milwaukee receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Milwaukee reported a total of $133.1 million in federal financial assistance under the SFA Cluster. UW-Milwaukee records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Milwaukee is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Milwaukee is required to maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed.
Condition:
UW-Milwaukee uses NSC to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Milwaukee that identify potential errors in UW-Milwaukee’s reporting of student activities through NSC. These errors are the responsibility of UW-Milwaukee to resolve to ensure its submissions to NSLDS are accurate and complete.
UW-Milwaukee did not report to NSLDS accurate information for the program level enrollment status effective date for five students we reviewed. In addition, based on how information from its student information system is extracted for student reporting to NSLDS, we found that the reporting inaccuracy extended to other UW-Milwaukee students.
Context:
We discussed with UW-Milwaukee staff its procedures for identifying student enrollment status changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Milwaukee relies on data from its student information system to compile information to transmit to NSC. UW-Milwaukee also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included two students who withdrew from UW-Milwaukee and four students who graduated from UW- Milwaukee. In addition, we selected ten additional UW-Milwaukee students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Milwaukee did not comply with requirements to accurately report certain student enrollment status changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
In 2021, NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW- Milwaukee’s data from its student information system and had communicated error or warning codes to UW-Milwaukee in these areas. UW-Milwaukee staff indicated that they were aware that NSC error reports included warnings to identify potential inaccurate reporting of program level enrollment status effective dates and that the errors were a known issue for Peoplesoft-based student information systems. However, UW-Milwaukee chose not to use an all-record update feature that was available to correct the program-level enrollment status effective dates for all student records simultaneously due to the risk that other reporting inaccuracies could result from the action. Further, UW-Milwaukee staff indicated that they were not aware that specific guidance on the program-level enrollment status effective date had been updated to reflect that corrections should be made to fully comply with NSLDS reporting requirements.
Recommendation:
We recommend the University of Wisconsin-Milwaukee:
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates; and
-report changes in student enrollment accurately, completely, and in a timely manner for all student changes that require reporting.
Finding 2024-709: Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Milwaukee: The University of Wisconsin-Milwaukee agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Background:
UW-Oshkosh receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Oshkosh reported a total of $45.3 million in federal financial assistance under the SFA Cluster. UW-Oshkosh records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Oshkosh is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Oshkosh is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time; and
-report a student who has completed a program with a status of “graduated” rather than “withdrawn.”
Condition:
UW-Oshkosh uses NSC to facilitate the enrollment reporting in NSLDS. NSC provides error reports to UW-Oshkosh that identify potential errors in UW Oshkosh’s reporting of student activities. It is the responsibility of UW-Oshkosh to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Oshkosh did not report to NSLDS accurate information for two of the three students we reviewed.
First, UW-Oshkosh did not report in a timely manner one student who withdrew from enrollment without notification. Second, UW-Oshkosh incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment.
Context:
We discussed with UW-Oshkosh staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and UW Oshkosh’s procedures for monitoring the reporting performed by NSC. UW-Oshkosh relies on data from its student information system to compile information to transmit to NSC. UW-Oshkosh also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve. To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023 24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student who withdrew from UW-Oshkosh and two students who graduated from UW‑Oshkosh.
Questioned Costs:
None.
Effect:
UW-Oshkosh did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Oshkosh did not report to NSLDS in a timely manner who had withdrawn from enrollment without notification, we found that UW-Oshkosh indicated that it believed it needed to report to NSLDS only when students withdrew from enrollment and had notified UW-Oshkosh of the withdrawal. As a result, students detected by UW Oshkosh through procedures completed by the financial aid office at the end of each term were not communicated to those staff in the registrar’s office who were responsible for NSLDS reporting.
Second, for the student UW-Oshkosh did not accurately report as graduated within NSLDS, we found that inaccuracies in the reporting of students who had graduated were noted on NSC error reports. However, UW-Oshkosh’s registrar’s office staff did sufficiently review the errors to correct the status in NSLDS.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as communicating those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-710: Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Background:
UW Parkside operates in a highly computerized environment and is responsible for maintaining confidential and sensitive information, such as student data. UW Parkside maintains its own student information system to administer federal student financial assistance programs under the SFA Cluster.
Criteria:
To ensure data processed and stored by UW-Parkside is protected from accidental or intentional misuse or destruction, and to provide proper internal control, information technology (IT) security policies and procedures are necessary. In addition, IT controls should be established to prevent inappropriate or inadvertent access to data. UW-Parkside is responsible for following specific requirements under the Gramm-Leach-Bliley Act (GLBA), which requires entities that administer student financial assistance programs to develop, implement, and maintain safeguards to protect the security, integrity, and confidentiality of student data.
Under GLBA, UW-Parkside is required to authenticate and permit access only to authorized users. Further, UW Board of Regents Policy 25-5 requires that UW-Parkside follow the National Institute of Standards and Technology (NIST) in establishing IT controls. NIST Special Publication (SP) 800-53, Security and Privacy Controls for Information Systems and Organizations, recommends best practices in IT controls related to user access. These best practices include developing a provisioning and deprovisioning process focused on limiting access in a manner that provides the least access based on business need; retaining documentation of provisioning and deprovisioning activities, including records of when such access was added or removed; and performing periodic reviews of access to ensure it remains appropriate.
Condition:
We found UW-Parkside did not have adequate IT controls in place during FY 2023-24 to provision, deprovision, and manage access to its student information system. First, UW-Parkside did not have a formal documented process to provision or deprovision user access to its student information system. Second, UW-Parkside did not maintain a list of provisioned users with access and was unable to generate a report of users provisioned or deprovisioned during FY 2023-24. Third, UW-Parkside did not complete a periodic review of access, which assists in ensuring its provisioning and deprovisioning processes are working as intended. Although failure in any one IT control may be detected by complementary IT controls, UW‑Parkside did not have effective IT controls in any of the three areas. As a result, UW-Parkside was at a higher risk of granting unauthorized access to its student information system.
Context:
We reviewed GLBA requirements, UW System Board of Regents policies, and NIST 800-53 guidance to identify policies and procedures for UW-Parkside’s monitoring of access granted to its student information system. We requested documentation from UW-Parkside to assess compliance with these policies.
Questioned Costs:
None.
Effect:
Ineffective general IT controls may permit controls over systems to operate improperly and may allow noncompliance to occur and not be detected. Weaknesses in IT security policies, procedures, and controls increase the risk that unauthorized or erroneous transactions could be processed or changes made to student data. In addition, failure to provide an appropriate level of protection for its student information system and data increased the risk that personally identifiable information could be accidentally or maliciously exposed.
Cause:
UW-Parkside did not have a formal policy or procedures in place to provision, deprovision, and review access to its student information system. UW-Parkside staff indicated the process for provisioning and deprovisioning access had been informally operated, such as through electronic mail and direct communication and it did not consistently retain documentation of these communications. For example,
UW-Parkside indicated access requests were accepted from a variety of UW-Parkside employees. As a result, UW-Parkside had not assessed whether a user’s access was necessary or otherwise limited the access only to specific information needed or to a specified time period. Finally, UW-Parkside also indicated that prior efforts to improve its provisioning and deprovisioning of user access were not fully completed or implemented, in part, due to staff turnover.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-develop and implement written procedures for provisioning and deprovisioning user access to its student information system, including specifying those who are authorized to request user access and assigning responsibility to staff to assess access requests to restrict the access only to data needed for a specified period of time;
-retain consistent documentation of its provisioning and deprovisioning activities;
-develop and implement written procedures for a review at least annually of access granted to its student information system; and
-complete an assessment of users who currently have access to its student information system and remove those users who no longer require the access.
Finding 2024-711: Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-Madison must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. For students that begin attending classes, but who later withdraw from enrollment, 34 CFR s. 668.22 requires that UW-Madison must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In order not to consider a student to have withdrawn from enrollment under certain circumstances, which permits a student to retain federal financial assistance that otherwise would need to be returned to the federal government, 34 CFR s. 668.22 (a) (2) (ii) provides certain exemptions to students.
Condition:
For four students, we found that UW-Madison did not accurately determine the amount of federal financial assistance it disbursed that should have been returned to the U.S. Department of Education. First, we found that UW-Madison did not return all federal financial assistance it disbursed to two students that did not begin attendance and to one student who only attended one day during FY 2023-24. For these three students, UW-Madison determined it failed to return $16,403 in federal financial assistance it disbursed during FY 2023-24. Second, we found that UW-Madison did not accurately determine the federal financial assistance that should be returned after a student withdrew from enrollment during the summer 2023 term. For this student, UW-Madison incorrectly applied an exemption, which led to UW-Madison failing to return $584 in federal financial assistance to the U.S. Department of Education.
Context:
UW-Madison uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Madison staff its process for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Madison to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. When reviewing the data UW-Madison provided, we noted potential errors in the amount of aid returned for students identified as never attending.
Separately, as part of a UW systemwide sample of 60 students, we selected 6 students who had received federal financial assistance and who withdrew from enrollment from UW-Madison to determine the amount of federal financial assistance those students earned and the related amounts UW-Madison returned to the U.S. Department of Education.
Questioned Costs:
$16,987, Plus an Undetermined Amount
Effect:
UW-Madison did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Madison identified that the errors in determining the amount of the federal financial assistance that should have been returned to the federal government for the four students we identified were manual errors in the withdrawal procedures and calculations completed during and at the end of each term. These errors were not detected by any other review procedures. Although UW-Madison correctly identified the status of the two students who never attended and the need to return all disbursed federal financial assistance, it did not follow through on the actual repayment.
For the student who had an exemption applied, the exemption was incorrectly selected when UW-Madison completed a determination, and the error was not detected in UW-Madison’s review process. UW-Madison indicated that its automated review processes conducted at the end of each term did not specifically address the matters we identified for the four students.
After we identified these errors in the determination of the amount of federal financial assistance to return to the federal government, UW-Madison returned in fall 2024 the unearned federal financial assistance for the three students who never attended or withdrew from enrollment after attending one day. In addition, UW Madison returned the additional $584 in February 2025 for the student who withdrew from enrollment and did not meet the criteria for a withdrawal exemption.
Recommendation:
We recommend the University of Wisconsin-Madison review, update, and implement its procedures to improve the accuracy and follow-through for making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including thoroughly reviewing applied exemptions, and returning federal financial assistance in a timely manner to the federal government.
Finding 2024-703: Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,987, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Background:
UW-River Falls receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-River Falls reported a total of $23.6 million in federal financial assistance under the SFA Cluster. UW-River Falls is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-River Falls must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. Under Volume 5, Chapter 1 of the Federal Student Aid Handbook, when a student begins attendance in at least one course but does not begin attendance in all courses the student was scheduled to attend, the school must determine if it is necessary to recalculate the student’s eligibility for the Pell Grant based on a revised enrollment status and the cost of education pursuant to 34 CFR s. 690.80. If the student withdraws, this recalculation must be performed before determining whether to return federal financial assistance pursuant to 34 CFR s. 668.22.
Condition:
We found that UW-River Falls did not return $16,010 in federal financial assistance for four students that did not begin attendance in all enrolled courses during FY 2023-24. This included two students who never began attendance in any enrolled courses for whom all disbursed federal financial assistance was required to be returned. This also included two students who began at least one course but not all courses for which the students had enrolled. UW-River Falls did not perform the required recalculation of Pell Grant eligibility or an assessment of federal financial assistance it had disbursed that these students had not earned.
Context:
UW-River Falls uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-River Falls the process used for identifying students who did not begin attending all enrolled courses or withdrew from enrollment, and we requested a list of such students during FY 2023-24. UW-River Falls did not have a complete list readily available of students who did not begin attending all enrolled courses.
Questioned Costs:
$16,010, Plus an Undetermined Amount
Effect:
UW-River Falls did not comply with all requirements to return federal financial assistance for students who never attended or did not begin attending all enrolled courses during FY 2023-24.
Cause:
UW-River Falls did not have procedures to identify from its student information system, or other sources, those students for whom it disbursed federal financial assistance, yet the students did not attend at least one course during the term or begin all courses enrolled. Depending on whether a student dropped any of their courses, UW-River Falls indicated that the procedures to evaluate attendance may not have identified all students who would ultimately be determined as never attending for the academic term.
After we requested a list of students who did not begin attending all enrolled courses, UW-River Falls identified two students who did not begin at least one course but for whom it had disbursed federal financial assistance. For the other two students who began at least one course, UW-River Falls completed the required Pell Grant recalculation for the students. UW-River Falls also determined the amount of federal financial assistance to return for all four students, as applicable, to the U.S. Department of Education in September 2024.
Recommendation:
We recommend the University of Wisconsin-River Falls review, update, and implement procedures to:
-identify students after the start of each academic term for whom it disbursed federal financial assistance and the students did not begin all enrolled courses;
-complete required recalculations for Pell Grant eligibility and a determination of federal financial assistance that was not earned by the students, as applicable; and
-return amounts to the federal government in a timely manner.
Finding 2024-704: Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,010, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-River Falls: The University of Wisconsin-River Falls agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Background:
UW-Parkside receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Parkside reported a total of $21.3 million in federal financial assistance under the SFA Cluster. UW-Parkside is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22, requires that UW-Parkside must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW Parkside should be returned to the U.S. Department of Education unless certain conditions are met. In determining whether federal financial assistance was earned by a student, the Federal Student Aid Handbook provides guidance on how to calculate applicable institution charges and academic days under different circumstances.
Condition:
For two of three students we reviewed who withdrew from enrollment during FY 2023-24, UW-Parkside inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Parkside incorrectly accounted for a disbursement that occurred after the student’s withdrawal from enrollment as an amount that was earned by the student for the fall 2023 term. As a result, UW Parkside returned $548 less than what should have been returned to the U.S. Department of Education. For the second student, UW-Parkside incorrectly identified the end date of the spring 2024 term and did not include the correct institutional charges in its determination. As a result, UW-Parkside returned $1,190 less than should have been returned to the U.S. Department of Education.
Context:
UW-Parkside uses a student information system to track activity for students that withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Parkside staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from
UW-Parkside to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 3 students who had received federal financial assistance and withdrew from UW-Parkside to determine the amount of federal financial assistance those students earned and the related amounts UW-Parkside returned to the U.S. Department of Education.
Questioned Costs:
$1,738, Plus an Undetermined Amount
Effect:
UW-Parkside did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Parkside did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal assistance to return. Although UW-Parkside disbursed federal financial assistance later than is typical to one student, the disbursement was not correctly categorized within the calculations completed by UW-Parkside to determine that the entire amount of the federal financial assistance was required to be returned to the federal government.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the students we identified.
Finding 2024-705: Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $1,738, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Background:
UW-Platteville receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Platteville reported a total of $29.1 million in federal financial assistance under the SFA Cluster. UW-Platteville is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Under 34 CFR s. 668.21, UW-Platteville must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. In addition, when a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Platteville must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In determining whether federal financial assistance was earned by a student, Volume 5, Chapter 2 of the Federal Student Aid Handbook specifies how to calculate academic days.
Condition:
For two of the five students we reviewed who never began attendance or who withdrew from enrollment during FY 2023-24, UW-Platteville inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Platteville incorrectly determined the student began attendance because the student attended one day of the fall 2023 term. As a result, UW-Platteville failed to return $24 in federal financial assistance to the U.S. Department of Education. For the second student, UW-Platteville did not exclude a five-day break from its determination of the federal financial assistance amount the student had earned during the fall 2023 term. Although this student had earned all of the federal financial assistance prior to the student’s withdrawal from enrollment, UW-Platteville incorrectly returned $1,226. Because UW-Platteville used the same calculation for all determinations for the fall 2023 term, there may be further errors in the federal financial assistance amounts UW-Platteville determined.
Context:
UW-Platteville uses a student information system to track activity for students who withdraw from enrollment in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Platteville staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Platteville to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 5 students who had received federal financial assistance and who withdrew from UW-Platteville to determine the amount of federal financial assistance those students earned and the related amounts UW-Platteville returned to the U.S. Department of Education.
Questioned Costs:
$24, Plus an Undetermined Amount
Effect:
UW-Platteville did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Platteville did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal financial assistance to return to the federal government. After we identified the error for the student who attended only one day, UW-Platteville returned the additional $24 to the federal government in November 2024. For the fall 2023 term, UW-Platteville changed its fall break from four to five days, which required a change in the number of academic days used in the calculation of federal financial assistance earned when a student withdraws from enrollment. UW-Platteville did not have a process to review the academic calendar for purposes of its return procedures.
Recommendation:
We recommend the University of Wisconsin-Platteville review, update, and implement its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including annually reviewing the academic days used in its determinations.
Finding 2024-706: Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $24, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Platteville: The University of Wisconsin-Platteville agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Background:
UW-Whitewater receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Whitewater reported a total of $58.4 million in federal financial assistance under the SFA Cluster. UW-Whitewater is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Whitewater must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook, the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW-Whitewater is required to be returned to the U.S. Department of Education unless certain conditions are met.
Condition:
UW-Whitewater inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education for one of seven students we reviewed who withdrew from enrollment during FY 2023 24. UW-Whitewater incorrectly accounted for a disbursement to the student that occurred after the date for which UW-Whitewater later identified the student had withdrawn from enrollment as an amount that was earned by the student. As a result, UW-Whitewater failed to return $400 in federal financial assistance to the U.S. Department of Education for the spring 2024 term.
Context:
In order to determine the federal financial assistance a student earned and the amount that must be returned to the U.S. Department of Education for amounts a student did not earn, UW-Whitewater uses a student information system to track activity for students who withdraw. We discussed with UW-Whitewater staff the process used for identifying students who withdrew from enrollment. We also requested information from UW-Whitewater to identify students who withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 7 students who had received federal financial assistance and who withdrew from UW-Whitewater to determine the amount of federal financial assistance those students earned and the related amounts UW-Whitewater returned to the U.S. Department of Education.
Questioned Costs:
$400, Plus an Undetermined Amount
Effect:
UW-Whitewater did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Whitewater did not have adequate procedures to review and ensure its determination of the amount of federal assistance to return was accurate. Although UW-Whitewater disbursed federal financial assistance later than is typical to the student, the disbursement was not correctly categorized within the calculations completed by UW-Whitewater nor was the categorization error detected by other
UW-Whitewater procedures.
Recommendation:
We recommend the University of Wisconsin-Whitewater:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the student we identified.
Finding 2024-707: Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $400, Plus an Undetermined Amount
Type of Finding: Noncompliance
Response from the University of Wisconsin-Whitewater: The University of Wisconsin-Whitewater agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Madison is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to the National Student Loan Data System (NSLDS). Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Madison is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time;
-report the same effective date for a student who withdraws from enrollment as the date used in its determination of whether any federal financial assistance must be returned in accordance with
34 CFR s. 668.22;
-report a student who has completed a program with a status of “graduated” rather than “withdrawn”;
-maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed; and
-maintain the program begin date, which is the date the student first began attending the program being reported, if a student’s program of study has not changed.
Condition:
UW-Madison uses the National Student Clearinghouse (NSC) to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Madison that identify potential errors in UW-Madison’s reporting of student activities. It is the responsibility of UW-Madison to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Madison did not report to NSLDS accurate information for 12 of the 17 students we reviewed. First, UW-Madison did not accurately report a student who withdrew from enrollment without notification in a timely manner. Second, UW-Madison incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment. Third, UW-Madison incorrectly reported the program-level enrollment status effective date for two students. Fourth, UW-Madison incorrectly reported the program begin date for six students. In addition, UW Madison incorrectly reported both the program-level enrollment status effective date and program begin date for two students.
Context:
We discussed with UW-Madison staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Madison relies on data from its student information system to compile information to transmit to NSC. UW-Madison also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student that withdrew from UW-Madison and six students who graduated from UW-Madison. In addition, we selected ten additional UW-Madison students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Madison did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Madison did not report to NSLDS who had withdrawn from enrollment without notification, we found UW-Madison’s enrollment reporting procedures did not assign responsibility for communicating certain information to those staff in the registrar’s office who are responsible for NSLDS reporting. As a result, those students the financial aid office determined had withdrawn from enrollment without notification, and for which it had completed a determination of federal financial assistance the students did not earn, were not known to staff in the registrar’s office for purposes of NSLDS reporting. In addition, UW-Madison indicated that withdrawals from enrollment without notification are identified after the term ends and its student information system did not have a dedicated effective date field in order to automatically identify such student records for the required NSLDS reporting.
Second, for the student UW-Madison did not accurately report as graduated within NSLDS, we found UW‑Madison relied on a NSC process that is intended to simultaneously update a student’s enrollment status in NSLDS when UW-Madison separately updates a student’s degree as completed. UW-Madison did not complete a separate report to ensure the enrollment status for graduated students was accurately reflected in NSLDS. However, in 2022 NSC had published information that indicated reliance solely on NSC’s process may result in the incorrect status being reported under certain circumstances. Although NSC error reports identified that such errors were present, UW-Madison indicated that it did not review these errors until fall 2024 when it began implementing new U.S. Department of Education reporting requirements.
At that time, UW-Madison stated that it identified that it did not consistently and accurately report in NSLDS those students who had graduated. UW-Madison stated that it then began to work with NSC to identify the extent of the reporting inaccuracies.
Third, in 2021 NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW-Madison’s data from its student information system and had communicated error or warning codes to UW-Madison in these areas. However, UW-Madison did not sufficiently review whether the records identified by NSC as potential errors resulted in inaccurate reporting. For example, NSC used warning codes for potential errors in the program-level enrollment status effective dates. As warning codes do not prohibit submission of reporting, UW-Madison did not review the warnings.
Fourth, in 2021 NSC similarly published information on accurately reporting student program begin dates in NSLDS and NSC had also identified instances of potential inaccurate reporting in UW Madison’s data from its student information system. Although NSC had communicated error or warning codes to UW-Madison in these areas, UW-Madison had not sufficiently reviewed whether the records identified by NSC as potential errors resulted in inaccurate reporting until 2023. At that time, UW-Madison indicated that, after reviewing other NSC warnings, it identified that it did not accurately report program begin dates for students. UW-Madison indicated it then began to work to update its student information system data extraction process to identify the correct program begin date for its submissions to NSC. However, it did not implement these changes until after the audit period.
In addition, UW-Madison indicated that it had turnover in staff responsible for NSLDS reporting in 2021, which may have caused UW-Madison to have missed the NSC publications regarding reporting graduated students accurately, new warning codes, and the importance of reviewing certain warning codes to accurately complete NSLDS reporting.
Recommendation:
We recommend the University of Wisconsin-Madison:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as updating its student information system to allow for an automated identification process to communicate those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated and implement separate reporting to the National Student Clearinghouse to accurately report students who graduate;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program-level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program begin dates and update its student information system extraction process to accurately report program begin dates; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-708: Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Background:
UW-Milwaukee receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Milwaukee reported a total of $133.1 million in federal financial assistance under the SFA Cluster. UW-Milwaukee records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Milwaukee is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Milwaukee is required to maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed.
Condition:
UW-Milwaukee uses NSC to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Milwaukee that identify potential errors in UW-Milwaukee’s reporting of student activities through NSC. These errors are the responsibility of UW-Milwaukee to resolve to ensure its submissions to NSLDS are accurate and complete.
UW-Milwaukee did not report to NSLDS accurate information for the program level enrollment status effective date for five students we reviewed. In addition, based on how information from its student information system is extracted for student reporting to NSLDS, we found that the reporting inaccuracy extended to other UW-Milwaukee students.
Context:
We discussed with UW-Milwaukee staff its procedures for identifying student enrollment status changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Milwaukee relies on data from its student information system to compile information to transmit to NSC. UW-Milwaukee also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included two students who withdrew from UW-Milwaukee and four students who graduated from UW- Milwaukee. In addition, we selected ten additional UW-Milwaukee students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Milwaukee did not comply with requirements to accurately report certain student enrollment status changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
In 2021, NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW- Milwaukee’s data from its student information system and had communicated error or warning codes to UW-Milwaukee in these areas. UW-Milwaukee staff indicated that they were aware that NSC error reports included warnings to identify potential inaccurate reporting of program level enrollment status effective dates and that the errors were a known issue for Peoplesoft-based student information systems. However, UW-Milwaukee chose not to use an all-record update feature that was available to correct the program-level enrollment status effective dates for all student records simultaneously due to the risk that other reporting inaccuracies could result from the action. Further, UW-Milwaukee staff indicated that they were not aware that specific guidance on the program-level enrollment status effective date had been updated to reflect that corrections should be made to fully comply with NSLDS reporting requirements.
Recommendation:
We recommend the University of Wisconsin-Milwaukee:
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates; and
-report changes in student enrollment accurately, completely, and in a timely manner for all student changes that require reporting.
Finding 2024-709: Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Milwaukee: The University of Wisconsin-Milwaukee agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Background:
UW-Oshkosh receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Oshkosh reported a total of $45.3 million in federal financial assistance under the SFA Cluster. UW-Oshkosh records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Oshkosh is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Oshkosh is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time; and
-report a student who has completed a program with a status of “graduated” rather than “withdrawn.”
Condition:
UW-Oshkosh uses NSC to facilitate the enrollment reporting in NSLDS. NSC provides error reports to UW-Oshkosh that identify potential errors in UW Oshkosh’s reporting of student activities. It is the responsibility of UW-Oshkosh to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Oshkosh did not report to NSLDS accurate information for two of the three students we reviewed.
First, UW-Oshkosh did not report in a timely manner one student who withdrew from enrollment without notification. Second, UW-Oshkosh incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment.
Context:
We discussed with UW-Oshkosh staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and UW Oshkosh’s procedures for monitoring the reporting performed by NSC. UW-Oshkosh relies on data from its student information system to compile information to transmit to NSC. UW-Oshkosh also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve. To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023 24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student who withdrew from UW-Oshkosh and two students who graduated from UW‑Oshkosh.
Questioned Costs:
None.
Effect:
UW-Oshkosh did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Oshkosh did not report to NSLDS in a timely manner who had withdrawn from enrollment without notification, we found that UW-Oshkosh indicated that it believed it needed to report to NSLDS only when students withdrew from enrollment and had notified UW-Oshkosh of the withdrawal. As a result, students detected by UW Oshkosh through procedures completed by the financial aid office at the end of each term were not communicated to those staff in the registrar’s office who were responsible for NSLDS reporting.
Second, for the student UW-Oshkosh did not accurately report as graduated within NSLDS, we found that inaccuracies in the reporting of students who had graduated were noted on NSC error reports. However, UW-Oshkosh’s registrar’s office staff did sufficiently review the errors to correct the status in NSLDS.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as communicating those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-710: Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Background:
UW Parkside operates in a highly computerized environment and is responsible for maintaining confidential and sensitive information, such as student data. UW Parkside maintains its own student information system to administer federal student financial assistance programs under the SFA Cluster.
Criteria:
To ensure data processed and stored by UW-Parkside is protected from accidental or intentional misuse or destruction, and to provide proper internal control, information technology (IT) security policies and procedures are necessary. In addition, IT controls should be established to prevent inappropriate or inadvertent access to data. UW-Parkside is responsible for following specific requirements under the Gramm-Leach-Bliley Act (GLBA), which requires entities that administer student financial assistance programs to develop, implement, and maintain safeguards to protect the security, integrity, and confidentiality of student data.
Under GLBA, UW-Parkside is required to authenticate and permit access only to authorized users. Further, UW Board of Regents Policy 25-5 requires that UW-Parkside follow the National Institute of Standards and Technology (NIST) in establishing IT controls. NIST Special Publication (SP) 800-53, Security and Privacy Controls for Information Systems and Organizations, recommends best practices in IT controls related to user access. These best practices include developing a provisioning and deprovisioning process focused on limiting access in a manner that provides the least access based on business need; retaining documentation of provisioning and deprovisioning activities, including records of when such access was added or removed; and performing periodic reviews of access to ensure it remains appropriate.
Condition:
We found UW-Parkside did not have adequate IT controls in place during FY 2023-24 to provision, deprovision, and manage access to its student information system. First, UW-Parkside did not have a formal documented process to provision or deprovision user access to its student information system. Second, UW-Parkside did not maintain a list of provisioned users with access and was unable to generate a report of users provisioned or deprovisioned during FY 2023-24. Third, UW-Parkside did not complete a periodic review of access, which assists in ensuring its provisioning and deprovisioning processes are working as intended. Although failure in any one IT control may be detected by complementary IT controls, UW‑Parkside did not have effective IT controls in any of the three areas. As a result, UW-Parkside was at a higher risk of granting unauthorized access to its student information system.
Context:
We reviewed GLBA requirements, UW System Board of Regents policies, and NIST 800-53 guidance to identify policies and procedures for UW-Parkside’s monitoring of access granted to its student information system. We requested documentation from UW-Parkside to assess compliance with these policies.
Questioned Costs:
None.
Effect:
Ineffective general IT controls may permit controls over systems to operate improperly and may allow noncompliance to occur and not be detected. Weaknesses in IT security policies, procedures, and controls increase the risk that unauthorized or erroneous transactions could be processed or changes made to student data. In addition, failure to provide an appropriate level of protection for its student information system and data increased the risk that personally identifiable information could be accidentally or maliciously exposed.
Cause:
UW-Parkside did not have a formal policy or procedures in place to provision, deprovision, and review access to its student information system. UW-Parkside staff indicated the process for provisioning and deprovisioning access had been informally operated, such as through electronic mail and direct communication and it did not consistently retain documentation of these communications. For example,
UW-Parkside indicated access requests were accepted from a variety of UW-Parkside employees. As a result, UW-Parkside had not assessed whether a user’s access was necessary or otherwise limited the access only to specific information needed or to a specified time period. Finally, UW-Parkside also indicated that prior efforts to improve its provisioning and deprovisioning of user access were not fully completed or implemented, in part, due to staff turnover.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-develop and implement written procedures for provisioning and deprovisioning user access to its student information system, including specifying those who are authorized to request user access and assigning responsibility to staff to assess access requests to restrict the access only to data needed for a specified period of time;
-retain consistent documentation of its provisioning and deprovisioning activities;
-develop and implement written procedures for a review at least annually of access granted to its student information system; and
-complete an assessment of users who currently have access to its student information system and remove those users who no longer require the access.
Finding 2024-711: Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-Madison must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. For students that begin attending classes, but who later withdraw from enrollment, 34 CFR s. 668.22 requires that UW-Madison must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In order not to consider a student to have withdrawn from enrollment under certain circumstances, which permits a student to retain federal financial assistance that otherwise would need to be returned to the federal government, 34 CFR s. 668.22 (a) (2) (ii) provides certain exemptions to students.
Condition:
For four students, we found that UW-Madison did not accurately determine the amount of federal financial assistance it disbursed that should have been returned to the U.S. Department of Education. First, we found that UW-Madison did not return all federal financial assistance it disbursed to two students that did not begin attendance and to one student who only attended one day during FY 2023-24. For these three students, UW-Madison determined it failed to return $16,403 in federal financial assistance it disbursed during FY 2023-24. Second, we found that UW-Madison did not accurately determine the federal financial assistance that should be returned after a student withdrew from enrollment during the summer 2023 term. For this student, UW-Madison incorrectly applied an exemption, which led to UW-Madison failing to return $584 in federal financial assistance to the U.S. Department of Education.
Context:
UW-Madison uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Madison staff its process for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Madison to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. When reviewing the data UW-Madison provided, we noted potential errors in the amount of aid returned for students identified as never attending.
Separately, as part of a UW systemwide sample of 60 students, we selected 6 students who had received federal financial assistance and who withdrew from enrollment from UW-Madison to determine the amount of federal financial assistance those students earned and the related amounts UW-Madison returned to the U.S. Department of Education.
Questioned Costs:
$16,987, Plus an Undetermined Amount
Effect:
UW-Madison did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Madison identified that the errors in determining the amount of the federal financial assistance that should have been returned to the federal government for the four students we identified were manual errors in the withdrawal procedures and calculations completed during and at the end of each term. These errors were not detected by any other review procedures. Although UW-Madison correctly identified the status of the two students who never attended and the need to return all disbursed federal financial assistance, it did not follow through on the actual repayment.
For the student who had an exemption applied, the exemption was incorrectly selected when UW-Madison completed a determination, and the error was not detected in UW-Madison’s review process. UW-Madison indicated that its automated review processes conducted at the end of each term did not specifically address the matters we identified for the four students.
After we identified these errors in the determination of the amount of federal financial assistance to return to the federal government, UW-Madison returned in fall 2024 the unearned federal financial assistance for the three students who never attended or withdrew from enrollment after attending one day. In addition, UW Madison returned the additional $584 in February 2025 for the student who withdrew from enrollment and did not meet the criteria for a withdrawal exemption.
Recommendation:
We recommend the University of Wisconsin-Madison review, update, and implement its procedures to improve the accuracy and follow-through for making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including thoroughly reviewing applied exemptions, and returning federal financial assistance in a timely manner to the federal government.
Finding 2024-703: Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,987, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Background:
UW-River Falls receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-River Falls reported a total of $23.6 million in federal financial assistance under the SFA Cluster. UW-River Falls is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-River Falls must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. Under Volume 5, Chapter 1 of the Federal Student Aid Handbook, when a student begins attendance in at least one course but does not begin attendance in all courses the student was scheduled to attend, the school must determine if it is necessary to recalculate the student’s eligibility for the Pell Grant based on a revised enrollment status and the cost of education pursuant to 34 CFR s. 690.80. If the student withdraws, this recalculation must be performed before determining whether to return federal financial assistance pursuant to 34 CFR s. 668.22.
Condition:
We found that UW-River Falls did not return $16,010 in federal financial assistance for four students that did not begin attendance in all enrolled courses during FY 2023-24. This included two students who never began attendance in any enrolled courses for whom all disbursed federal financial assistance was required to be returned. This also included two students who began at least one course but not all courses for which the students had enrolled. UW-River Falls did not perform the required recalculation of Pell Grant eligibility or an assessment of federal financial assistance it had disbursed that these students had not earned.
Context:
UW-River Falls uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-River Falls the process used for identifying students who did not begin attending all enrolled courses or withdrew from enrollment, and we requested a list of such students during FY 2023-24. UW-River Falls did not have a complete list readily available of students who did not begin attending all enrolled courses.
Questioned Costs:
$16,010, Plus an Undetermined Amount
Effect:
UW-River Falls did not comply with all requirements to return federal financial assistance for students who never attended or did not begin attending all enrolled courses during FY 2023-24.
Cause:
UW-River Falls did not have procedures to identify from its student information system, or other sources, those students for whom it disbursed federal financial assistance, yet the students did not attend at least one course during the term or begin all courses enrolled. Depending on whether a student dropped any of their courses, UW-River Falls indicated that the procedures to evaluate attendance may not have identified all students who would ultimately be determined as never attending for the academic term.
After we requested a list of students who did not begin attending all enrolled courses, UW-River Falls identified two students who did not begin at least one course but for whom it had disbursed federal financial assistance. For the other two students who began at least one course, UW-River Falls completed the required Pell Grant recalculation for the students. UW-River Falls also determined the amount of federal financial assistance to return for all four students, as applicable, to the U.S. Department of Education in September 2024.
Recommendation:
We recommend the University of Wisconsin-River Falls review, update, and implement procedures to:
-identify students after the start of each academic term for whom it disbursed federal financial assistance and the students did not begin all enrolled courses;
-complete required recalculations for Pell Grant eligibility and a determination of federal financial assistance that was not earned by the students, as applicable; and
-return amounts to the federal government in a timely manner.
Finding 2024-704: Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,010, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-River Falls: The University of Wisconsin-River Falls agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Background:
UW-Parkside receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Parkside reported a total of $21.3 million in federal financial assistance under the SFA Cluster. UW-Parkside is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22, requires that UW-Parkside must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW Parkside should be returned to the U.S. Department of Education unless certain conditions are met. In determining whether federal financial assistance was earned by a student, the Federal Student Aid Handbook provides guidance on how to calculate applicable institution charges and academic days under different circumstances.
Condition:
For two of three students we reviewed who withdrew from enrollment during FY 2023-24, UW-Parkside inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Parkside incorrectly accounted for a disbursement that occurred after the student’s withdrawal from enrollment as an amount that was earned by the student for the fall 2023 term. As a result, UW Parkside returned $548 less than what should have been returned to the U.S. Department of Education. For the second student, UW-Parkside incorrectly identified the end date of the spring 2024 term and did not include the correct institutional charges in its determination. As a result, UW-Parkside returned $1,190 less than should have been returned to the U.S. Department of Education.
Context:
UW-Parkside uses a student information system to track activity for students that withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Parkside staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from
UW-Parkside to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 3 students who had received federal financial assistance and withdrew from UW-Parkside to determine the amount of federal financial assistance those students earned and the related amounts UW-Parkside returned to the U.S. Department of Education.
Questioned Costs:
$1,738, Plus an Undetermined Amount
Effect:
UW-Parkside did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Parkside did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal assistance to return. Although UW-Parkside disbursed federal financial assistance later than is typical to one student, the disbursement was not correctly categorized within the calculations completed by UW-Parkside to determine that the entire amount of the federal financial assistance was required to be returned to the federal government.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the students we identified.
Finding 2024-705: Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $1,738, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Background:
UW-Platteville receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Platteville reported a total of $29.1 million in federal financial assistance under the SFA Cluster. UW-Platteville is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Under 34 CFR s. 668.21, UW-Platteville must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. In addition, when a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Platteville must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In determining whether federal financial assistance was earned by a student, Volume 5, Chapter 2 of the Federal Student Aid Handbook specifies how to calculate academic days.
Condition:
For two of the five students we reviewed who never began attendance or who withdrew from enrollment during FY 2023-24, UW-Platteville inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Platteville incorrectly determined the student began attendance because the student attended one day of the fall 2023 term. As a result, UW-Platteville failed to return $24 in federal financial assistance to the U.S. Department of Education. For the second student, UW-Platteville did not exclude a five-day break from its determination of the federal financial assistance amount the student had earned during the fall 2023 term. Although this student had earned all of the federal financial assistance prior to the student’s withdrawal from enrollment, UW-Platteville incorrectly returned $1,226. Because UW-Platteville used the same calculation for all determinations for the fall 2023 term, there may be further errors in the federal financial assistance amounts UW-Platteville determined.
Context:
UW-Platteville uses a student information system to track activity for students who withdraw from enrollment in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Platteville staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Platteville to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 5 students who had received federal financial assistance and who withdrew from UW-Platteville to determine the amount of federal financial assistance those students earned and the related amounts UW-Platteville returned to the U.S. Department of Education.
Questioned Costs:
$24, Plus an Undetermined Amount
Effect:
UW-Platteville did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Platteville did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal financial assistance to return to the federal government. After we identified the error for the student who attended only one day, UW-Platteville returned the additional $24 to the federal government in November 2024. For the fall 2023 term, UW-Platteville changed its fall break from four to five days, which required a change in the number of academic days used in the calculation of federal financial assistance earned when a student withdraws from enrollment. UW-Platteville did not have a process to review the academic calendar for purposes of its return procedures.
Recommendation:
We recommend the University of Wisconsin-Platteville review, update, and implement its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including annually reviewing the academic days used in its determinations.
Finding 2024-706: Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $24, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Platteville: The University of Wisconsin-Platteville agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Background:
UW-Whitewater receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Whitewater reported a total of $58.4 million in federal financial assistance under the SFA Cluster. UW-Whitewater is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Whitewater must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook, the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW-Whitewater is required to be returned to the U.S. Department of Education unless certain conditions are met.
Condition:
UW-Whitewater inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education for one of seven students we reviewed who withdrew from enrollment during FY 2023 24. UW-Whitewater incorrectly accounted for a disbursement to the student that occurred after the date for which UW-Whitewater later identified the student had withdrawn from enrollment as an amount that was earned by the student. As a result, UW-Whitewater failed to return $400 in federal financial assistance to the U.S. Department of Education for the spring 2024 term.
Context:
In order to determine the federal financial assistance a student earned and the amount that must be returned to the U.S. Department of Education for amounts a student did not earn, UW-Whitewater uses a student information system to track activity for students who withdraw. We discussed with UW-Whitewater staff the process used for identifying students who withdrew from enrollment. We also requested information from UW-Whitewater to identify students who withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 7 students who had received federal financial assistance and who withdrew from UW-Whitewater to determine the amount of federal financial assistance those students earned and the related amounts UW-Whitewater returned to the U.S. Department of Education.
Questioned Costs:
$400, Plus an Undetermined Amount
Effect:
UW-Whitewater did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Whitewater did not have adequate procedures to review and ensure its determination of the amount of federal assistance to return was accurate. Although UW-Whitewater disbursed federal financial assistance later than is typical to the student, the disbursement was not correctly categorized within the calculations completed by UW-Whitewater nor was the categorization error detected by other
UW-Whitewater procedures.
Recommendation:
We recommend the University of Wisconsin-Whitewater:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the student we identified.
Finding 2024-707: Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $400, Plus an Undetermined Amount
Type of Finding: Noncompliance
Response from the University of Wisconsin-Whitewater: The University of Wisconsin-Whitewater agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Madison is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to the National Student Loan Data System (NSLDS). Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Madison is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time;
-report the same effective date for a student who withdraws from enrollment as the date used in its determination of whether any federal financial assistance must be returned in accordance with
34 CFR s. 668.22;
-report a student who has completed a program with a status of “graduated” rather than “withdrawn”;
-maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed; and
-maintain the program begin date, which is the date the student first began attending the program being reported, if a student’s program of study has not changed.
Condition:
UW-Madison uses the National Student Clearinghouse (NSC) to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Madison that identify potential errors in UW-Madison’s reporting of student activities. It is the responsibility of UW-Madison to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Madison did not report to NSLDS accurate information for 12 of the 17 students we reviewed. First, UW-Madison did not accurately report a student who withdrew from enrollment without notification in a timely manner. Second, UW-Madison incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment. Third, UW-Madison incorrectly reported the program-level enrollment status effective date for two students. Fourth, UW-Madison incorrectly reported the program begin date for six students. In addition, UW Madison incorrectly reported both the program-level enrollment status effective date and program begin date for two students.
Context:
We discussed with UW-Madison staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Madison relies on data from its student information system to compile information to transmit to NSC. UW-Madison also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student that withdrew from UW-Madison and six students who graduated from UW-Madison. In addition, we selected ten additional UW-Madison students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Madison did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Madison did not report to NSLDS who had withdrawn from enrollment without notification, we found UW-Madison’s enrollment reporting procedures did not assign responsibility for communicating certain information to those staff in the registrar’s office who are responsible for NSLDS reporting. As a result, those students the financial aid office determined had withdrawn from enrollment without notification, and for which it had completed a determination of federal financial assistance the students did not earn, were not known to staff in the registrar’s office for purposes of NSLDS reporting. In addition, UW-Madison indicated that withdrawals from enrollment without notification are identified after the term ends and its student information system did not have a dedicated effective date field in order to automatically identify such student records for the required NSLDS reporting.
Second, for the student UW-Madison did not accurately report as graduated within NSLDS, we found UW‑Madison relied on a NSC process that is intended to simultaneously update a student’s enrollment status in NSLDS when UW-Madison separately updates a student’s degree as completed. UW-Madison did not complete a separate report to ensure the enrollment status for graduated students was accurately reflected in NSLDS. However, in 2022 NSC had published information that indicated reliance solely on NSC’s process may result in the incorrect status being reported under certain circumstances. Although NSC error reports identified that such errors were present, UW-Madison indicated that it did not review these errors until fall 2024 when it began implementing new U.S. Department of Education reporting requirements.
At that time, UW-Madison stated that it identified that it did not consistently and accurately report in NSLDS those students who had graduated. UW-Madison stated that it then began to work with NSC to identify the extent of the reporting inaccuracies.
Third, in 2021 NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW-Madison’s data from its student information system and had communicated error or warning codes to UW-Madison in these areas. However, UW-Madison did not sufficiently review whether the records identified by NSC as potential errors resulted in inaccurate reporting. For example, NSC used warning codes for potential errors in the program-level enrollment status effective dates. As warning codes do not prohibit submission of reporting, UW-Madison did not review the warnings.
Fourth, in 2021 NSC similarly published information on accurately reporting student program begin dates in NSLDS and NSC had also identified instances of potential inaccurate reporting in UW Madison’s data from its student information system. Although NSC had communicated error or warning codes to UW-Madison in these areas, UW-Madison had not sufficiently reviewed whether the records identified by NSC as potential errors resulted in inaccurate reporting until 2023. At that time, UW-Madison indicated that, after reviewing other NSC warnings, it identified that it did not accurately report program begin dates for students. UW-Madison indicated it then began to work to update its student information system data extraction process to identify the correct program begin date for its submissions to NSC. However, it did not implement these changes until after the audit period.
In addition, UW-Madison indicated that it had turnover in staff responsible for NSLDS reporting in 2021, which may have caused UW-Madison to have missed the NSC publications regarding reporting graduated students accurately, new warning codes, and the importance of reviewing certain warning codes to accurately complete NSLDS reporting.
Recommendation:
We recommend the University of Wisconsin-Madison:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as updating its student information system to allow for an automated identification process to communicate those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated and implement separate reporting to the National Student Clearinghouse to accurately report students who graduate;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program-level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program begin dates and update its student information system extraction process to accurately report program begin dates; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-708: Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Background:
UW-Milwaukee receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Milwaukee reported a total of $133.1 million in federal financial assistance under the SFA Cluster. UW-Milwaukee records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Milwaukee is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Milwaukee is required to maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed.
Condition:
UW-Milwaukee uses NSC to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Milwaukee that identify potential errors in UW-Milwaukee’s reporting of student activities through NSC. These errors are the responsibility of UW-Milwaukee to resolve to ensure its submissions to NSLDS are accurate and complete.
UW-Milwaukee did not report to NSLDS accurate information for the program level enrollment status effective date for five students we reviewed. In addition, based on how information from its student information system is extracted for student reporting to NSLDS, we found that the reporting inaccuracy extended to other UW-Milwaukee students.
Context:
We discussed with UW-Milwaukee staff its procedures for identifying student enrollment status changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Milwaukee relies on data from its student information system to compile information to transmit to NSC. UW-Milwaukee also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included two students who withdrew from UW-Milwaukee and four students who graduated from UW- Milwaukee. In addition, we selected ten additional UW-Milwaukee students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Milwaukee did not comply with requirements to accurately report certain student enrollment status changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
In 2021, NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW- Milwaukee’s data from its student information system and had communicated error or warning codes to UW-Milwaukee in these areas. UW-Milwaukee staff indicated that they were aware that NSC error reports included warnings to identify potential inaccurate reporting of program level enrollment status effective dates and that the errors were a known issue for Peoplesoft-based student information systems. However, UW-Milwaukee chose not to use an all-record update feature that was available to correct the program-level enrollment status effective dates for all student records simultaneously due to the risk that other reporting inaccuracies could result from the action. Further, UW-Milwaukee staff indicated that they were not aware that specific guidance on the program-level enrollment status effective date had been updated to reflect that corrections should be made to fully comply with NSLDS reporting requirements.
Recommendation:
We recommend the University of Wisconsin-Milwaukee:
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates; and
-report changes in student enrollment accurately, completely, and in a timely manner for all student changes that require reporting.
Finding 2024-709: Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Milwaukee: The University of Wisconsin-Milwaukee agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Background:
UW-Oshkosh receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Oshkosh reported a total of $45.3 million in federal financial assistance under the SFA Cluster. UW-Oshkosh records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Oshkosh is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Oshkosh is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time; and
-report a student who has completed a program with a status of “graduated” rather than “withdrawn.”
Condition:
UW-Oshkosh uses NSC to facilitate the enrollment reporting in NSLDS. NSC provides error reports to UW-Oshkosh that identify potential errors in UW Oshkosh’s reporting of student activities. It is the responsibility of UW-Oshkosh to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Oshkosh did not report to NSLDS accurate information for two of the three students we reviewed.
First, UW-Oshkosh did not report in a timely manner one student who withdrew from enrollment without notification. Second, UW-Oshkosh incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment.
Context:
We discussed with UW-Oshkosh staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and UW Oshkosh’s procedures for monitoring the reporting performed by NSC. UW-Oshkosh relies on data from its student information system to compile information to transmit to NSC. UW-Oshkosh also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve. To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023 24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student who withdrew from UW-Oshkosh and two students who graduated from UW‑Oshkosh.
Questioned Costs:
None.
Effect:
UW-Oshkosh did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Oshkosh did not report to NSLDS in a timely manner who had withdrawn from enrollment without notification, we found that UW-Oshkosh indicated that it believed it needed to report to NSLDS only when students withdrew from enrollment and had notified UW-Oshkosh of the withdrawal. As a result, students detected by UW Oshkosh through procedures completed by the financial aid office at the end of each term were not communicated to those staff in the registrar’s office who were responsible for NSLDS reporting.
Second, for the student UW-Oshkosh did not accurately report as graduated within NSLDS, we found that inaccuracies in the reporting of students who had graduated were noted on NSC error reports. However, UW-Oshkosh’s registrar’s office staff did sufficiently review the errors to correct the status in NSLDS.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as communicating those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-710: Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Background:
UW Parkside operates in a highly computerized environment and is responsible for maintaining confidential and sensitive information, such as student data. UW Parkside maintains its own student information system to administer federal student financial assistance programs under the SFA Cluster.
Criteria:
To ensure data processed and stored by UW-Parkside is protected from accidental or intentional misuse or destruction, and to provide proper internal control, information technology (IT) security policies and procedures are necessary. In addition, IT controls should be established to prevent inappropriate or inadvertent access to data. UW-Parkside is responsible for following specific requirements under the Gramm-Leach-Bliley Act (GLBA), which requires entities that administer student financial assistance programs to develop, implement, and maintain safeguards to protect the security, integrity, and confidentiality of student data.
Under GLBA, UW-Parkside is required to authenticate and permit access only to authorized users. Further, UW Board of Regents Policy 25-5 requires that UW-Parkside follow the National Institute of Standards and Technology (NIST) in establishing IT controls. NIST Special Publication (SP) 800-53, Security and Privacy Controls for Information Systems and Organizations, recommends best practices in IT controls related to user access. These best practices include developing a provisioning and deprovisioning process focused on limiting access in a manner that provides the least access based on business need; retaining documentation of provisioning and deprovisioning activities, including records of when such access was added or removed; and performing periodic reviews of access to ensure it remains appropriate.
Condition:
We found UW-Parkside did not have adequate IT controls in place during FY 2023-24 to provision, deprovision, and manage access to its student information system. First, UW-Parkside did not have a formal documented process to provision or deprovision user access to its student information system. Second, UW-Parkside did not maintain a list of provisioned users with access and was unable to generate a report of users provisioned or deprovisioned during FY 2023-24. Third, UW-Parkside did not complete a periodic review of access, which assists in ensuring its provisioning and deprovisioning processes are working as intended. Although failure in any one IT control may be detected by complementary IT controls, UW‑Parkside did not have effective IT controls in any of the three areas. As a result, UW-Parkside was at a higher risk of granting unauthorized access to its student information system.
Context:
We reviewed GLBA requirements, UW System Board of Regents policies, and NIST 800-53 guidance to identify policies and procedures for UW-Parkside’s monitoring of access granted to its student information system. We requested documentation from UW-Parkside to assess compliance with these policies.
Questioned Costs:
None.
Effect:
Ineffective general IT controls may permit controls over systems to operate improperly and may allow noncompliance to occur and not be detected. Weaknesses in IT security policies, procedures, and controls increase the risk that unauthorized or erroneous transactions could be processed or changes made to student data. In addition, failure to provide an appropriate level of protection for its student information system and data increased the risk that personally identifiable information could be accidentally or maliciously exposed.
Cause:
UW-Parkside did not have a formal policy or procedures in place to provision, deprovision, and review access to its student information system. UW-Parkside staff indicated the process for provisioning and deprovisioning access had been informally operated, such as through electronic mail and direct communication and it did not consistently retain documentation of these communications. For example,
UW-Parkside indicated access requests were accepted from a variety of UW-Parkside employees. As a result, UW-Parkside had not assessed whether a user’s access was necessary or otherwise limited the access only to specific information needed or to a specified time period. Finally, UW-Parkside also indicated that prior efforts to improve its provisioning and deprovisioning of user access were not fully completed or implemented, in part, due to staff turnover.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-develop and implement written procedures for provisioning and deprovisioning user access to its student information system, including specifying those who are authorized to request user access and assigning responsibility to staff to assess access requests to restrict the access only to data needed for a specified period of time;
-retain consistent documentation of its provisioning and deprovisioning activities;
-develop and implement written procedures for a review at least annually of access granted to its student information system; and
-complete an assessment of users who currently have access to its student information system and remove those users who no longer require the access.
Finding 2024-711: Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-Madison must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. For students that begin attending classes, but who later withdraw from enrollment, 34 CFR s. 668.22 requires that UW-Madison must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In order not to consider a student to have withdrawn from enrollment under certain circumstances, which permits a student to retain federal financial assistance that otherwise would need to be returned to the federal government, 34 CFR s. 668.22 (a) (2) (ii) provides certain exemptions to students.
Condition:
For four students, we found that UW-Madison did not accurately determine the amount of federal financial assistance it disbursed that should have been returned to the U.S. Department of Education. First, we found that UW-Madison did not return all federal financial assistance it disbursed to two students that did not begin attendance and to one student who only attended one day during FY 2023-24. For these three students, UW-Madison determined it failed to return $16,403 in federal financial assistance it disbursed during FY 2023-24. Second, we found that UW-Madison did not accurately determine the federal financial assistance that should be returned after a student withdrew from enrollment during the summer 2023 term. For this student, UW-Madison incorrectly applied an exemption, which led to UW-Madison failing to return $584 in federal financial assistance to the U.S. Department of Education.
Context:
UW-Madison uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Madison staff its process for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Madison to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. When reviewing the data UW-Madison provided, we noted potential errors in the amount of aid returned for students identified as never attending.
Separately, as part of a UW systemwide sample of 60 students, we selected 6 students who had received federal financial assistance and who withdrew from enrollment from UW-Madison to determine the amount of federal financial assistance those students earned and the related amounts UW-Madison returned to the U.S. Department of Education.
Questioned Costs:
$16,987, Plus an Undetermined Amount
Effect:
UW-Madison did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Madison identified that the errors in determining the amount of the federal financial assistance that should have been returned to the federal government for the four students we identified were manual errors in the withdrawal procedures and calculations completed during and at the end of each term. These errors were not detected by any other review procedures. Although UW-Madison correctly identified the status of the two students who never attended and the need to return all disbursed federal financial assistance, it did not follow through on the actual repayment.
For the student who had an exemption applied, the exemption was incorrectly selected when UW-Madison completed a determination, and the error was not detected in UW-Madison’s review process. UW-Madison indicated that its automated review processes conducted at the end of each term did not specifically address the matters we identified for the four students.
After we identified these errors in the determination of the amount of federal financial assistance to return to the federal government, UW-Madison returned in fall 2024 the unearned federal financial assistance for the three students who never attended or withdrew from enrollment after attending one day. In addition, UW Madison returned the additional $584 in February 2025 for the student who withdrew from enrollment and did not meet the criteria for a withdrawal exemption.
Recommendation:
We recommend the University of Wisconsin-Madison review, update, and implement its procedures to improve the accuracy and follow-through for making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including thoroughly reviewing applied exemptions, and returning federal financial assistance in a timely manner to the federal government.
Finding 2024-703: Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,987, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Background:
UW-River Falls receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-River Falls reported a total of $23.6 million in federal financial assistance under the SFA Cluster. UW-River Falls is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-River Falls must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. Under Volume 5, Chapter 1 of the Federal Student Aid Handbook, when a student begins attendance in at least one course but does not begin attendance in all courses the student was scheduled to attend, the school must determine if it is necessary to recalculate the student’s eligibility for the Pell Grant based on a revised enrollment status and the cost of education pursuant to 34 CFR s. 690.80. If the student withdraws, this recalculation must be performed before determining whether to return federal financial assistance pursuant to 34 CFR s. 668.22.
Condition:
We found that UW-River Falls did not return $16,010 in federal financial assistance for four students that did not begin attendance in all enrolled courses during FY 2023-24. This included two students who never began attendance in any enrolled courses for whom all disbursed federal financial assistance was required to be returned. This also included two students who began at least one course but not all courses for which the students had enrolled. UW-River Falls did not perform the required recalculation of Pell Grant eligibility or an assessment of federal financial assistance it had disbursed that these students had not earned.
Context:
UW-River Falls uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-River Falls the process used for identifying students who did not begin attending all enrolled courses or withdrew from enrollment, and we requested a list of such students during FY 2023-24. UW-River Falls did not have a complete list readily available of students who did not begin attending all enrolled courses.
Questioned Costs:
$16,010, Plus an Undetermined Amount
Effect:
UW-River Falls did not comply with all requirements to return federal financial assistance for students who never attended or did not begin attending all enrolled courses during FY 2023-24.
Cause:
UW-River Falls did not have procedures to identify from its student information system, or other sources, those students for whom it disbursed federal financial assistance, yet the students did not attend at least one course during the term or begin all courses enrolled. Depending on whether a student dropped any of their courses, UW-River Falls indicated that the procedures to evaluate attendance may not have identified all students who would ultimately be determined as never attending for the academic term.
After we requested a list of students who did not begin attending all enrolled courses, UW-River Falls identified two students who did not begin at least one course but for whom it had disbursed federal financial assistance. For the other two students who began at least one course, UW-River Falls completed the required Pell Grant recalculation for the students. UW-River Falls also determined the amount of federal financial assistance to return for all four students, as applicable, to the U.S. Department of Education in September 2024.
Recommendation:
We recommend the University of Wisconsin-River Falls review, update, and implement procedures to:
-identify students after the start of each academic term for whom it disbursed federal financial assistance and the students did not begin all enrolled courses;
-complete required recalculations for Pell Grant eligibility and a determination of federal financial assistance that was not earned by the students, as applicable; and
-return amounts to the federal government in a timely manner.
Finding 2024-704: Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,010, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-River Falls: The University of Wisconsin-River Falls agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Background:
UW-Parkside receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Parkside reported a total of $21.3 million in federal financial assistance under the SFA Cluster. UW-Parkside is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22, requires that UW-Parkside must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW Parkside should be returned to the U.S. Department of Education unless certain conditions are met. In determining whether federal financial assistance was earned by a student, the Federal Student Aid Handbook provides guidance on how to calculate applicable institution charges and academic days under different circumstances.
Condition:
For two of three students we reviewed who withdrew from enrollment during FY 2023-24, UW-Parkside inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Parkside incorrectly accounted for a disbursement that occurred after the student’s withdrawal from enrollment as an amount that was earned by the student for the fall 2023 term. As a result, UW Parkside returned $548 less than what should have been returned to the U.S. Department of Education. For the second student, UW-Parkside incorrectly identified the end date of the spring 2024 term and did not include the correct institutional charges in its determination. As a result, UW-Parkside returned $1,190 less than should have been returned to the U.S. Department of Education.
Context:
UW-Parkside uses a student information system to track activity for students that withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Parkside staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from
UW-Parkside to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 3 students who had received federal financial assistance and withdrew from UW-Parkside to determine the amount of federal financial assistance those students earned and the related amounts UW-Parkside returned to the U.S. Department of Education.
Questioned Costs:
$1,738, Plus an Undetermined Amount
Effect:
UW-Parkside did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Parkside did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal assistance to return. Although UW-Parkside disbursed federal financial assistance later than is typical to one student, the disbursement was not correctly categorized within the calculations completed by UW-Parkside to determine that the entire amount of the federal financial assistance was required to be returned to the federal government.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the students we identified.
Finding 2024-705: Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $1,738, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Background:
UW-Platteville receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Platteville reported a total of $29.1 million in federal financial assistance under the SFA Cluster. UW-Platteville is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Under 34 CFR s. 668.21, UW-Platteville must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. In addition, when a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Platteville must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In determining whether federal financial assistance was earned by a student, Volume 5, Chapter 2 of the Federal Student Aid Handbook specifies how to calculate academic days.
Condition:
For two of the five students we reviewed who never began attendance or who withdrew from enrollment during FY 2023-24, UW-Platteville inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Platteville incorrectly determined the student began attendance because the student attended one day of the fall 2023 term. As a result, UW-Platteville failed to return $24 in federal financial assistance to the U.S. Department of Education. For the second student, UW-Platteville did not exclude a five-day break from its determination of the federal financial assistance amount the student had earned during the fall 2023 term. Although this student had earned all of the federal financial assistance prior to the student’s withdrawal from enrollment, UW-Platteville incorrectly returned $1,226. Because UW-Platteville used the same calculation for all determinations for the fall 2023 term, there may be further errors in the federal financial assistance amounts UW-Platteville determined.
Context:
UW-Platteville uses a student information system to track activity for students who withdraw from enrollment in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Platteville staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Platteville to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 5 students who had received federal financial assistance and who withdrew from UW-Platteville to determine the amount of federal financial assistance those students earned and the related amounts UW-Platteville returned to the U.S. Department of Education.
Questioned Costs:
$24, Plus an Undetermined Amount
Effect:
UW-Platteville did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Platteville did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal financial assistance to return to the federal government. After we identified the error for the student who attended only one day, UW-Platteville returned the additional $24 to the federal government in November 2024. For the fall 2023 term, UW-Platteville changed its fall break from four to five days, which required a change in the number of academic days used in the calculation of federal financial assistance earned when a student withdraws from enrollment. UW-Platteville did not have a process to review the academic calendar for purposes of its return procedures.
Recommendation:
We recommend the University of Wisconsin-Platteville review, update, and implement its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including annually reviewing the academic days used in its determinations.
Finding 2024-706: Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $24, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Platteville: The University of Wisconsin-Platteville agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Background:
UW-Whitewater receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Whitewater reported a total of $58.4 million in federal financial assistance under the SFA Cluster. UW-Whitewater is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Whitewater must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook, the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW-Whitewater is required to be returned to the U.S. Department of Education unless certain conditions are met.
Condition:
UW-Whitewater inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education for one of seven students we reviewed who withdrew from enrollment during FY 2023 24. UW-Whitewater incorrectly accounted for a disbursement to the student that occurred after the date for which UW-Whitewater later identified the student had withdrawn from enrollment as an amount that was earned by the student. As a result, UW-Whitewater failed to return $400 in federal financial assistance to the U.S. Department of Education for the spring 2024 term.
Context:
In order to determine the federal financial assistance a student earned and the amount that must be returned to the U.S. Department of Education for amounts a student did not earn, UW-Whitewater uses a student information system to track activity for students who withdraw. We discussed with UW-Whitewater staff the process used for identifying students who withdrew from enrollment. We also requested information from UW-Whitewater to identify students who withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 7 students who had received federal financial assistance and who withdrew from UW-Whitewater to determine the amount of federal financial assistance those students earned and the related amounts UW-Whitewater returned to the U.S. Department of Education.
Questioned Costs:
$400, Plus an Undetermined Amount
Effect:
UW-Whitewater did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Whitewater did not have adequate procedures to review and ensure its determination of the amount of federal assistance to return was accurate. Although UW-Whitewater disbursed federal financial assistance later than is typical to the student, the disbursement was not correctly categorized within the calculations completed by UW-Whitewater nor was the categorization error detected by other
UW-Whitewater procedures.
Recommendation:
We recommend the University of Wisconsin-Whitewater:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the student we identified.
Finding 2024-707: Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $400, Plus an Undetermined Amount
Type of Finding: Noncompliance
Response from the University of Wisconsin-Whitewater: The University of Wisconsin-Whitewater agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Madison is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to the National Student Loan Data System (NSLDS). Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Madison is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time;
-report the same effective date for a student who withdraws from enrollment as the date used in its determination of whether any federal financial assistance must be returned in accordance with
34 CFR s. 668.22;
-report a student who has completed a program with a status of “graduated” rather than “withdrawn”;
-maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed; and
-maintain the program begin date, which is the date the student first began attending the program being reported, if a student’s program of study has not changed.
Condition:
UW-Madison uses the National Student Clearinghouse (NSC) to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Madison that identify potential errors in UW-Madison’s reporting of student activities. It is the responsibility of UW-Madison to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Madison did not report to NSLDS accurate information for 12 of the 17 students we reviewed. First, UW-Madison did not accurately report a student who withdrew from enrollment without notification in a timely manner. Second, UW-Madison incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment. Third, UW-Madison incorrectly reported the program-level enrollment status effective date for two students. Fourth, UW-Madison incorrectly reported the program begin date for six students. In addition, UW Madison incorrectly reported both the program-level enrollment status effective date and program begin date for two students.
Context:
We discussed with UW-Madison staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Madison relies on data from its student information system to compile information to transmit to NSC. UW-Madison also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student that withdrew from UW-Madison and six students who graduated from UW-Madison. In addition, we selected ten additional UW-Madison students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Madison did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Madison did not report to NSLDS who had withdrawn from enrollment without notification, we found UW-Madison’s enrollment reporting procedures did not assign responsibility for communicating certain information to those staff in the registrar’s office who are responsible for NSLDS reporting. As a result, those students the financial aid office determined had withdrawn from enrollment without notification, and for which it had completed a determination of federal financial assistance the students did not earn, were not known to staff in the registrar’s office for purposes of NSLDS reporting. In addition, UW-Madison indicated that withdrawals from enrollment without notification are identified after the term ends and its student information system did not have a dedicated effective date field in order to automatically identify such student records for the required NSLDS reporting.
Second, for the student UW-Madison did not accurately report as graduated within NSLDS, we found UW‑Madison relied on a NSC process that is intended to simultaneously update a student’s enrollment status in NSLDS when UW-Madison separately updates a student’s degree as completed. UW-Madison did not complete a separate report to ensure the enrollment status for graduated students was accurately reflected in NSLDS. However, in 2022 NSC had published information that indicated reliance solely on NSC’s process may result in the incorrect status being reported under certain circumstances. Although NSC error reports identified that such errors were present, UW-Madison indicated that it did not review these errors until fall 2024 when it began implementing new U.S. Department of Education reporting requirements.
At that time, UW-Madison stated that it identified that it did not consistently and accurately report in NSLDS those students who had graduated. UW-Madison stated that it then began to work with NSC to identify the extent of the reporting inaccuracies.
Third, in 2021 NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW-Madison’s data from its student information system and had communicated error or warning codes to UW-Madison in these areas. However, UW-Madison did not sufficiently review whether the records identified by NSC as potential errors resulted in inaccurate reporting. For example, NSC used warning codes for potential errors in the program-level enrollment status effective dates. As warning codes do not prohibit submission of reporting, UW-Madison did not review the warnings.
Fourth, in 2021 NSC similarly published information on accurately reporting student program begin dates in NSLDS and NSC had also identified instances of potential inaccurate reporting in UW Madison’s data from its student information system. Although NSC had communicated error or warning codes to UW-Madison in these areas, UW-Madison had not sufficiently reviewed whether the records identified by NSC as potential errors resulted in inaccurate reporting until 2023. At that time, UW-Madison indicated that, after reviewing other NSC warnings, it identified that it did not accurately report program begin dates for students. UW-Madison indicated it then began to work to update its student information system data extraction process to identify the correct program begin date for its submissions to NSC. However, it did not implement these changes until after the audit period.
In addition, UW-Madison indicated that it had turnover in staff responsible for NSLDS reporting in 2021, which may have caused UW-Madison to have missed the NSC publications regarding reporting graduated students accurately, new warning codes, and the importance of reviewing certain warning codes to accurately complete NSLDS reporting.
Recommendation:
We recommend the University of Wisconsin-Madison:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as updating its student information system to allow for an automated identification process to communicate those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated and implement separate reporting to the National Student Clearinghouse to accurately report students who graduate;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program-level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program begin dates and update its student information system extraction process to accurately report program begin dates; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-708: Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Background:
UW-Milwaukee receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Milwaukee reported a total of $133.1 million in federal financial assistance under the SFA Cluster. UW-Milwaukee records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Milwaukee is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Milwaukee is required to maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed.
Condition:
UW-Milwaukee uses NSC to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Milwaukee that identify potential errors in UW-Milwaukee’s reporting of student activities through NSC. These errors are the responsibility of UW-Milwaukee to resolve to ensure its submissions to NSLDS are accurate and complete.
UW-Milwaukee did not report to NSLDS accurate information for the program level enrollment status effective date for five students we reviewed. In addition, based on how information from its student information system is extracted for student reporting to NSLDS, we found that the reporting inaccuracy extended to other UW-Milwaukee students.
Context:
We discussed with UW-Milwaukee staff its procedures for identifying student enrollment status changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Milwaukee relies on data from its student information system to compile information to transmit to NSC. UW-Milwaukee also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included two students who withdrew from UW-Milwaukee and four students who graduated from UW- Milwaukee. In addition, we selected ten additional UW-Milwaukee students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Milwaukee did not comply with requirements to accurately report certain student enrollment status changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
In 2021, NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW- Milwaukee’s data from its student information system and had communicated error or warning codes to UW-Milwaukee in these areas. UW-Milwaukee staff indicated that they were aware that NSC error reports included warnings to identify potential inaccurate reporting of program level enrollment status effective dates and that the errors were a known issue for Peoplesoft-based student information systems. However, UW-Milwaukee chose not to use an all-record update feature that was available to correct the program-level enrollment status effective dates for all student records simultaneously due to the risk that other reporting inaccuracies could result from the action. Further, UW-Milwaukee staff indicated that they were not aware that specific guidance on the program-level enrollment status effective date had been updated to reflect that corrections should be made to fully comply with NSLDS reporting requirements.
Recommendation:
We recommend the University of Wisconsin-Milwaukee:
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates; and
-report changes in student enrollment accurately, completely, and in a timely manner for all student changes that require reporting.
Finding 2024-709: Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Milwaukee: The University of Wisconsin-Milwaukee agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Background:
UW-Oshkosh receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Oshkosh reported a total of $45.3 million in federal financial assistance under the SFA Cluster. UW-Oshkosh records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Oshkosh is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Oshkosh is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time; and
-report a student who has completed a program with a status of “graduated” rather than “withdrawn.”
Condition:
UW-Oshkosh uses NSC to facilitate the enrollment reporting in NSLDS. NSC provides error reports to UW-Oshkosh that identify potential errors in UW Oshkosh’s reporting of student activities. It is the responsibility of UW-Oshkosh to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Oshkosh did not report to NSLDS accurate information for two of the three students we reviewed.
First, UW-Oshkosh did not report in a timely manner one student who withdrew from enrollment without notification. Second, UW-Oshkosh incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment.
Context:
We discussed with UW-Oshkosh staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and UW Oshkosh’s procedures for monitoring the reporting performed by NSC. UW-Oshkosh relies on data from its student information system to compile information to transmit to NSC. UW-Oshkosh also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve. To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023 24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student who withdrew from UW-Oshkosh and two students who graduated from UW‑Oshkosh.
Questioned Costs:
None.
Effect:
UW-Oshkosh did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Oshkosh did not report to NSLDS in a timely manner who had withdrawn from enrollment without notification, we found that UW-Oshkosh indicated that it believed it needed to report to NSLDS only when students withdrew from enrollment and had notified UW-Oshkosh of the withdrawal. As a result, students detected by UW Oshkosh through procedures completed by the financial aid office at the end of each term were not communicated to those staff in the registrar’s office who were responsible for NSLDS reporting.
Second, for the student UW-Oshkosh did not accurately report as graduated within NSLDS, we found that inaccuracies in the reporting of students who had graduated were noted on NSC error reports. However, UW-Oshkosh’s registrar’s office staff did sufficiently review the errors to correct the status in NSLDS.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as communicating those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-710: Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Background:
UW Parkside operates in a highly computerized environment and is responsible for maintaining confidential and sensitive information, such as student data. UW Parkside maintains its own student information system to administer federal student financial assistance programs under the SFA Cluster.
Criteria:
To ensure data processed and stored by UW-Parkside is protected from accidental or intentional misuse or destruction, and to provide proper internal control, information technology (IT) security policies and procedures are necessary. In addition, IT controls should be established to prevent inappropriate or inadvertent access to data. UW-Parkside is responsible for following specific requirements under the Gramm-Leach-Bliley Act (GLBA), which requires entities that administer student financial assistance programs to develop, implement, and maintain safeguards to protect the security, integrity, and confidentiality of student data.
Under GLBA, UW-Parkside is required to authenticate and permit access only to authorized users. Further, UW Board of Regents Policy 25-5 requires that UW-Parkside follow the National Institute of Standards and Technology (NIST) in establishing IT controls. NIST Special Publication (SP) 800-53, Security and Privacy Controls for Information Systems and Organizations, recommends best practices in IT controls related to user access. These best practices include developing a provisioning and deprovisioning process focused on limiting access in a manner that provides the least access based on business need; retaining documentation of provisioning and deprovisioning activities, including records of when such access was added or removed; and performing periodic reviews of access to ensure it remains appropriate.
Condition:
We found UW-Parkside did not have adequate IT controls in place during FY 2023-24 to provision, deprovision, and manage access to its student information system. First, UW-Parkside did not have a formal documented process to provision or deprovision user access to its student information system. Second, UW-Parkside did not maintain a list of provisioned users with access and was unable to generate a report of users provisioned or deprovisioned during FY 2023-24. Third, UW-Parkside did not complete a periodic review of access, which assists in ensuring its provisioning and deprovisioning processes are working as intended. Although failure in any one IT control may be detected by complementary IT controls, UW‑Parkside did not have effective IT controls in any of the three areas. As a result, UW-Parkside was at a higher risk of granting unauthorized access to its student information system.
Context:
We reviewed GLBA requirements, UW System Board of Regents policies, and NIST 800-53 guidance to identify policies and procedures for UW-Parkside’s monitoring of access granted to its student information system. We requested documentation from UW-Parkside to assess compliance with these policies.
Questioned Costs:
None.
Effect:
Ineffective general IT controls may permit controls over systems to operate improperly and may allow noncompliance to occur and not be detected. Weaknesses in IT security policies, procedures, and controls increase the risk that unauthorized or erroneous transactions could be processed or changes made to student data. In addition, failure to provide an appropriate level of protection for its student information system and data increased the risk that personally identifiable information could be accidentally or maliciously exposed.
Cause:
UW-Parkside did not have a formal policy or procedures in place to provision, deprovision, and review access to its student information system. UW-Parkside staff indicated the process for provisioning and deprovisioning access had been informally operated, such as through electronic mail and direct communication and it did not consistently retain documentation of these communications. For example,
UW-Parkside indicated access requests were accepted from a variety of UW-Parkside employees. As a result, UW-Parkside had not assessed whether a user’s access was necessary or otherwise limited the access only to specific information needed or to a specified time period. Finally, UW-Parkside also indicated that prior efforts to improve its provisioning and deprovisioning of user access were not fully completed or implemented, in part, due to staff turnover.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-develop and implement written procedures for provisioning and deprovisioning user access to its student information system, including specifying those who are authorized to request user access and assigning responsibility to staff to assess access requests to restrict the access only to data needed for a specified period of time;
-retain consistent documentation of its provisioning and deprovisioning activities;
-develop and implement written procedures for a review at least annually of access granted to its student information system; and
-complete an assessment of users who currently have access to its student information system and remove those users who no longer require the access.
Finding 2024-711: Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Background:
The DOA State Controller’s Office (SCO) is responsible for coordinating with other state agencies to prepare the State of Wisconsin Schedule of Expenditures of Federal Awards (SEFA). The SEFA, which is required to be published in the State of Wisconsin single audit report, is a listing of all federal programs administered by an entity. The SEFA includes the total expenditures for the reporting period and identifies any amounts provided to subrecipients for each federal program.
Each state agency prepares a SEFA for the federal programs it administers. For federal programs administered by UW System Administration and UW institutions, UW System Administration staff work with UW institution staff to compile the UW SEFA. The UW SEFA is provided to DOA, which compiles the agency-level SEFAs into the statewide SEFA.
Criteria:
Under 2 CFR s. 200.510 (b), the State is required to prepare a SEFA for the period covered by the State’s financial statements and the SEFA must include the total federal awards expended and include the total amount provided to subrecipients from each federal program. In addition, for federal awards received as a subrecipient, the name of the pass-through entity is required to be identified in the SEFA.
Condition:
We identified multiple errors in the presentation of federal expenditures in the SEFA prepared by UW System Administration. First, we found UW System Administration reported only $2.0 million in federal expenditures for the ELC grant, based on ELC funding UW-Madison received from DHS. However, DHS reported reimbursing UW-Madison $18.2 million in expenditures under the ELC grant. UW System Administration was not able to fully reconcile these amounts.
Second, we found UW System Administration incorrectly reported a disallowance of $10.1 million to the Federal Perkins Loan Program—Federal Capital Contributions (Assistance Listing number 84.038) and did not remove the disallowance before reporting total expenditures for the Perkins Loan program. As a result, UW-Madison underreported Perkins Loan federal financial assistance by $10.1 million in its SEFA. After we identified this error, UW System Administration corrected the amount reported in the final SEFA.
Third, we found UW System Administration reported $330,476 in federal expenditures for the Immunization Cooperative Agreements grant (Assistance Listing number 93.268). However, UW-Madison staff administering the program indicated the expenditures were for the Health Disparities grant.
Fourth, we found that $3.1 million in expenditures for a UW-Eau Claire award under the CSLFRF grant was incorrectly reported as a subgrant from the Wisconsin Economic Development Corporation. However, this funding related to an agreement between UW-Eau Claire and the Wisconsin Department of Workforce Development (DWD), and should have been reported as a direct award on the SEFA.
Fifth, we found that UW System Administration incorrectly included non-research grants in the Research and Development Cluster in the SEFA. After we inquired and suggested changes, UW System Administration identified that $28.8 million in federal expenditures for 20 grant programs were incorrectly reported as part of the Research and Development Cluster. For example, UW System Administration reported $9.0 million in expenditures for the DBII grant, $6.3 million for the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561), and $2.2 million in expenditures under the CSLFRF grant as expenditures in the Research and Development Cluster, but none of these programs relate to research.
Context:
UW System Administration reported $1.9 billion in federal financial assistance in FY 2023-24. We reviewed UW System’s SEFA to assess the reported expenditures, particularly for major programs. We inquired of UW System Administration regarding its procedures for preparation of the SEFA, and of UW institution staff as needed to understand the recording of federal grant expenditures.
Questioned Costs:
None.
Effect:
UW System Administration is not assured that its reporting in the SEFA accurately reflects its expenditure of federal assistance. Errors such as those we identified are noncompliant with federal requirements.
Cause:
Although UW System Administration had queries to document the steps in its SEFA preparation process, it did not have formal written procedures for the process. Overall, UW System Administration’s procedures for preparing the SEFA were insufficient to detect and correct potential errors in recording transactions when grant funds are transferred between UW institutions and state agencies.
For the ELC grant, the expenditures were coded to a non-federal account in UW-Madison’s records, and thus were not included in the compilation of the SEFA. UW-Madison staff indicated that the relationship with DHS for the ELC grant was a contractual relationship and therefore UW-Madison did not establish the original ELC project as a federal grant in its accounting records. Further, UW System Administration did not have sufficient processes in place to verify with DHS that the ELC expenditures were appropriately reflected in the UW System SEFA.
For the Perkins Loan Program, UW System Administration did not have sufficient procedures in place to identify disallowances and other types of credits that require adjustment when preparing the federal expenditures in the SEFA.
For the Health Disparities grant, there was a lack of communication between UW-Madison department-level accounting staff and DHS to ensure agreement on which federal program the federal expenditures should be recorded.
For the UW-Eau Claire CSLFRF award, UW staff relied on how the award was named in UW System’s accounting records, rather than reviewing the award agreement to determine that the award was from DWD, rather than WEDC.
Finally, UW System Administration did not have sufficient procedures in place to ensure only research grant expenditures were included in the Research and Development Cluster.
Recommendation:
We recommend the University of Wisconsin System Administration:
-revise and document its procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include steps to correctly identify grant activity between UW institutions and grant activity between UW institutions and other state agencies;
-revise and document its procedures for identifying grants as research to ensure correct reporting in the Research and Development Cluster;
-work with all UW institutions and state agencies to ensure federal expenditures are recorded correctly in its SEFA; and
-provide training and guidance to UW institutions on the revised and documented SEFA preparation procedures.
Finding 2024-712: Multiple Grants—Reporting in the Schedule of Expenditures of Federal Awards
Dairy Business Innovation Initiatives (Assistance Listing number 10.176)
Award Numbers Award Years
AM200100XXXXG001 2020
21DBIWI1006 2021
AM21DBIWI1010 2022
AM22DBIWI1014 2022
23DBIWI1019 2023
Questioned Costs: None
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing number 10.561)
Award Numbers Award Years
2WI400115 2023
2WI400115 2024
Questioned Costs: None
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: None
Drinking Water State Revolving Fund (Assistance Listing number 66.468)
Award Numbers Award Years
98597721 2021
98597722 2022
98597723 2023
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative
(Assistance Listing number 66.469)
Award Numbers Award Years
00E02456 2019
00E02490 2019
00E02975 2021
00E03149 2022
00E03187 2022
00E03188 2022
001E0301 2022
03E00712 2022
00E03404 2023
Questioned Costs: None
Federal Perkins Loan Program—Federal Capital Contributions
(Assistance Listing number 84.038)
Award Numbers Award Years
Various Various
Questioned Costs: None
English Language Acquisition State Grants (Assistance Listing number 84.365)
Award Number Award Year
T365Z210124 2021
Questioned Costs: None
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Covid-19—Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
(Assistance Listing number 93.323)
Award Number Award Year
NU50CK000534 2024
Questioned Costs: None
Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Numbers Award Years
1B08TI084677-01 2021-2024
1B08TI085839-01 2022-2024
1B08TI087071-01 2023-2025
Questioned Costs: None
Children's Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2305WI15CHIP 2023
2405WI15CHIP 2024
Questioned Costs: None
Medical Assistance Program
(Assistance Listing number 93.778)
Award Numbers Award Years
2305WI5MAP 2023
2405WI5MAP 2024
Questioned Costs: None
Covid-19—Block Grants for Prevention and Treatment of Substance Abuse
(Assistance Listing number 93.959)
Award Number Award Years
1B08TI083973-01 2021-2025
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin System Administration: The University of Wisconsin System Administration agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-Madison must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. For students that begin attending classes, but who later withdraw from enrollment, 34 CFR s. 668.22 requires that UW-Madison must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In order not to consider a student to have withdrawn from enrollment under certain circumstances, which permits a student to retain federal financial assistance that otherwise would need to be returned to the federal government, 34 CFR s. 668.22 (a) (2) (ii) provides certain exemptions to students.
Condition:
For four students, we found that UW-Madison did not accurately determine the amount of federal financial assistance it disbursed that should have been returned to the U.S. Department of Education. First, we found that UW-Madison did not return all federal financial assistance it disbursed to two students that did not begin attendance and to one student who only attended one day during FY 2023-24. For these three students, UW-Madison determined it failed to return $16,403 in federal financial assistance it disbursed during FY 2023-24. Second, we found that UW-Madison did not accurately determine the federal financial assistance that should be returned after a student withdrew from enrollment during the summer 2023 term. For this student, UW-Madison incorrectly applied an exemption, which led to UW-Madison failing to return $584 in federal financial assistance to the U.S. Department of Education.
Context:
UW-Madison uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Madison staff its process for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Madison to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. When reviewing the data UW-Madison provided, we noted potential errors in the amount of aid returned for students identified as never attending.
Separately, as part of a UW systemwide sample of 60 students, we selected 6 students who had received federal financial assistance and who withdrew from enrollment from UW-Madison to determine the amount of federal financial assistance those students earned and the related amounts UW-Madison returned to the U.S. Department of Education.
Questioned Costs:
$16,987, Plus an Undetermined Amount
Effect:
UW-Madison did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Madison identified that the errors in determining the amount of the federal financial assistance that should have been returned to the federal government for the four students we identified were manual errors in the withdrawal procedures and calculations completed during and at the end of each term. These errors were not detected by any other review procedures. Although UW-Madison correctly identified the status of the two students who never attended and the need to return all disbursed federal financial assistance, it did not follow through on the actual repayment.
For the student who had an exemption applied, the exemption was incorrectly selected when UW-Madison completed a determination, and the error was not detected in UW-Madison’s review process. UW-Madison indicated that its automated review processes conducted at the end of each term did not specifically address the matters we identified for the four students.
After we identified these errors in the determination of the amount of federal financial assistance to return to the federal government, UW-Madison returned in fall 2024 the unearned federal financial assistance for the three students who never attended or withdrew from enrollment after attending one day. In addition, UW Madison returned the additional $584 in February 2025 for the student who withdrew from enrollment and did not meet the criteria for a withdrawal exemption.
Recommendation:
We recommend the University of Wisconsin-Madison review, update, and implement its procedures to improve the accuracy and follow-through for making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including thoroughly reviewing applied exemptions, and returning federal financial assistance in a timely manner to the federal government.
Finding 2024-703: Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,987, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Background:
UW-River Falls receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-River Falls reported a total of $23.6 million in federal financial assistance under the SFA Cluster. UW-River Falls is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-River Falls must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. Under Volume 5, Chapter 1 of the Federal Student Aid Handbook, when a student begins attendance in at least one course but does not begin attendance in all courses the student was scheduled to attend, the school must determine if it is necessary to recalculate the student’s eligibility for the Pell Grant based on a revised enrollment status and the cost of education pursuant to 34 CFR s. 690.80. If the student withdraws, this recalculation must be performed before determining whether to return federal financial assistance pursuant to 34 CFR s. 668.22.
Condition:
We found that UW-River Falls did not return $16,010 in federal financial assistance for four students that did not begin attendance in all enrolled courses during FY 2023-24. This included two students who never began attendance in any enrolled courses for whom all disbursed federal financial assistance was required to be returned. This also included two students who began at least one course but not all courses for which the students had enrolled. UW-River Falls did not perform the required recalculation of Pell Grant eligibility or an assessment of federal financial assistance it had disbursed that these students had not earned.
Context:
UW-River Falls uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-River Falls the process used for identifying students who did not begin attending all enrolled courses or withdrew from enrollment, and we requested a list of such students during FY 2023-24. UW-River Falls did not have a complete list readily available of students who did not begin attending all enrolled courses.
Questioned Costs:
$16,010, Plus an Undetermined Amount
Effect:
UW-River Falls did not comply with all requirements to return federal financial assistance for students who never attended or did not begin attending all enrolled courses during FY 2023-24.
Cause:
UW-River Falls did not have procedures to identify from its student information system, or other sources, those students for whom it disbursed federal financial assistance, yet the students did not attend at least one course during the term or begin all courses enrolled. Depending on whether a student dropped any of their courses, UW-River Falls indicated that the procedures to evaluate attendance may not have identified all students who would ultimately be determined as never attending for the academic term.
After we requested a list of students who did not begin attending all enrolled courses, UW-River Falls identified two students who did not begin at least one course but for whom it had disbursed federal financial assistance. For the other two students who began at least one course, UW-River Falls completed the required Pell Grant recalculation for the students. UW-River Falls also determined the amount of federal financial assistance to return for all four students, as applicable, to the U.S. Department of Education in September 2024.
Recommendation:
We recommend the University of Wisconsin-River Falls review, update, and implement procedures to:
-identify students after the start of each academic term for whom it disbursed federal financial assistance and the students did not begin all enrolled courses;
-complete required recalculations for Pell Grant eligibility and a determination of federal financial assistance that was not earned by the students, as applicable; and
-return amounts to the federal government in a timely manner.
Finding 2024-704: Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,010, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-River Falls: The University of Wisconsin-River Falls agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Background:
UW-Parkside receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Parkside reported a total of $21.3 million in federal financial assistance under the SFA Cluster. UW-Parkside is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22, requires that UW-Parkside must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW Parkside should be returned to the U.S. Department of Education unless certain conditions are met. In determining whether federal financial assistance was earned by a student, the Federal Student Aid Handbook provides guidance on how to calculate applicable institution charges and academic days under different circumstances.
Condition:
For two of three students we reviewed who withdrew from enrollment during FY 2023-24, UW-Parkside inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Parkside incorrectly accounted for a disbursement that occurred after the student’s withdrawal from enrollment as an amount that was earned by the student for the fall 2023 term. As a result, UW Parkside returned $548 less than what should have been returned to the U.S. Department of Education. For the second student, UW-Parkside incorrectly identified the end date of the spring 2024 term and did not include the correct institutional charges in its determination. As a result, UW-Parkside returned $1,190 less than should have been returned to the U.S. Department of Education.
Context:
UW-Parkside uses a student information system to track activity for students that withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Parkside staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from
UW-Parkside to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 3 students who had received federal financial assistance and withdrew from UW-Parkside to determine the amount of federal financial assistance those students earned and the related amounts UW-Parkside returned to the U.S. Department of Education.
Questioned Costs:
$1,738, Plus an Undetermined Amount
Effect:
UW-Parkside did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Parkside did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal assistance to return. Although UW-Parkside disbursed federal financial assistance later than is typical to one student, the disbursement was not correctly categorized within the calculations completed by UW-Parkside to determine that the entire amount of the federal financial assistance was required to be returned to the federal government.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the students we identified.
Finding 2024-705: Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $1,738, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Background:
UW-Platteville receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Platteville reported a total of $29.1 million in federal financial assistance under the SFA Cluster. UW-Platteville is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Under 34 CFR s. 668.21, UW-Platteville must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. In addition, when a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Platteville must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In determining whether federal financial assistance was earned by a student, Volume 5, Chapter 2 of the Federal Student Aid Handbook specifies how to calculate academic days.
Condition:
For two of the five students we reviewed who never began attendance or who withdrew from enrollment during FY 2023-24, UW-Platteville inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Platteville incorrectly determined the student began attendance because the student attended one day of the fall 2023 term. As a result, UW-Platteville failed to return $24 in federal financial assistance to the U.S. Department of Education. For the second student, UW-Platteville did not exclude a five-day break from its determination of the federal financial assistance amount the student had earned during the fall 2023 term. Although this student had earned all of the federal financial assistance prior to the student’s withdrawal from enrollment, UW-Platteville incorrectly returned $1,226. Because UW-Platteville used the same calculation for all determinations for the fall 2023 term, there may be further errors in the federal financial assistance amounts UW-Platteville determined.
Context:
UW-Platteville uses a student information system to track activity for students who withdraw from enrollment in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Platteville staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Platteville to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 5 students who had received federal financial assistance and who withdrew from UW-Platteville to determine the amount of federal financial assistance those students earned and the related amounts UW-Platteville returned to the U.S. Department of Education.
Questioned Costs:
$24, Plus an Undetermined Amount
Effect:
UW-Platteville did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Platteville did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal financial assistance to return to the federal government. After we identified the error for the student who attended only one day, UW-Platteville returned the additional $24 to the federal government in November 2024. For the fall 2023 term, UW-Platteville changed its fall break from four to five days, which required a change in the number of academic days used in the calculation of federal financial assistance earned when a student withdraws from enrollment. UW-Platteville did not have a process to review the academic calendar for purposes of its return procedures.
Recommendation:
We recommend the University of Wisconsin-Platteville review, update, and implement its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including annually reviewing the academic days used in its determinations.
Finding 2024-706: Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $24, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Platteville: The University of Wisconsin-Platteville agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Background:
UW-Whitewater receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Whitewater reported a total of $58.4 million in federal financial assistance under the SFA Cluster. UW-Whitewater is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Whitewater must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook, the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW-Whitewater is required to be returned to the U.S. Department of Education unless certain conditions are met.
Condition:
UW-Whitewater inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education for one of seven students we reviewed who withdrew from enrollment during FY 2023 24. UW-Whitewater incorrectly accounted for a disbursement to the student that occurred after the date for which UW-Whitewater later identified the student had withdrawn from enrollment as an amount that was earned by the student. As a result, UW-Whitewater failed to return $400 in federal financial assistance to the U.S. Department of Education for the spring 2024 term.
Context:
In order to determine the federal financial assistance a student earned and the amount that must be returned to the U.S. Department of Education for amounts a student did not earn, UW-Whitewater uses a student information system to track activity for students who withdraw. We discussed with UW-Whitewater staff the process used for identifying students who withdrew from enrollment. We also requested information from UW-Whitewater to identify students who withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 7 students who had received federal financial assistance and who withdrew from UW-Whitewater to determine the amount of federal financial assistance those students earned and the related amounts UW-Whitewater returned to the U.S. Department of Education.
Questioned Costs:
$400, Plus an Undetermined Amount
Effect:
UW-Whitewater did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Whitewater did not have adequate procedures to review and ensure its determination of the amount of federal assistance to return was accurate. Although UW-Whitewater disbursed federal financial assistance later than is typical to the student, the disbursement was not correctly categorized within the calculations completed by UW-Whitewater nor was the categorization error detected by other
UW-Whitewater procedures.
Recommendation:
We recommend the University of Wisconsin-Whitewater:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the student we identified.
Finding 2024-707: Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $400, Plus an Undetermined Amount
Type of Finding: Noncompliance
Response from the University of Wisconsin-Whitewater: The University of Wisconsin-Whitewater agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Madison is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to the National Student Loan Data System (NSLDS). Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Madison is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time;
-report the same effective date for a student who withdraws from enrollment as the date used in its determination of whether any federal financial assistance must be returned in accordance with
34 CFR s. 668.22;
-report a student who has completed a program with a status of “graduated” rather than “withdrawn”;
-maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed; and
-maintain the program begin date, which is the date the student first began attending the program being reported, if a student’s program of study has not changed.
Condition:
UW-Madison uses the National Student Clearinghouse (NSC) to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Madison that identify potential errors in UW-Madison’s reporting of student activities. It is the responsibility of UW-Madison to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Madison did not report to NSLDS accurate information for 12 of the 17 students we reviewed. First, UW-Madison did not accurately report a student who withdrew from enrollment without notification in a timely manner. Second, UW-Madison incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment. Third, UW-Madison incorrectly reported the program-level enrollment status effective date for two students. Fourth, UW-Madison incorrectly reported the program begin date for six students. In addition, UW Madison incorrectly reported both the program-level enrollment status effective date and program begin date for two students.
Context:
We discussed with UW-Madison staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Madison relies on data from its student information system to compile information to transmit to NSC. UW-Madison also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student that withdrew from UW-Madison and six students who graduated from UW-Madison. In addition, we selected ten additional UW-Madison students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Madison did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Madison did not report to NSLDS who had withdrawn from enrollment without notification, we found UW-Madison’s enrollment reporting procedures did not assign responsibility for communicating certain information to those staff in the registrar’s office who are responsible for NSLDS reporting. As a result, those students the financial aid office determined had withdrawn from enrollment without notification, and for which it had completed a determination of federal financial assistance the students did not earn, were not known to staff in the registrar’s office for purposes of NSLDS reporting. In addition, UW-Madison indicated that withdrawals from enrollment without notification are identified after the term ends and its student information system did not have a dedicated effective date field in order to automatically identify such student records for the required NSLDS reporting.
Second, for the student UW-Madison did not accurately report as graduated within NSLDS, we found UW‑Madison relied on a NSC process that is intended to simultaneously update a student’s enrollment status in NSLDS when UW-Madison separately updates a student’s degree as completed. UW-Madison did not complete a separate report to ensure the enrollment status for graduated students was accurately reflected in NSLDS. However, in 2022 NSC had published information that indicated reliance solely on NSC’s process may result in the incorrect status being reported under certain circumstances. Although NSC error reports identified that such errors were present, UW-Madison indicated that it did not review these errors until fall 2024 when it began implementing new U.S. Department of Education reporting requirements.
At that time, UW-Madison stated that it identified that it did not consistently and accurately report in NSLDS those students who had graduated. UW-Madison stated that it then began to work with NSC to identify the extent of the reporting inaccuracies.
Third, in 2021 NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW-Madison’s data from its student information system and had communicated error or warning codes to UW-Madison in these areas. However, UW-Madison did not sufficiently review whether the records identified by NSC as potential errors resulted in inaccurate reporting. For example, NSC used warning codes for potential errors in the program-level enrollment status effective dates. As warning codes do not prohibit submission of reporting, UW-Madison did not review the warnings.
Fourth, in 2021 NSC similarly published information on accurately reporting student program begin dates in NSLDS and NSC had also identified instances of potential inaccurate reporting in UW Madison’s data from its student information system. Although NSC had communicated error or warning codes to UW-Madison in these areas, UW-Madison had not sufficiently reviewed whether the records identified by NSC as potential errors resulted in inaccurate reporting until 2023. At that time, UW-Madison indicated that, after reviewing other NSC warnings, it identified that it did not accurately report program begin dates for students. UW-Madison indicated it then began to work to update its student information system data extraction process to identify the correct program begin date for its submissions to NSC. However, it did not implement these changes until after the audit period.
In addition, UW-Madison indicated that it had turnover in staff responsible for NSLDS reporting in 2021, which may have caused UW-Madison to have missed the NSC publications regarding reporting graduated students accurately, new warning codes, and the importance of reviewing certain warning codes to accurately complete NSLDS reporting.
Recommendation:
We recommend the University of Wisconsin-Madison:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as updating its student information system to allow for an automated identification process to communicate those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated and implement separate reporting to the National Student Clearinghouse to accurately report students who graduate;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program-level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program begin dates and update its student information system extraction process to accurately report program begin dates; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-708: Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Background:
UW-Milwaukee receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Milwaukee reported a total of $133.1 million in federal financial assistance under the SFA Cluster. UW-Milwaukee records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Milwaukee is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Milwaukee is required to maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed.
Condition:
UW-Milwaukee uses NSC to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Milwaukee that identify potential errors in UW-Milwaukee’s reporting of student activities through NSC. These errors are the responsibility of UW-Milwaukee to resolve to ensure its submissions to NSLDS are accurate and complete.
UW-Milwaukee did not report to NSLDS accurate information for the program level enrollment status effective date for five students we reviewed. In addition, based on how information from its student information system is extracted for student reporting to NSLDS, we found that the reporting inaccuracy extended to other UW-Milwaukee students.
Context:
We discussed with UW-Milwaukee staff its procedures for identifying student enrollment status changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Milwaukee relies on data from its student information system to compile information to transmit to NSC. UW-Milwaukee also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included two students who withdrew from UW-Milwaukee and four students who graduated from UW- Milwaukee. In addition, we selected ten additional UW-Milwaukee students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Milwaukee did not comply with requirements to accurately report certain student enrollment status changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
In 2021, NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW- Milwaukee’s data from its student information system and had communicated error or warning codes to UW-Milwaukee in these areas. UW-Milwaukee staff indicated that they were aware that NSC error reports included warnings to identify potential inaccurate reporting of program level enrollment status effective dates and that the errors were a known issue for Peoplesoft-based student information systems. However, UW-Milwaukee chose not to use an all-record update feature that was available to correct the program-level enrollment status effective dates for all student records simultaneously due to the risk that other reporting inaccuracies could result from the action. Further, UW-Milwaukee staff indicated that they were not aware that specific guidance on the program-level enrollment status effective date had been updated to reflect that corrections should be made to fully comply with NSLDS reporting requirements.
Recommendation:
We recommend the University of Wisconsin-Milwaukee:
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates; and
-report changes in student enrollment accurately, completely, and in a timely manner for all student changes that require reporting.
Finding 2024-709: Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Milwaukee: The University of Wisconsin-Milwaukee agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Background:
UW-Oshkosh receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Oshkosh reported a total of $45.3 million in federal financial assistance under the SFA Cluster. UW-Oshkosh records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Oshkosh is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Oshkosh is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time; and
-report a student who has completed a program with a status of “graduated” rather than “withdrawn.”
Condition:
UW-Oshkosh uses NSC to facilitate the enrollment reporting in NSLDS. NSC provides error reports to UW-Oshkosh that identify potential errors in UW Oshkosh’s reporting of student activities. It is the responsibility of UW-Oshkosh to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Oshkosh did not report to NSLDS accurate information for two of the three students we reviewed.
First, UW-Oshkosh did not report in a timely manner one student who withdrew from enrollment without notification. Second, UW-Oshkosh incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment.
Context:
We discussed with UW-Oshkosh staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and UW Oshkosh’s procedures for monitoring the reporting performed by NSC. UW-Oshkosh relies on data from its student information system to compile information to transmit to NSC. UW-Oshkosh also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve. To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023 24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student who withdrew from UW-Oshkosh and two students who graduated from UW‑Oshkosh.
Questioned Costs:
None.
Effect:
UW-Oshkosh did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Oshkosh did not report to NSLDS in a timely manner who had withdrawn from enrollment without notification, we found that UW-Oshkosh indicated that it believed it needed to report to NSLDS only when students withdrew from enrollment and had notified UW-Oshkosh of the withdrawal. As a result, students detected by UW Oshkosh through procedures completed by the financial aid office at the end of each term were not communicated to those staff in the registrar’s office who were responsible for NSLDS reporting.
Second, for the student UW-Oshkosh did not accurately report as graduated within NSLDS, we found that inaccuracies in the reporting of students who had graduated were noted on NSC error reports. However, UW-Oshkosh’s registrar’s office staff did sufficiently review the errors to correct the status in NSLDS.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as communicating those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-710: Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Background:
UW Parkside operates in a highly computerized environment and is responsible for maintaining confidential and sensitive information, such as student data. UW Parkside maintains its own student information system to administer federal student financial assistance programs under the SFA Cluster.
Criteria:
To ensure data processed and stored by UW-Parkside is protected from accidental or intentional misuse or destruction, and to provide proper internal control, information technology (IT) security policies and procedures are necessary. In addition, IT controls should be established to prevent inappropriate or inadvertent access to data. UW-Parkside is responsible for following specific requirements under the Gramm-Leach-Bliley Act (GLBA), which requires entities that administer student financial assistance programs to develop, implement, and maintain safeguards to protect the security, integrity, and confidentiality of student data.
Under GLBA, UW-Parkside is required to authenticate and permit access only to authorized users. Further, UW Board of Regents Policy 25-5 requires that UW-Parkside follow the National Institute of Standards and Technology (NIST) in establishing IT controls. NIST Special Publication (SP) 800-53, Security and Privacy Controls for Information Systems and Organizations, recommends best practices in IT controls related to user access. These best practices include developing a provisioning and deprovisioning process focused on limiting access in a manner that provides the least access based on business need; retaining documentation of provisioning and deprovisioning activities, including records of when such access was added or removed; and performing periodic reviews of access to ensure it remains appropriate.
Condition:
We found UW-Parkside did not have adequate IT controls in place during FY 2023-24 to provision, deprovision, and manage access to its student information system. First, UW-Parkside did not have a formal documented process to provision or deprovision user access to its student information system. Second, UW-Parkside did not maintain a list of provisioned users with access and was unable to generate a report of users provisioned or deprovisioned during FY 2023-24. Third, UW-Parkside did not complete a periodic review of access, which assists in ensuring its provisioning and deprovisioning processes are working as intended. Although failure in any one IT control may be detected by complementary IT controls, UW‑Parkside did not have effective IT controls in any of the three areas. As a result, UW-Parkside was at a higher risk of granting unauthorized access to its student information system.
Context:
We reviewed GLBA requirements, UW System Board of Regents policies, and NIST 800-53 guidance to identify policies and procedures for UW-Parkside’s monitoring of access granted to its student information system. We requested documentation from UW-Parkside to assess compliance with these policies.
Questioned Costs:
None.
Effect:
Ineffective general IT controls may permit controls over systems to operate improperly and may allow noncompliance to occur and not be detected. Weaknesses in IT security policies, procedures, and controls increase the risk that unauthorized or erroneous transactions could be processed or changes made to student data. In addition, failure to provide an appropriate level of protection for its student information system and data increased the risk that personally identifiable information could be accidentally or maliciously exposed.
Cause:
UW-Parkside did not have a formal policy or procedures in place to provision, deprovision, and review access to its student information system. UW-Parkside staff indicated the process for provisioning and deprovisioning access had been informally operated, such as through electronic mail and direct communication and it did not consistently retain documentation of these communications. For example,
UW-Parkside indicated access requests were accepted from a variety of UW-Parkside employees. As a result, UW-Parkside had not assessed whether a user’s access was necessary or otherwise limited the access only to specific information needed or to a specified time period. Finally, UW-Parkside also indicated that prior efforts to improve its provisioning and deprovisioning of user access were not fully completed or implemented, in part, due to staff turnover.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-develop and implement written procedures for provisioning and deprovisioning user access to its student information system, including specifying those who are authorized to request user access and assigning responsibility to staff to assess access requests to restrict the access only to data needed for a specified period of time;
-retain consistent documentation of its provisioning and deprovisioning activities;
-develop and implement written procedures for a review at least annually of access granted to its student information system; and
-complete an assessment of users who currently have access to its student information system and remove those users who no longer require the access.
Finding 2024-711: Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Monthly Reconciliations
Background:
UW institutions receive funding for several grant and loan programs, such as Federal Direct Student Loans (Assistance Listing number 84.268) and the Federal Pell Grant Program (Assistance Listing number 84.063), from the U.S. Department of Education that are administered under the SFA Cluster. UW Oshkosh is required to comply with U.S. Department of Education requirements for disbursing funds to students under the Direct Student Loans and Pell Grant programs. This includes reporting disbursement activity in a U.S. Department of Education system in a timely manner. For FY 2023-24, UW-Oshkosh reported federal financial assistance of $29.7 million in Direct Student Loans and $10.3 million in Pell Grants.
Criteria:
Pursuant to 34 CFR s. 685.300 (b) (5), UW-Oshkosh is required to perform monthly reconciliations between U.S. Department of Education systems and its financial and business systems for all Direct Student Loans activity. The monthly reconciliations include two components:
-an external review between UW Oshkosh’s disbursements in its student information system compared to data in a U.S. Department of Education reporting system; and
-an internal reconciliation between UW Oshkosh’s student information system and its accounting system.
In addition, U.S. Department of Education guidance included in Volume 4, Chapter 5, of the Federal Student Aid Handbook, recommends that UW Oshkosh similarly complete monthly reconciliations for Pell Grant activity.
Condition:
Although UW-Oshkosh provided documentation for the external component of reconciliations it completed for the two months we selected to review for the Direct Student Loans and Pell Grant reconciliations during FY 2023 24, it did not provide documentation for the internal component of these reconciliations.
Context:
We reviewed and discussed UW Oshkosh’s procedures for performing monthly reconciliations for Direct Student Loans and Pell Grant disbursements. We selected two monthly Direct Student Loans and Pell Grant reconciliations and reviewed the internal and external reconciliation components for each month.
Questioned Costs:
None.
Effect:
Without documentation, UW-Oshkosh cannot be assured that it accurately completed the required reconciliations to identify whether Direct Student Loans or Pell Grant disbursements were properly reported to the U.S. Department of Education and other federal requirements were being met.
Cause:
UW-Oshkosh indicated that it was unable to locate documentation for the internal component of the reconciliation for the months we requested because the documentation was not retained in a shared folder. In addition, UW Oshkosh indicated that there had been staff turnover in the position that completed the reconciliations.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-ensure all required monthly reconciliations are completed in a timely manner; and
-retain documentation to support all monthly reconciliations it completes.
Finding 2024-700: Student Financial Assistance Cluster—UW-Oshkosh Monthly Reconciliations
Federal Pell Grant Program (Assistance Listing number 84.063)
Award Numbers Award Years
Various Various
Questioned Costs: None
Federal Direct Student Loans (Assistance Listing number 84.268)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-Madison must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. For students that begin attending classes, but who later withdraw from enrollment, 34 CFR s. 668.22 requires that UW-Madison must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In order not to consider a student to have withdrawn from enrollment under certain circumstances, which permits a student to retain federal financial assistance that otherwise would need to be returned to the federal government, 34 CFR s. 668.22 (a) (2) (ii) provides certain exemptions to students.
Condition:
For four students, we found that UW-Madison did not accurately determine the amount of federal financial assistance it disbursed that should have been returned to the U.S. Department of Education. First, we found that UW-Madison did not return all federal financial assistance it disbursed to two students that did not begin attendance and to one student who only attended one day during FY 2023-24. For these three students, UW-Madison determined it failed to return $16,403 in federal financial assistance it disbursed during FY 2023-24. Second, we found that UW-Madison did not accurately determine the federal financial assistance that should be returned after a student withdrew from enrollment during the summer 2023 term. For this student, UW-Madison incorrectly applied an exemption, which led to UW-Madison failing to return $584 in federal financial assistance to the U.S. Department of Education.
Context:
UW-Madison uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Madison staff its process for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Madison to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. When reviewing the data UW-Madison provided, we noted potential errors in the amount of aid returned for students identified as never attending.
Separately, as part of a UW systemwide sample of 60 students, we selected 6 students who had received federal financial assistance and who withdrew from enrollment from UW-Madison to determine the amount of federal financial assistance those students earned and the related amounts UW-Madison returned to the U.S. Department of Education.
Questioned Costs:
$16,987, Plus an Undetermined Amount
Effect:
UW-Madison did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Madison identified that the errors in determining the amount of the federal financial assistance that should have been returned to the federal government for the four students we identified were manual errors in the withdrawal procedures and calculations completed during and at the end of each term. These errors were not detected by any other review procedures. Although UW-Madison correctly identified the status of the two students who never attended and the need to return all disbursed federal financial assistance, it did not follow through on the actual repayment.
For the student who had an exemption applied, the exemption was incorrectly selected when UW-Madison completed a determination, and the error was not detected in UW-Madison’s review process. UW-Madison indicated that its automated review processes conducted at the end of each term did not specifically address the matters we identified for the four students.
After we identified these errors in the determination of the amount of federal financial assistance to return to the federal government, UW-Madison returned in fall 2024 the unearned federal financial assistance for the three students who never attended or withdrew from enrollment after attending one day. In addition, UW Madison returned the additional $584 in February 2025 for the student who withdrew from enrollment and did not meet the criteria for a withdrawal exemption.
Recommendation:
We recommend the University of Wisconsin-Madison review, update, and implement its procedures to improve the accuracy and follow-through for making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including thoroughly reviewing applied exemptions, and returning federal financial assistance in a timely manner to the federal government.
Finding 2024-703: Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,987, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Background:
UW-River Falls receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-River Falls reported a total of $23.6 million in federal financial assistance under the SFA Cluster. UW-River Falls is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-River Falls must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. Under Volume 5, Chapter 1 of the Federal Student Aid Handbook, when a student begins attendance in at least one course but does not begin attendance in all courses the student was scheduled to attend, the school must determine if it is necessary to recalculate the student’s eligibility for the Pell Grant based on a revised enrollment status and the cost of education pursuant to 34 CFR s. 690.80. If the student withdraws, this recalculation must be performed before determining whether to return federal financial assistance pursuant to 34 CFR s. 668.22.
Condition:
We found that UW-River Falls did not return $16,010 in federal financial assistance for four students that did not begin attendance in all enrolled courses during FY 2023-24. This included two students who never began attendance in any enrolled courses for whom all disbursed federal financial assistance was required to be returned. This also included two students who began at least one course but not all courses for which the students had enrolled. UW-River Falls did not perform the required recalculation of Pell Grant eligibility or an assessment of federal financial assistance it had disbursed that these students had not earned.
Context:
UW-River Falls uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-River Falls the process used for identifying students who did not begin attending all enrolled courses or withdrew from enrollment, and we requested a list of such students during FY 2023-24. UW-River Falls did not have a complete list readily available of students who did not begin attending all enrolled courses.
Questioned Costs:
$16,010, Plus an Undetermined Amount
Effect:
UW-River Falls did not comply with all requirements to return federal financial assistance for students who never attended or did not begin attending all enrolled courses during FY 2023-24.
Cause:
UW-River Falls did not have procedures to identify from its student information system, or other sources, those students for whom it disbursed federal financial assistance, yet the students did not attend at least one course during the term or begin all courses enrolled. Depending on whether a student dropped any of their courses, UW-River Falls indicated that the procedures to evaluate attendance may not have identified all students who would ultimately be determined as never attending for the academic term.
After we requested a list of students who did not begin attending all enrolled courses, UW-River Falls identified two students who did not begin at least one course but for whom it had disbursed federal financial assistance. For the other two students who began at least one course, UW-River Falls completed the required Pell Grant recalculation for the students. UW-River Falls also determined the amount of federal financial assistance to return for all four students, as applicable, to the U.S. Department of Education in September 2024.
Recommendation:
We recommend the University of Wisconsin-River Falls review, update, and implement procedures to:
-identify students after the start of each academic term for whom it disbursed federal financial assistance and the students did not begin all enrolled courses;
-complete required recalculations for Pell Grant eligibility and a determination of federal financial assistance that was not earned by the students, as applicable; and
-return amounts to the federal government in a timely manner.
Finding 2024-704: Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,010, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-River Falls: The University of Wisconsin-River Falls agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Background:
UW-Parkside receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Parkside reported a total of $21.3 million in federal financial assistance under the SFA Cluster. UW-Parkside is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22, requires that UW-Parkside must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW Parkside should be returned to the U.S. Department of Education unless certain conditions are met. In determining whether federal financial assistance was earned by a student, the Federal Student Aid Handbook provides guidance on how to calculate applicable institution charges and academic days under different circumstances.
Condition:
For two of three students we reviewed who withdrew from enrollment during FY 2023-24, UW-Parkside inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Parkside incorrectly accounted for a disbursement that occurred after the student’s withdrawal from enrollment as an amount that was earned by the student for the fall 2023 term. As a result, UW Parkside returned $548 less than what should have been returned to the U.S. Department of Education. For the second student, UW-Parkside incorrectly identified the end date of the spring 2024 term and did not include the correct institutional charges in its determination. As a result, UW-Parkside returned $1,190 less than should have been returned to the U.S. Department of Education.
Context:
UW-Parkside uses a student information system to track activity for students that withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Parkside staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from
UW-Parkside to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 3 students who had received federal financial assistance and withdrew from UW-Parkside to determine the amount of federal financial assistance those students earned and the related amounts UW-Parkside returned to the U.S. Department of Education.
Questioned Costs:
$1,738, Plus an Undetermined Amount
Effect:
UW-Parkside did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Parkside did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal assistance to return. Although UW-Parkside disbursed federal financial assistance later than is typical to one student, the disbursement was not correctly categorized within the calculations completed by UW-Parkside to determine that the entire amount of the federal financial assistance was required to be returned to the federal government.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the students we identified.
Finding 2024-705: Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $1,738, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Background:
UW-Platteville receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Platteville reported a total of $29.1 million in federal financial assistance under the SFA Cluster. UW-Platteville is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Under 34 CFR s. 668.21, UW-Platteville must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. In addition, when a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Platteville must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In determining whether federal financial assistance was earned by a student, Volume 5, Chapter 2 of the Federal Student Aid Handbook specifies how to calculate academic days.
Condition:
For two of the five students we reviewed who never began attendance or who withdrew from enrollment during FY 2023-24, UW-Platteville inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Platteville incorrectly determined the student began attendance because the student attended one day of the fall 2023 term. As a result, UW-Platteville failed to return $24 in federal financial assistance to the U.S. Department of Education. For the second student, UW-Platteville did not exclude a five-day break from its determination of the federal financial assistance amount the student had earned during the fall 2023 term. Although this student had earned all of the federal financial assistance prior to the student’s withdrawal from enrollment, UW-Platteville incorrectly returned $1,226. Because UW-Platteville used the same calculation for all determinations for the fall 2023 term, there may be further errors in the federal financial assistance amounts UW-Platteville determined.
Context:
UW-Platteville uses a student information system to track activity for students who withdraw from enrollment in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Platteville staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Platteville to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 5 students who had received federal financial assistance and who withdrew from UW-Platteville to determine the amount of federal financial assistance those students earned and the related amounts UW-Platteville returned to the U.S. Department of Education.
Questioned Costs:
$24, Plus an Undetermined Amount
Effect:
UW-Platteville did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Platteville did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal financial assistance to return to the federal government. After we identified the error for the student who attended only one day, UW-Platteville returned the additional $24 to the federal government in November 2024. For the fall 2023 term, UW-Platteville changed its fall break from four to five days, which required a change in the number of academic days used in the calculation of federal financial assistance earned when a student withdraws from enrollment. UW-Platteville did not have a process to review the academic calendar for purposes of its return procedures.
Recommendation:
We recommend the University of Wisconsin-Platteville review, update, and implement its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including annually reviewing the academic days used in its determinations.
Finding 2024-706: Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $24, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Platteville: The University of Wisconsin-Platteville agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Background:
UW-Whitewater receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Whitewater reported a total of $58.4 million in federal financial assistance under the SFA Cluster. UW-Whitewater is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Whitewater must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook, the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW-Whitewater is required to be returned to the U.S. Department of Education unless certain conditions are met.
Condition:
UW-Whitewater inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education for one of seven students we reviewed who withdrew from enrollment during FY 2023 24. UW-Whitewater incorrectly accounted for a disbursement to the student that occurred after the date for which UW-Whitewater later identified the student had withdrawn from enrollment as an amount that was earned by the student. As a result, UW-Whitewater failed to return $400 in federal financial assistance to the U.S. Department of Education for the spring 2024 term.
Context:
In order to determine the federal financial assistance a student earned and the amount that must be returned to the U.S. Department of Education for amounts a student did not earn, UW-Whitewater uses a student information system to track activity for students who withdraw. We discussed with UW-Whitewater staff the process used for identifying students who withdrew from enrollment. We also requested information from UW-Whitewater to identify students who withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 7 students who had received federal financial assistance and who withdrew from UW-Whitewater to determine the amount of federal financial assistance those students earned and the related amounts UW-Whitewater returned to the U.S. Department of Education.
Questioned Costs:
$400, Plus an Undetermined Amount
Effect:
UW-Whitewater did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Whitewater did not have adequate procedures to review and ensure its determination of the amount of federal assistance to return was accurate. Although UW-Whitewater disbursed federal financial assistance later than is typical to the student, the disbursement was not correctly categorized within the calculations completed by UW-Whitewater nor was the categorization error detected by other
UW-Whitewater procedures.
Recommendation:
We recommend the University of Wisconsin-Whitewater:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the student we identified.
Finding 2024-707: Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $400, Plus an Undetermined Amount
Type of Finding: Noncompliance
Response from the University of Wisconsin-Whitewater: The University of Wisconsin-Whitewater agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Madison is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to the National Student Loan Data System (NSLDS). Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Madison is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time;
-report the same effective date for a student who withdraws from enrollment as the date used in its determination of whether any federal financial assistance must be returned in accordance with
34 CFR s. 668.22;
-report a student who has completed a program with a status of “graduated” rather than “withdrawn”;
-maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed; and
-maintain the program begin date, which is the date the student first began attending the program being reported, if a student’s program of study has not changed.
Condition:
UW-Madison uses the National Student Clearinghouse (NSC) to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Madison that identify potential errors in UW-Madison’s reporting of student activities. It is the responsibility of UW-Madison to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Madison did not report to NSLDS accurate information for 12 of the 17 students we reviewed. First, UW-Madison did not accurately report a student who withdrew from enrollment without notification in a timely manner. Second, UW-Madison incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment. Third, UW-Madison incorrectly reported the program-level enrollment status effective date for two students. Fourth, UW-Madison incorrectly reported the program begin date for six students. In addition, UW Madison incorrectly reported both the program-level enrollment status effective date and program begin date for two students.
Context:
We discussed with UW-Madison staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Madison relies on data from its student information system to compile information to transmit to NSC. UW-Madison also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student that withdrew from UW-Madison and six students who graduated from UW-Madison. In addition, we selected ten additional UW-Madison students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Madison did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Madison did not report to NSLDS who had withdrawn from enrollment without notification, we found UW-Madison’s enrollment reporting procedures did not assign responsibility for communicating certain information to those staff in the registrar’s office who are responsible for NSLDS reporting. As a result, those students the financial aid office determined had withdrawn from enrollment without notification, and for which it had completed a determination of federal financial assistance the students did not earn, were not known to staff in the registrar’s office for purposes of NSLDS reporting. In addition, UW-Madison indicated that withdrawals from enrollment without notification are identified after the term ends and its student information system did not have a dedicated effective date field in order to automatically identify such student records for the required NSLDS reporting.
Second, for the student UW-Madison did not accurately report as graduated within NSLDS, we found UW‑Madison relied on a NSC process that is intended to simultaneously update a student’s enrollment status in NSLDS when UW-Madison separately updates a student’s degree as completed. UW-Madison did not complete a separate report to ensure the enrollment status for graduated students was accurately reflected in NSLDS. However, in 2022 NSC had published information that indicated reliance solely on NSC’s process may result in the incorrect status being reported under certain circumstances. Although NSC error reports identified that such errors were present, UW-Madison indicated that it did not review these errors until fall 2024 when it began implementing new U.S. Department of Education reporting requirements.
At that time, UW-Madison stated that it identified that it did not consistently and accurately report in NSLDS those students who had graduated. UW-Madison stated that it then began to work with NSC to identify the extent of the reporting inaccuracies.
Third, in 2021 NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW-Madison’s data from its student information system and had communicated error or warning codes to UW-Madison in these areas. However, UW-Madison did not sufficiently review whether the records identified by NSC as potential errors resulted in inaccurate reporting. For example, NSC used warning codes for potential errors in the program-level enrollment status effective dates. As warning codes do not prohibit submission of reporting, UW-Madison did not review the warnings.
Fourth, in 2021 NSC similarly published information on accurately reporting student program begin dates in NSLDS and NSC had also identified instances of potential inaccurate reporting in UW Madison’s data from its student information system. Although NSC had communicated error or warning codes to UW-Madison in these areas, UW-Madison had not sufficiently reviewed whether the records identified by NSC as potential errors resulted in inaccurate reporting until 2023. At that time, UW-Madison indicated that, after reviewing other NSC warnings, it identified that it did not accurately report program begin dates for students. UW-Madison indicated it then began to work to update its student information system data extraction process to identify the correct program begin date for its submissions to NSC. However, it did not implement these changes until after the audit period.
In addition, UW-Madison indicated that it had turnover in staff responsible for NSLDS reporting in 2021, which may have caused UW-Madison to have missed the NSC publications regarding reporting graduated students accurately, new warning codes, and the importance of reviewing certain warning codes to accurately complete NSLDS reporting.
Recommendation:
We recommend the University of Wisconsin-Madison:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as updating its student information system to allow for an automated identification process to communicate those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated and implement separate reporting to the National Student Clearinghouse to accurately report students who graduate;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program-level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program begin dates and update its student information system extraction process to accurately report program begin dates; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-708: Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Background:
UW-Milwaukee receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Milwaukee reported a total of $133.1 million in federal financial assistance under the SFA Cluster. UW-Milwaukee records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Milwaukee is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Milwaukee is required to maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed.
Condition:
UW-Milwaukee uses NSC to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Milwaukee that identify potential errors in UW-Milwaukee’s reporting of student activities through NSC. These errors are the responsibility of UW-Milwaukee to resolve to ensure its submissions to NSLDS are accurate and complete.
UW-Milwaukee did not report to NSLDS accurate information for the program level enrollment status effective date for five students we reviewed. In addition, based on how information from its student information system is extracted for student reporting to NSLDS, we found that the reporting inaccuracy extended to other UW-Milwaukee students.
Context:
We discussed with UW-Milwaukee staff its procedures for identifying student enrollment status changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Milwaukee relies on data from its student information system to compile information to transmit to NSC. UW-Milwaukee also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included two students who withdrew from UW-Milwaukee and four students who graduated from UW- Milwaukee. In addition, we selected ten additional UW-Milwaukee students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Milwaukee did not comply with requirements to accurately report certain student enrollment status changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
In 2021, NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW- Milwaukee’s data from its student information system and had communicated error or warning codes to UW-Milwaukee in these areas. UW-Milwaukee staff indicated that they were aware that NSC error reports included warnings to identify potential inaccurate reporting of program level enrollment status effective dates and that the errors were a known issue for Peoplesoft-based student information systems. However, UW-Milwaukee chose not to use an all-record update feature that was available to correct the program-level enrollment status effective dates for all student records simultaneously due to the risk that other reporting inaccuracies could result from the action. Further, UW-Milwaukee staff indicated that they were not aware that specific guidance on the program-level enrollment status effective date had been updated to reflect that corrections should be made to fully comply with NSLDS reporting requirements.
Recommendation:
We recommend the University of Wisconsin-Milwaukee:
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates; and
-report changes in student enrollment accurately, completely, and in a timely manner for all student changes that require reporting.
Finding 2024-709: Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Milwaukee: The University of Wisconsin-Milwaukee agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Background:
UW-Oshkosh receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Oshkosh reported a total of $45.3 million in federal financial assistance under the SFA Cluster. UW-Oshkosh records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Oshkosh is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Oshkosh is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time; and
-report a student who has completed a program with a status of “graduated” rather than “withdrawn.”
Condition:
UW-Oshkosh uses NSC to facilitate the enrollment reporting in NSLDS. NSC provides error reports to UW-Oshkosh that identify potential errors in UW Oshkosh’s reporting of student activities. It is the responsibility of UW-Oshkosh to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Oshkosh did not report to NSLDS accurate information for two of the three students we reviewed.
First, UW-Oshkosh did not report in a timely manner one student who withdrew from enrollment without notification. Second, UW-Oshkosh incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment.
Context:
We discussed with UW-Oshkosh staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and UW Oshkosh’s procedures for monitoring the reporting performed by NSC. UW-Oshkosh relies on data from its student information system to compile information to transmit to NSC. UW-Oshkosh also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve. To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023 24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student who withdrew from UW-Oshkosh and two students who graduated from UW‑Oshkosh.
Questioned Costs:
None.
Effect:
UW-Oshkosh did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Oshkosh did not report to NSLDS in a timely manner who had withdrawn from enrollment without notification, we found that UW-Oshkosh indicated that it believed it needed to report to NSLDS only when students withdrew from enrollment and had notified UW-Oshkosh of the withdrawal. As a result, students detected by UW Oshkosh through procedures completed by the financial aid office at the end of each term were not communicated to those staff in the registrar’s office who were responsible for NSLDS reporting.
Second, for the student UW-Oshkosh did not accurately report as graduated within NSLDS, we found that inaccuracies in the reporting of students who had graduated were noted on NSC error reports. However, UW-Oshkosh’s registrar’s office staff did sufficiently review the errors to correct the status in NSLDS.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as communicating those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-710: Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Background:
UW Parkside operates in a highly computerized environment and is responsible for maintaining confidential and sensitive information, such as student data. UW Parkside maintains its own student information system to administer federal student financial assistance programs under the SFA Cluster.
Criteria:
To ensure data processed and stored by UW-Parkside is protected from accidental or intentional misuse or destruction, and to provide proper internal control, information technology (IT) security policies and procedures are necessary. In addition, IT controls should be established to prevent inappropriate or inadvertent access to data. UW-Parkside is responsible for following specific requirements under the Gramm-Leach-Bliley Act (GLBA), which requires entities that administer student financial assistance programs to develop, implement, and maintain safeguards to protect the security, integrity, and confidentiality of student data.
Under GLBA, UW-Parkside is required to authenticate and permit access only to authorized users. Further, UW Board of Regents Policy 25-5 requires that UW-Parkside follow the National Institute of Standards and Technology (NIST) in establishing IT controls. NIST Special Publication (SP) 800-53, Security and Privacy Controls for Information Systems and Organizations, recommends best practices in IT controls related to user access. These best practices include developing a provisioning and deprovisioning process focused on limiting access in a manner that provides the least access based on business need; retaining documentation of provisioning and deprovisioning activities, including records of when such access was added or removed; and performing periodic reviews of access to ensure it remains appropriate.
Condition:
We found UW-Parkside did not have adequate IT controls in place during FY 2023-24 to provision, deprovision, and manage access to its student information system. First, UW-Parkside did not have a formal documented process to provision or deprovision user access to its student information system. Second, UW-Parkside did not maintain a list of provisioned users with access and was unable to generate a report of users provisioned or deprovisioned during FY 2023-24. Third, UW-Parkside did not complete a periodic review of access, which assists in ensuring its provisioning and deprovisioning processes are working as intended. Although failure in any one IT control may be detected by complementary IT controls, UW‑Parkside did not have effective IT controls in any of the three areas. As a result, UW-Parkside was at a higher risk of granting unauthorized access to its student information system.
Context:
We reviewed GLBA requirements, UW System Board of Regents policies, and NIST 800-53 guidance to identify policies and procedures for UW-Parkside’s monitoring of access granted to its student information system. We requested documentation from UW-Parkside to assess compliance with these policies.
Questioned Costs:
None.
Effect:
Ineffective general IT controls may permit controls over systems to operate improperly and may allow noncompliance to occur and not be detected. Weaknesses in IT security policies, procedures, and controls increase the risk that unauthorized or erroneous transactions could be processed or changes made to student data. In addition, failure to provide an appropriate level of protection for its student information system and data increased the risk that personally identifiable information could be accidentally or maliciously exposed.
Cause:
UW-Parkside did not have a formal policy or procedures in place to provision, deprovision, and review access to its student information system. UW-Parkside staff indicated the process for provisioning and deprovisioning access had been informally operated, such as through electronic mail and direct communication and it did not consistently retain documentation of these communications. For example,
UW-Parkside indicated access requests were accepted from a variety of UW-Parkside employees. As a result, UW-Parkside had not assessed whether a user’s access was necessary or otherwise limited the access only to specific information needed or to a specified time period. Finally, UW-Parkside also indicated that prior efforts to improve its provisioning and deprovisioning of user access were not fully completed or implemented, in part, due to staff turnover.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-develop and implement written procedures for provisioning and deprovisioning user access to its student information system, including specifying those who are authorized to request user access and assigning responsibility to staff to assess access requests to restrict the access only to data needed for a specified period of time;
-retain consistent documentation of its provisioning and deprovisioning activities;
-develop and implement written procedures for a review at least annually of access granted to its student information system; and
-complete an assessment of users who currently have access to its student information system and remove those users who no longer require the access.
Finding 2024-711: Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Monthly Reconciliations
Background:
UW institutions receive funding for several grant and loan programs, such as Federal Direct Student Loans (Assistance Listing number 84.268) and the Federal Pell Grant Program (Assistance Listing number 84.063), from the U.S. Department of Education that are administered under the SFA Cluster. UW Oshkosh is required to comply with U.S. Department of Education requirements for disbursing funds to students under the Direct Student Loans and Pell Grant programs. This includes reporting disbursement activity in a U.S. Department of Education system in a timely manner. For FY 2023-24, UW-Oshkosh reported federal financial assistance of $29.7 million in Direct Student Loans and $10.3 million in Pell Grants.
Criteria:
Pursuant to 34 CFR s. 685.300 (b) (5), UW-Oshkosh is required to perform monthly reconciliations between U.S. Department of Education systems and its financial and business systems for all Direct Student Loans activity. The monthly reconciliations include two components:
-an external review between UW Oshkosh’s disbursements in its student information system compared to data in a U.S. Department of Education reporting system; and
-an internal reconciliation between UW Oshkosh’s student information system and its accounting system.
In addition, U.S. Department of Education guidance included in Volume 4, Chapter 5, of the Federal Student Aid Handbook, recommends that UW Oshkosh similarly complete monthly reconciliations for Pell Grant activity.
Condition:
Although UW-Oshkosh provided documentation for the external component of reconciliations it completed for the two months we selected to review for the Direct Student Loans and Pell Grant reconciliations during FY 2023 24, it did not provide documentation for the internal component of these reconciliations.
Context:
We reviewed and discussed UW Oshkosh’s procedures for performing monthly reconciliations for Direct Student Loans and Pell Grant disbursements. We selected two monthly Direct Student Loans and Pell Grant reconciliations and reviewed the internal and external reconciliation components for each month.
Questioned Costs:
None.
Effect:
Without documentation, UW-Oshkosh cannot be assured that it accurately completed the required reconciliations to identify whether Direct Student Loans or Pell Grant disbursements were properly reported to the U.S. Department of Education and other federal requirements were being met.
Cause:
UW-Oshkosh indicated that it was unable to locate documentation for the internal component of the reconciliation for the months we requested because the documentation was not retained in a shared folder. In addition, UW Oshkosh indicated that there had been staff turnover in the position that completed the reconciliations.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-ensure all required monthly reconciliations are completed in a timely manner; and
-retain documentation to support all monthly reconciliations it completes.
Finding 2024-700: Student Financial Assistance Cluster—UW-Oshkosh Monthly Reconciliations
Federal Pell Grant Program (Assistance Listing number 84.063)
Award Numbers Award Years
Various Various
Questioned Costs: None
Federal Direct Student Loans (Assistance Listing number 84.268)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-Madison must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. For students that begin attending classes, but who later withdraw from enrollment, 34 CFR s. 668.22 requires that UW-Madison must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In order not to consider a student to have withdrawn from enrollment under certain circumstances, which permits a student to retain federal financial assistance that otherwise would need to be returned to the federal government, 34 CFR s. 668.22 (a) (2) (ii) provides certain exemptions to students.
Condition:
For four students, we found that UW-Madison did not accurately determine the amount of federal financial assistance it disbursed that should have been returned to the U.S. Department of Education. First, we found that UW-Madison did not return all federal financial assistance it disbursed to two students that did not begin attendance and to one student who only attended one day during FY 2023-24. For these three students, UW-Madison determined it failed to return $16,403 in federal financial assistance it disbursed during FY 2023-24. Second, we found that UW-Madison did not accurately determine the federal financial assistance that should be returned after a student withdrew from enrollment during the summer 2023 term. For this student, UW-Madison incorrectly applied an exemption, which led to UW-Madison failing to return $584 in federal financial assistance to the U.S. Department of Education.
Context:
UW-Madison uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Madison staff its process for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Madison to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. When reviewing the data UW-Madison provided, we noted potential errors in the amount of aid returned for students identified as never attending.
Separately, as part of a UW systemwide sample of 60 students, we selected 6 students who had received federal financial assistance and who withdrew from enrollment from UW-Madison to determine the amount of federal financial assistance those students earned and the related amounts UW-Madison returned to the U.S. Department of Education.
Questioned Costs:
$16,987, Plus an Undetermined Amount
Effect:
UW-Madison did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Madison identified that the errors in determining the amount of the federal financial assistance that should have been returned to the federal government for the four students we identified were manual errors in the withdrawal procedures and calculations completed during and at the end of each term. These errors were not detected by any other review procedures. Although UW-Madison correctly identified the status of the two students who never attended and the need to return all disbursed federal financial assistance, it did not follow through on the actual repayment.
For the student who had an exemption applied, the exemption was incorrectly selected when UW-Madison completed a determination, and the error was not detected in UW-Madison’s review process. UW-Madison indicated that its automated review processes conducted at the end of each term did not specifically address the matters we identified for the four students.
After we identified these errors in the determination of the amount of federal financial assistance to return to the federal government, UW-Madison returned in fall 2024 the unearned federal financial assistance for the three students who never attended or withdrew from enrollment after attending one day. In addition, UW Madison returned the additional $584 in February 2025 for the student who withdrew from enrollment and did not meet the criteria for a withdrawal exemption.
Recommendation:
We recommend the University of Wisconsin-Madison review, update, and implement its procedures to improve the accuracy and follow-through for making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including thoroughly reviewing applied exemptions, and returning federal financial assistance in a timely manner to the federal government.
Finding 2024-703: Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,987, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Background:
UW-River Falls receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-River Falls reported a total of $23.6 million in federal financial assistance under the SFA Cluster. UW-River Falls is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-River Falls must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. Under Volume 5, Chapter 1 of the Federal Student Aid Handbook, when a student begins attendance in at least one course but does not begin attendance in all courses the student was scheduled to attend, the school must determine if it is necessary to recalculate the student’s eligibility for the Pell Grant based on a revised enrollment status and the cost of education pursuant to 34 CFR s. 690.80. If the student withdraws, this recalculation must be performed before determining whether to return federal financial assistance pursuant to 34 CFR s. 668.22.
Condition:
We found that UW-River Falls did not return $16,010 in federal financial assistance for four students that did not begin attendance in all enrolled courses during FY 2023-24. This included two students who never began attendance in any enrolled courses for whom all disbursed federal financial assistance was required to be returned. This also included two students who began at least one course but not all courses for which the students had enrolled. UW-River Falls did not perform the required recalculation of Pell Grant eligibility or an assessment of federal financial assistance it had disbursed that these students had not earned.
Context:
UW-River Falls uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-River Falls the process used for identifying students who did not begin attending all enrolled courses or withdrew from enrollment, and we requested a list of such students during FY 2023-24. UW-River Falls did not have a complete list readily available of students who did not begin attending all enrolled courses.
Questioned Costs:
$16,010, Plus an Undetermined Amount
Effect:
UW-River Falls did not comply with all requirements to return federal financial assistance for students who never attended or did not begin attending all enrolled courses during FY 2023-24.
Cause:
UW-River Falls did not have procedures to identify from its student information system, or other sources, those students for whom it disbursed federal financial assistance, yet the students did not attend at least one course during the term or begin all courses enrolled. Depending on whether a student dropped any of their courses, UW-River Falls indicated that the procedures to evaluate attendance may not have identified all students who would ultimately be determined as never attending for the academic term.
After we requested a list of students who did not begin attending all enrolled courses, UW-River Falls identified two students who did not begin at least one course but for whom it had disbursed federal financial assistance. For the other two students who began at least one course, UW-River Falls completed the required Pell Grant recalculation for the students. UW-River Falls also determined the amount of federal financial assistance to return for all four students, as applicable, to the U.S. Department of Education in September 2024.
Recommendation:
We recommend the University of Wisconsin-River Falls review, update, and implement procedures to:
-identify students after the start of each academic term for whom it disbursed federal financial assistance and the students did not begin all enrolled courses;
-complete required recalculations for Pell Grant eligibility and a determination of federal financial assistance that was not earned by the students, as applicable; and
-return amounts to the federal government in a timely manner.
Finding 2024-704: Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,010, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-River Falls: The University of Wisconsin-River Falls agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Background:
UW-Parkside receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Parkside reported a total of $21.3 million in federal financial assistance under the SFA Cluster. UW-Parkside is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22, requires that UW-Parkside must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW Parkside should be returned to the U.S. Department of Education unless certain conditions are met. In determining whether federal financial assistance was earned by a student, the Federal Student Aid Handbook provides guidance on how to calculate applicable institution charges and academic days under different circumstances.
Condition:
For two of three students we reviewed who withdrew from enrollment during FY 2023-24, UW-Parkside inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Parkside incorrectly accounted for a disbursement that occurred after the student’s withdrawal from enrollment as an amount that was earned by the student for the fall 2023 term. As a result, UW Parkside returned $548 less than what should have been returned to the U.S. Department of Education. For the second student, UW-Parkside incorrectly identified the end date of the spring 2024 term and did not include the correct institutional charges in its determination. As a result, UW-Parkside returned $1,190 less than should have been returned to the U.S. Department of Education.
Context:
UW-Parkside uses a student information system to track activity for students that withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Parkside staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from
UW-Parkside to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 3 students who had received federal financial assistance and withdrew from UW-Parkside to determine the amount of federal financial assistance those students earned and the related amounts UW-Parkside returned to the U.S. Department of Education.
Questioned Costs:
$1,738, Plus an Undetermined Amount
Effect:
UW-Parkside did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Parkside did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal assistance to return. Although UW-Parkside disbursed federal financial assistance later than is typical to one student, the disbursement was not correctly categorized within the calculations completed by UW-Parkside to determine that the entire amount of the federal financial assistance was required to be returned to the federal government.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the students we identified.
Finding 2024-705: Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $1,738, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Background:
UW-Platteville receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Platteville reported a total of $29.1 million in federal financial assistance under the SFA Cluster. UW-Platteville is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Under 34 CFR s. 668.21, UW-Platteville must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. In addition, when a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Platteville must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In determining whether federal financial assistance was earned by a student, Volume 5, Chapter 2 of the Federal Student Aid Handbook specifies how to calculate academic days.
Condition:
For two of the five students we reviewed who never began attendance or who withdrew from enrollment during FY 2023-24, UW-Platteville inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Platteville incorrectly determined the student began attendance because the student attended one day of the fall 2023 term. As a result, UW-Platteville failed to return $24 in federal financial assistance to the U.S. Department of Education. For the second student, UW-Platteville did not exclude a five-day break from its determination of the federal financial assistance amount the student had earned during the fall 2023 term. Although this student had earned all of the federal financial assistance prior to the student’s withdrawal from enrollment, UW-Platteville incorrectly returned $1,226. Because UW-Platteville used the same calculation for all determinations for the fall 2023 term, there may be further errors in the federal financial assistance amounts UW-Platteville determined.
Context:
UW-Platteville uses a student information system to track activity for students who withdraw from enrollment in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Platteville staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Platteville to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 5 students who had received federal financial assistance and who withdrew from UW-Platteville to determine the amount of federal financial assistance those students earned and the related amounts UW-Platteville returned to the U.S. Department of Education.
Questioned Costs:
$24, Plus an Undetermined Amount
Effect:
UW-Platteville did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Platteville did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal financial assistance to return to the federal government. After we identified the error for the student who attended only one day, UW-Platteville returned the additional $24 to the federal government in November 2024. For the fall 2023 term, UW-Platteville changed its fall break from four to five days, which required a change in the number of academic days used in the calculation of federal financial assistance earned when a student withdraws from enrollment. UW-Platteville did not have a process to review the academic calendar for purposes of its return procedures.
Recommendation:
We recommend the University of Wisconsin-Platteville review, update, and implement its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including annually reviewing the academic days used in its determinations.
Finding 2024-706: Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $24, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Platteville: The University of Wisconsin-Platteville agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Background:
UW-Whitewater receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Whitewater reported a total of $58.4 million in federal financial assistance under the SFA Cluster. UW-Whitewater is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Whitewater must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook, the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW-Whitewater is required to be returned to the U.S. Department of Education unless certain conditions are met.
Condition:
UW-Whitewater inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education for one of seven students we reviewed who withdrew from enrollment during FY 2023 24. UW-Whitewater incorrectly accounted for a disbursement to the student that occurred after the date for which UW-Whitewater later identified the student had withdrawn from enrollment as an amount that was earned by the student. As a result, UW-Whitewater failed to return $400 in federal financial assistance to the U.S. Department of Education for the spring 2024 term.
Context:
In order to determine the federal financial assistance a student earned and the amount that must be returned to the U.S. Department of Education for amounts a student did not earn, UW-Whitewater uses a student information system to track activity for students who withdraw. We discussed with UW-Whitewater staff the process used for identifying students who withdrew from enrollment. We also requested information from UW-Whitewater to identify students who withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 7 students who had received federal financial assistance and who withdrew from UW-Whitewater to determine the amount of federal financial assistance those students earned and the related amounts UW-Whitewater returned to the U.S. Department of Education.
Questioned Costs:
$400, Plus an Undetermined Amount
Effect:
UW-Whitewater did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Whitewater did not have adequate procedures to review and ensure its determination of the amount of federal assistance to return was accurate. Although UW-Whitewater disbursed federal financial assistance later than is typical to the student, the disbursement was not correctly categorized within the calculations completed by UW-Whitewater nor was the categorization error detected by other
UW-Whitewater procedures.
Recommendation:
We recommend the University of Wisconsin-Whitewater:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the student we identified.
Finding 2024-707: Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $400, Plus an Undetermined Amount
Type of Finding: Noncompliance
Response from the University of Wisconsin-Whitewater: The University of Wisconsin-Whitewater agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Madison is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to the National Student Loan Data System (NSLDS). Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Madison is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time;
-report the same effective date for a student who withdraws from enrollment as the date used in its determination of whether any federal financial assistance must be returned in accordance with
34 CFR s. 668.22;
-report a student who has completed a program with a status of “graduated” rather than “withdrawn”;
-maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed; and
-maintain the program begin date, which is the date the student first began attending the program being reported, if a student’s program of study has not changed.
Condition:
UW-Madison uses the National Student Clearinghouse (NSC) to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Madison that identify potential errors in UW-Madison’s reporting of student activities. It is the responsibility of UW-Madison to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Madison did not report to NSLDS accurate information for 12 of the 17 students we reviewed. First, UW-Madison did not accurately report a student who withdrew from enrollment without notification in a timely manner. Second, UW-Madison incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment. Third, UW-Madison incorrectly reported the program-level enrollment status effective date for two students. Fourth, UW-Madison incorrectly reported the program begin date for six students. In addition, UW Madison incorrectly reported both the program-level enrollment status effective date and program begin date for two students.
Context:
We discussed with UW-Madison staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Madison relies on data from its student information system to compile information to transmit to NSC. UW-Madison also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student that withdrew from UW-Madison and six students who graduated from UW-Madison. In addition, we selected ten additional UW-Madison students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Madison did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Madison did not report to NSLDS who had withdrawn from enrollment without notification, we found UW-Madison’s enrollment reporting procedures did not assign responsibility for communicating certain information to those staff in the registrar’s office who are responsible for NSLDS reporting. As a result, those students the financial aid office determined had withdrawn from enrollment without notification, and for which it had completed a determination of federal financial assistance the students did not earn, were not known to staff in the registrar’s office for purposes of NSLDS reporting. In addition, UW-Madison indicated that withdrawals from enrollment without notification are identified after the term ends and its student information system did not have a dedicated effective date field in order to automatically identify such student records for the required NSLDS reporting.
Second, for the student UW-Madison did not accurately report as graduated within NSLDS, we found UW‑Madison relied on a NSC process that is intended to simultaneously update a student’s enrollment status in NSLDS when UW-Madison separately updates a student’s degree as completed. UW-Madison did not complete a separate report to ensure the enrollment status for graduated students was accurately reflected in NSLDS. However, in 2022 NSC had published information that indicated reliance solely on NSC’s process may result in the incorrect status being reported under certain circumstances. Although NSC error reports identified that such errors were present, UW-Madison indicated that it did not review these errors until fall 2024 when it began implementing new U.S. Department of Education reporting requirements.
At that time, UW-Madison stated that it identified that it did not consistently and accurately report in NSLDS those students who had graduated. UW-Madison stated that it then began to work with NSC to identify the extent of the reporting inaccuracies.
Third, in 2021 NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW-Madison’s data from its student information system and had communicated error or warning codes to UW-Madison in these areas. However, UW-Madison did not sufficiently review whether the records identified by NSC as potential errors resulted in inaccurate reporting. For example, NSC used warning codes for potential errors in the program-level enrollment status effective dates. As warning codes do not prohibit submission of reporting, UW-Madison did not review the warnings.
Fourth, in 2021 NSC similarly published information on accurately reporting student program begin dates in NSLDS and NSC had also identified instances of potential inaccurate reporting in UW Madison’s data from its student information system. Although NSC had communicated error or warning codes to UW-Madison in these areas, UW-Madison had not sufficiently reviewed whether the records identified by NSC as potential errors resulted in inaccurate reporting until 2023. At that time, UW-Madison indicated that, after reviewing other NSC warnings, it identified that it did not accurately report program begin dates for students. UW-Madison indicated it then began to work to update its student information system data extraction process to identify the correct program begin date for its submissions to NSC. However, it did not implement these changes until after the audit period.
In addition, UW-Madison indicated that it had turnover in staff responsible for NSLDS reporting in 2021, which may have caused UW-Madison to have missed the NSC publications regarding reporting graduated students accurately, new warning codes, and the importance of reviewing certain warning codes to accurately complete NSLDS reporting.
Recommendation:
We recommend the University of Wisconsin-Madison:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as updating its student information system to allow for an automated identification process to communicate those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated and implement separate reporting to the National Student Clearinghouse to accurately report students who graduate;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program-level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program begin dates and update its student information system extraction process to accurately report program begin dates; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-708: Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Background:
UW-Milwaukee receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Milwaukee reported a total of $133.1 million in federal financial assistance under the SFA Cluster. UW-Milwaukee records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Milwaukee is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Milwaukee is required to maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed.
Condition:
UW-Milwaukee uses NSC to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Milwaukee that identify potential errors in UW-Milwaukee’s reporting of student activities through NSC. These errors are the responsibility of UW-Milwaukee to resolve to ensure its submissions to NSLDS are accurate and complete.
UW-Milwaukee did not report to NSLDS accurate information for the program level enrollment status effective date for five students we reviewed. In addition, based on how information from its student information system is extracted for student reporting to NSLDS, we found that the reporting inaccuracy extended to other UW-Milwaukee students.
Context:
We discussed with UW-Milwaukee staff its procedures for identifying student enrollment status changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Milwaukee relies on data from its student information system to compile information to transmit to NSC. UW-Milwaukee also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included two students who withdrew from UW-Milwaukee and four students who graduated from UW- Milwaukee. In addition, we selected ten additional UW-Milwaukee students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Milwaukee did not comply with requirements to accurately report certain student enrollment status changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
In 2021, NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW- Milwaukee’s data from its student information system and had communicated error or warning codes to UW-Milwaukee in these areas. UW-Milwaukee staff indicated that they were aware that NSC error reports included warnings to identify potential inaccurate reporting of program level enrollment status effective dates and that the errors were a known issue for Peoplesoft-based student information systems. However, UW-Milwaukee chose not to use an all-record update feature that was available to correct the program-level enrollment status effective dates for all student records simultaneously due to the risk that other reporting inaccuracies could result from the action. Further, UW-Milwaukee staff indicated that they were not aware that specific guidance on the program-level enrollment status effective date had been updated to reflect that corrections should be made to fully comply with NSLDS reporting requirements.
Recommendation:
We recommend the University of Wisconsin-Milwaukee:
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates; and
-report changes in student enrollment accurately, completely, and in a timely manner for all student changes that require reporting.
Finding 2024-709: Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Milwaukee: The University of Wisconsin-Milwaukee agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Background:
UW-Oshkosh receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Oshkosh reported a total of $45.3 million in federal financial assistance under the SFA Cluster. UW-Oshkosh records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Oshkosh is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Oshkosh is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time; and
-report a student who has completed a program with a status of “graduated” rather than “withdrawn.”
Condition:
UW-Oshkosh uses NSC to facilitate the enrollment reporting in NSLDS. NSC provides error reports to UW-Oshkosh that identify potential errors in UW Oshkosh’s reporting of student activities. It is the responsibility of UW-Oshkosh to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Oshkosh did not report to NSLDS accurate information for two of the three students we reviewed.
First, UW-Oshkosh did not report in a timely manner one student who withdrew from enrollment without notification. Second, UW-Oshkosh incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment.
Context:
We discussed with UW-Oshkosh staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and UW Oshkosh’s procedures for monitoring the reporting performed by NSC. UW-Oshkosh relies on data from its student information system to compile information to transmit to NSC. UW-Oshkosh also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve. To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023 24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student who withdrew from UW-Oshkosh and two students who graduated from UW‑Oshkosh.
Questioned Costs:
None.
Effect:
UW-Oshkosh did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Oshkosh did not report to NSLDS in a timely manner who had withdrawn from enrollment without notification, we found that UW-Oshkosh indicated that it believed it needed to report to NSLDS only when students withdrew from enrollment and had notified UW-Oshkosh of the withdrawal. As a result, students detected by UW Oshkosh through procedures completed by the financial aid office at the end of each term were not communicated to those staff in the registrar’s office who were responsible for NSLDS reporting.
Second, for the student UW-Oshkosh did not accurately report as graduated within NSLDS, we found that inaccuracies in the reporting of students who had graduated were noted on NSC error reports. However, UW-Oshkosh’s registrar’s office staff did sufficiently review the errors to correct the status in NSLDS.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as communicating those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-710: Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Background:
UW Parkside operates in a highly computerized environment and is responsible for maintaining confidential and sensitive information, such as student data. UW Parkside maintains its own student information system to administer federal student financial assistance programs under the SFA Cluster.
Criteria:
To ensure data processed and stored by UW-Parkside is protected from accidental or intentional misuse or destruction, and to provide proper internal control, information technology (IT) security policies and procedures are necessary. In addition, IT controls should be established to prevent inappropriate or inadvertent access to data. UW-Parkside is responsible for following specific requirements under the Gramm-Leach-Bliley Act (GLBA), which requires entities that administer student financial assistance programs to develop, implement, and maintain safeguards to protect the security, integrity, and confidentiality of student data.
Under GLBA, UW-Parkside is required to authenticate and permit access only to authorized users. Further, UW Board of Regents Policy 25-5 requires that UW-Parkside follow the National Institute of Standards and Technology (NIST) in establishing IT controls. NIST Special Publication (SP) 800-53, Security and Privacy Controls for Information Systems and Organizations, recommends best practices in IT controls related to user access. These best practices include developing a provisioning and deprovisioning process focused on limiting access in a manner that provides the least access based on business need; retaining documentation of provisioning and deprovisioning activities, including records of when such access was added or removed; and performing periodic reviews of access to ensure it remains appropriate.
Condition:
We found UW-Parkside did not have adequate IT controls in place during FY 2023-24 to provision, deprovision, and manage access to its student information system. First, UW-Parkside did not have a formal documented process to provision or deprovision user access to its student information system. Second, UW-Parkside did not maintain a list of provisioned users with access and was unable to generate a report of users provisioned or deprovisioned during FY 2023-24. Third, UW-Parkside did not complete a periodic review of access, which assists in ensuring its provisioning and deprovisioning processes are working as intended. Although failure in any one IT control may be detected by complementary IT controls, UW‑Parkside did not have effective IT controls in any of the three areas. As a result, UW-Parkside was at a higher risk of granting unauthorized access to its student information system.
Context:
We reviewed GLBA requirements, UW System Board of Regents policies, and NIST 800-53 guidance to identify policies and procedures for UW-Parkside’s monitoring of access granted to its student information system. We requested documentation from UW-Parkside to assess compliance with these policies.
Questioned Costs:
None.
Effect:
Ineffective general IT controls may permit controls over systems to operate improperly and may allow noncompliance to occur and not be detected. Weaknesses in IT security policies, procedures, and controls increase the risk that unauthorized or erroneous transactions could be processed or changes made to student data. In addition, failure to provide an appropriate level of protection for its student information system and data increased the risk that personally identifiable information could be accidentally or maliciously exposed.
Cause:
UW-Parkside did not have a formal policy or procedures in place to provision, deprovision, and review access to its student information system. UW-Parkside staff indicated the process for provisioning and deprovisioning access had been informally operated, such as through electronic mail and direct communication and it did not consistently retain documentation of these communications. For example,
UW-Parkside indicated access requests were accepted from a variety of UW-Parkside employees. As a result, UW-Parkside had not assessed whether a user’s access was necessary or otherwise limited the access only to specific information needed or to a specified time period. Finally, UW-Parkside also indicated that prior efforts to improve its provisioning and deprovisioning of user access were not fully completed or implemented, in part, due to staff turnover.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-develop and implement written procedures for provisioning and deprovisioning user access to its student information system, including specifying those who are authorized to request user access and assigning responsibility to staff to assess access requests to restrict the access only to data needed for a specified period of time;
-retain consistent documentation of its provisioning and deprovisioning activities;
-develop and implement written procedures for a review at least annually of access granted to its student information system; and
-complete an assessment of users who currently have access to its student information system and remove those users who no longer require the access.
Finding 2024-711: Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-Madison must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. For students that begin attending classes, but who later withdraw from enrollment, 34 CFR s. 668.22 requires that UW-Madison must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In order not to consider a student to have withdrawn from enrollment under certain circumstances, which permits a student to retain federal financial assistance that otherwise would need to be returned to the federal government, 34 CFR s. 668.22 (a) (2) (ii) provides certain exemptions to students.
Condition:
For four students, we found that UW-Madison did not accurately determine the amount of federal financial assistance it disbursed that should have been returned to the U.S. Department of Education. First, we found that UW-Madison did not return all federal financial assistance it disbursed to two students that did not begin attendance and to one student who only attended one day during FY 2023-24. For these three students, UW-Madison determined it failed to return $16,403 in federal financial assistance it disbursed during FY 2023-24. Second, we found that UW-Madison did not accurately determine the federal financial assistance that should be returned after a student withdrew from enrollment during the summer 2023 term. For this student, UW-Madison incorrectly applied an exemption, which led to UW-Madison failing to return $584 in federal financial assistance to the U.S. Department of Education.
Context:
UW-Madison uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Madison staff its process for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Madison to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. When reviewing the data UW-Madison provided, we noted potential errors in the amount of aid returned for students identified as never attending.
Separately, as part of a UW systemwide sample of 60 students, we selected 6 students who had received federal financial assistance and who withdrew from enrollment from UW-Madison to determine the amount of federal financial assistance those students earned and the related amounts UW-Madison returned to the U.S. Department of Education.
Questioned Costs:
$16,987, Plus an Undetermined Amount
Effect:
UW-Madison did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Madison identified that the errors in determining the amount of the federal financial assistance that should have been returned to the federal government for the four students we identified were manual errors in the withdrawal procedures and calculations completed during and at the end of each term. These errors were not detected by any other review procedures. Although UW-Madison correctly identified the status of the two students who never attended and the need to return all disbursed federal financial assistance, it did not follow through on the actual repayment.
For the student who had an exemption applied, the exemption was incorrectly selected when UW-Madison completed a determination, and the error was not detected in UW-Madison’s review process. UW-Madison indicated that its automated review processes conducted at the end of each term did not specifically address the matters we identified for the four students.
After we identified these errors in the determination of the amount of federal financial assistance to return to the federal government, UW-Madison returned in fall 2024 the unearned federal financial assistance for the three students who never attended or withdrew from enrollment after attending one day. In addition, UW Madison returned the additional $584 in February 2025 for the student who withdrew from enrollment and did not meet the criteria for a withdrawal exemption.
Recommendation:
We recommend the University of Wisconsin-Madison review, update, and implement its procedures to improve the accuracy and follow-through for making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including thoroughly reviewing applied exemptions, and returning federal financial assistance in a timely manner to the federal government.
Finding 2024-703: Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,987, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Background:
UW-River Falls receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-River Falls reported a total of $23.6 million in federal financial assistance under the SFA Cluster. UW-River Falls is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-River Falls must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. Under Volume 5, Chapter 1 of the Federal Student Aid Handbook, when a student begins attendance in at least one course but does not begin attendance in all courses the student was scheduled to attend, the school must determine if it is necessary to recalculate the student’s eligibility for the Pell Grant based on a revised enrollment status and the cost of education pursuant to 34 CFR s. 690.80. If the student withdraws, this recalculation must be performed before determining whether to return federal financial assistance pursuant to 34 CFR s. 668.22.
Condition:
We found that UW-River Falls did not return $16,010 in federal financial assistance for four students that did not begin attendance in all enrolled courses during FY 2023-24. This included two students who never began attendance in any enrolled courses for whom all disbursed federal financial assistance was required to be returned. This also included two students who began at least one course but not all courses for which the students had enrolled. UW-River Falls did not perform the required recalculation of Pell Grant eligibility or an assessment of federal financial assistance it had disbursed that these students had not earned.
Context:
UW-River Falls uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-River Falls the process used for identifying students who did not begin attending all enrolled courses or withdrew from enrollment, and we requested a list of such students during FY 2023-24. UW-River Falls did not have a complete list readily available of students who did not begin attending all enrolled courses.
Questioned Costs:
$16,010, Plus an Undetermined Amount
Effect:
UW-River Falls did not comply with all requirements to return federal financial assistance for students who never attended or did not begin attending all enrolled courses during FY 2023-24.
Cause:
UW-River Falls did not have procedures to identify from its student information system, or other sources, those students for whom it disbursed federal financial assistance, yet the students did not attend at least one course during the term or begin all courses enrolled. Depending on whether a student dropped any of their courses, UW-River Falls indicated that the procedures to evaluate attendance may not have identified all students who would ultimately be determined as never attending for the academic term.
After we requested a list of students who did not begin attending all enrolled courses, UW-River Falls identified two students who did not begin at least one course but for whom it had disbursed federal financial assistance. For the other two students who began at least one course, UW-River Falls completed the required Pell Grant recalculation for the students. UW-River Falls also determined the amount of federal financial assistance to return for all four students, as applicable, to the U.S. Department of Education in September 2024.
Recommendation:
We recommend the University of Wisconsin-River Falls review, update, and implement procedures to:
-identify students after the start of each academic term for whom it disbursed federal financial assistance and the students did not begin all enrolled courses;
-complete required recalculations for Pell Grant eligibility and a determination of federal financial assistance that was not earned by the students, as applicable; and
-return amounts to the federal government in a timely manner.
Finding 2024-704: Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,010, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-River Falls: The University of Wisconsin-River Falls agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Background:
UW-Parkside receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Parkside reported a total of $21.3 million in federal financial assistance under the SFA Cluster. UW-Parkside is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22, requires that UW-Parkside must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW Parkside should be returned to the U.S. Department of Education unless certain conditions are met. In determining whether federal financial assistance was earned by a student, the Federal Student Aid Handbook provides guidance on how to calculate applicable institution charges and academic days under different circumstances.
Condition:
For two of three students we reviewed who withdrew from enrollment during FY 2023-24, UW-Parkside inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Parkside incorrectly accounted for a disbursement that occurred after the student’s withdrawal from enrollment as an amount that was earned by the student for the fall 2023 term. As a result, UW Parkside returned $548 less than what should have been returned to the U.S. Department of Education. For the second student, UW-Parkside incorrectly identified the end date of the spring 2024 term and did not include the correct institutional charges in its determination. As a result, UW-Parkside returned $1,190 less than should have been returned to the U.S. Department of Education.
Context:
UW-Parkside uses a student information system to track activity for students that withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Parkside staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from
UW-Parkside to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 3 students who had received federal financial assistance and withdrew from UW-Parkside to determine the amount of federal financial assistance those students earned and the related amounts UW-Parkside returned to the U.S. Department of Education.
Questioned Costs:
$1,738, Plus an Undetermined Amount
Effect:
UW-Parkside did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Parkside did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal assistance to return. Although UW-Parkside disbursed federal financial assistance later than is typical to one student, the disbursement was not correctly categorized within the calculations completed by UW-Parkside to determine that the entire amount of the federal financial assistance was required to be returned to the federal government.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the students we identified.
Finding 2024-705: Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $1,738, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Background:
UW-Platteville receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Platteville reported a total of $29.1 million in federal financial assistance under the SFA Cluster. UW-Platteville is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Under 34 CFR s. 668.21, UW-Platteville must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. In addition, when a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Platteville must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In determining whether federal financial assistance was earned by a student, Volume 5, Chapter 2 of the Federal Student Aid Handbook specifies how to calculate academic days.
Condition:
For two of the five students we reviewed who never began attendance or who withdrew from enrollment during FY 2023-24, UW-Platteville inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Platteville incorrectly determined the student began attendance because the student attended one day of the fall 2023 term. As a result, UW-Platteville failed to return $24 in federal financial assistance to the U.S. Department of Education. For the second student, UW-Platteville did not exclude a five-day break from its determination of the federal financial assistance amount the student had earned during the fall 2023 term. Although this student had earned all of the federal financial assistance prior to the student’s withdrawal from enrollment, UW-Platteville incorrectly returned $1,226. Because UW-Platteville used the same calculation for all determinations for the fall 2023 term, there may be further errors in the federal financial assistance amounts UW-Platteville determined.
Context:
UW-Platteville uses a student information system to track activity for students who withdraw from enrollment in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Platteville staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Platteville to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 5 students who had received federal financial assistance and who withdrew from UW-Platteville to determine the amount of federal financial assistance those students earned and the related amounts UW-Platteville returned to the U.S. Department of Education.
Questioned Costs:
$24, Plus an Undetermined Amount
Effect:
UW-Platteville did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Platteville did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal financial assistance to return to the federal government. After we identified the error for the student who attended only one day, UW-Platteville returned the additional $24 to the federal government in November 2024. For the fall 2023 term, UW-Platteville changed its fall break from four to five days, which required a change in the number of academic days used in the calculation of federal financial assistance earned when a student withdraws from enrollment. UW-Platteville did not have a process to review the academic calendar for purposes of its return procedures.
Recommendation:
We recommend the University of Wisconsin-Platteville review, update, and implement its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including annually reviewing the academic days used in its determinations.
Finding 2024-706: Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $24, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Platteville: The University of Wisconsin-Platteville agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Background:
UW-Whitewater receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Whitewater reported a total of $58.4 million in federal financial assistance under the SFA Cluster. UW-Whitewater is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Whitewater must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook, the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW-Whitewater is required to be returned to the U.S. Department of Education unless certain conditions are met.
Condition:
UW-Whitewater inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education for one of seven students we reviewed who withdrew from enrollment during FY 2023 24. UW-Whitewater incorrectly accounted for a disbursement to the student that occurred after the date for which UW-Whitewater later identified the student had withdrawn from enrollment as an amount that was earned by the student. As a result, UW-Whitewater failed to return $400 in federal financial assistance to the U.S. Department of Education for the spring 2024 term.
Context:
In order to determine the federal financial assistance a student earned and the amount that must be returned to the U.S. Department of Education for amounts a student did not earn, UW-Whitewater uses a student information system to track activity for students who withdraw. We discussed with UW-Whitewater staff the process used for identifying students who withdrew from enrollment. We also requested information from UW-Whitewater to identify students who withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 7 students who had received federal financial assistance and who withdrew from UW-Whitewater to determine the amount of federal financial assistance those students earned and the related amounts UW-Whitewater returned to the U.S. Department of Education.
Questioned Costs:
$400, Plus an Undetermined Amount
Effect:
UW-Whitewater did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Whitewater did not have adequate procedures to review and ensure its determination of the amount of federal assistance to return was accurate. Although UW-Whitewater disbursed federal financial assistance later than is typical to the student, the disbursement was not correctly categorized within the calculations completed by UW-Whitewater nor was the categorization error detected by other
UW-Whitewater procedures.
Recommendation:
We recommend the University of Wisconsin-Whitewater:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the student we identified.
Finding 2024-707: Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $400, Plus an Undetermined Amount
Type of Finding: Noncompliance
Response from the University of Wisconsin-Whitewater: The University of Wisconsin-Whitewater agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Madison is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to the National Student Loan Data System (NSLDS). Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Madison is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time;
-report the same effective date for a student who withdraws from enrollment as the date used in its determination of whether any federal financial assistance must be returned in accordance with
34 CFR s. 668.22;
-report a student who has completed a program with a status of “graduated” rather than “withdrawn”;
-maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed; and
-maintain the program begin date, which is the date the student first began attending the program being reported, if a student’s program of study has not changed.
Condition:
UW-Madison uses the National Student Clearinghouse (NSC) to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Madison that identify potential errors in UW-Madison’s reporting of student activities. It is the responsibility of UW-Madison to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Madison did not report to NSLDS accurate information for 12 of the 17 students we reviewed. First, UW-Madison did not accurately report a student who withdrew from enrollment without notification in a timely manner. Second, UW-Madison incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment. Third, UW-Madison incorrectly reported the program-level enrollment status effective date for two students. Fourth, UW-Madison incorrectly reported the program begin date for six students. In addition, UW Madison incorrectly reported both the program-level enrollment status effective date and program begin date for two students.
Context:
We discussed with UW-Madison staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Madison relies on data from its student information system to compile information to transmit to NSC. UW-Madison also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student that withdrew from UW-Madison and six students who graduated from UW-Madison. In addition, we selected ten additional UW-Madison students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Madison did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Madison did not report to NSLDS who had withdrawn from enrollment without notification, we found UW-Madison’s enrollment reporting procedures did not assign responsibility for communicating certain information to those staff in the registrar’s office who are responsible for NSLDS reporting. As a result, those students the financial aid office determined had withdrawn from enrollment without notification, and for which it had completed a determination of federal financial assistance the students did not earn, were not known to staff in the registrar’s office for purposes of NSLDS reporting. In addition, UW-Madison indicated that withdrawals from enrollment without notification are identified after the term ends and its student information system did not have a dedicated effective date field in order to automatically identify such student records for the required NSLDS reporting.
Second, for the student UW-Madison did not accurately report as graduated within NSLDS, we found UW‑Madison relied on a NSC process that is intended to simultaneously update a student’s enrollment status in NSLDS when UW-Madison separately updates a student’s degree as completed. UW-Madison did not complete a separate report to ensure the enrollment status for graduated students was accurately reflected in NSLDS. However, in 2022 NSC had published information that indicated reliance solely on NSC’s process may result in the incorrect status being reported under certain circumstances. Although NSC error reports identified that such errors were present, UW-Madison indicated that it did not review these errors until fall 2024 when it began implementing new U.S. Department of Education reporting requirements.
At that time, UW-Madison stated that it identified that it did not consistently and accurately report in NSLDS those students who had graduated. UW-Madison stated that it then began to work with NSC to identify the extent of the reporting inaccuracies.
Third, in 2021 NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW-Madison’s data from its student information system and had communicated error or warning codes to UW-Madison in these areas. However, UW-Madison did not sufficiently review whether the records identified by NSC as potential errors resulted in inaccurate reporting. For example, NSC used warning codes for potential errors in the program-level enrollment status effective dates. As warning codes do not prohibit submission of reporting, UW-Madison did not review the warnings.
Fourth, in 2021 NSC similarly published information on accurately reporting student program begin dates in NSLDS and NSC had also identified instances of potential inaccurate reporting in UW Madison’s data from its student information system. Although NSC had communicated error or warning codes to UW-Madison in these areas, UW-Madison had not sufficiently reviewed whether the records identified by NSC as potential errors resulted in inaccurate reporting until 2023. At that time, UW-Madison indicated that, after reviewing other NSC warnings, it identified that it did not accurately report program begin dates for students. UW-Madison indicated it then began to work to update its student information system data extraction process to identify the correct program begin date for its submissions to NSC. However, it did not implement these changes until after the audit period.
In addition, UW-Madison indicated that it had turnover in staff responsible for NSLDS reporting in 2021, which may have caused UW-Madison to have missed the NSC publications regarding reporting graduated students accurately, new warning codes, and the importance of reviewing certain warning codes to accurately complete NSLDS reporting.
Recommendation:
We recommend the University of Wisconsin-Madison:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as updating its student information system to allow for an automated identification process to communicate those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated and implement separate reporting to the National Student Clearinghouse to accurately report students who graduate;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program-level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program begin dates and update its student information system extraction process to accurately report program begin dates; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-708: Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Background:
UW-Milwaukee receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Milwaukee reported a total of $133.1 million in federal financial assistance under the SFA Cluster. UW-Milwaukee records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Milwaukee is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Milwaukee is required to maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed.
Condition:
UW-Milwaukee uses NSC to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Milwaukee that identify potential errors in UW-Milwaukee’s reporting of student activities through NSC. These errors are the responsibility of UW-Milwaukee to resolve to ensure its submissions to NSLDS are accurate and complete.
UW-Milwaukee did not report to NSLDS accurate information for the program level enrollment status effective date for five students we reviewed. In addition, based on how information from its student information system is extracted for student reporting to NSLDS, we found that the reporting inaccuracy extended to other UW-Milwaukee students.
Context:
We discussed with UW-Milwaukee staff its procedures for identifying student enrollment status changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Milwaukee relies on data from its student information system to compile information to transmit to NSC. UW-Milwaukee also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included two students who withdrew from UW-Milwaukee and four students who graduated from UW- Milwaukee. In addition, we selected ten additional UW-Milwaukee students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Milwaukee did not comply with requirements to accurately report certain student enrollment status changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
In 2021, NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW- Milwaukee’s data from its student information system and had communicated error or warning codes to UW-Milwaukee in these areas. UW-Milwaukee staff indicated that they were aware that NSC error reports included warnings to identify potential inaccurate reporting of program level enrollment status effective dates and that the errors were a known issue for Peoplesoft-based student information systems. However, UW-Milwaukee chose not to use an all-record update feature that was available to correct the program-level enrollment status effective dates for all student records simultaneously due to the risk that other reporting inaccuracies could result from the action. Further, UW-Milwaukee staff indicated that they were not aware that specific guidance on the program-level enrollment status effective date had been updated to reflect that corrections should be made to fully comply with NSLDS reporting requirements.
Recommendation:
We recommend the University of Wisconsin-Milwaukee:
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates; and
-report changes in student enrollment accurately, completely, and in a timely manner for all student changes that require reporting.
Finding 2024-709: Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Milwaukee: The University of Wisconsin-Milwaukee agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Background:
UW-Oshkosh receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Oshkosh reported a total of $45.3 million in federal financial assistance under the SFA Cluster. UW-Oshkosh records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Oshkosh is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Oshkosh is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time; and
-report a student who has completed a program with a status of “graduated” rather than “withdrawn.”
Condition:
UW-Oshkosh uses NSC to facilitate the enrollment reporting in NSLDS. NSC provides error reports to UW-Oshkosh that identify potential errors in UW Oshkosh’s reporting of student activities. It is the responsibility of UW-Oshkosh to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Oshkosh did not report to NSLDS accurate information for two of the three students we reviewed.
First, UW-Oshkosh did not report in a timely manner one student who withdrew from enrollment without notification. Second, UW-Oshkosh incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment.
Context:
We discussed with UW-Oshkosh staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and UW Oshkosh’s procedures for monitoring the reporting performed by NSC. UW-Oshkosh relies on data from its student information system to compile information to transmit to NSC. UW-Oshkosh also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve. To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023 24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student who withdrew from UW-Oshkosh and two students who graduated from UW‑Oshkosh.
Questioned Costs:
None.
Effect:
UW-Oshkosh did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Oshkosh did not report to NSLDS in a timely manner who had withdrawn from enrollment without notification, we found that UW-Oshkosh indicated that it believed it needed to report to NSLDS only when students withdrew from enrollment and had notified UW-Oshkosh of the withdrawal. As a result, students detected by UW Oshkosh through procedures completed by the financial aid office at the end of each term were not communicated to those staff in the registrar’s office who were responsible for NSLDS reporting.
Second, for the student UW-Oshkosh did not accurately report as graduated within NSLDS, we found that inaccuracies in the reporting of students who had graduated were noted on NSC error reports. However, UW-Oshkosh’s registrar’s office staff did sufficiently review the errors to correct the status in NSLDS.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as communicating those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-710: Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Background:
UW Parkside operates in a highly computerized environment and is responsible for maintaining confidential and sensitive information, such as student data. UW Parkside maintains its own student information system to administer federal student financial assistance programs under the SFA Cluster.
Criteria:
To ensure data processed and stored by UW-Parkside is protected from accidental or intentional misuse or destruction, and to provide proper internal control, information technology (IT) security policies and procedures are necessary. In addition, IT controls should be established to prevent inappropriate or inadvertent access to data. UW-Parkside is responsible for following specific requirements under the Gramm-Leach-Bliley Act (GLBA), which requires entities that administer student financial assistance programs to develop, implement, and maintain safeguards to protect the security, integrity, and confidentiality of student data.
Under GLBA, UW-Parkside is required to authenticate and permit access only to authorized users. Further, UW Board of Regents Policy 25-5 requires that UW-Parkside follow the National Institute of Standards and Technology (NIST) in establishing IT controls. NIST Special Publication (SP) 800-53, Security and Privacy Controls for Information Systems and Organizations, recommends best practices in IT controls related to user access. These best practices include developing a provisioning and deprovisioning process focused on limiting access in a manner that provides the least access based on business need; retaining documentation of provisioning and deprovisioning activities, including records of when such access was added or removed; and performing periodic reviews of access to ensure it remains appropriate.
Condition:
We found UW-Parkside did not have adequate IT controls in place during FY 2023-24 to provision, deprovision, and manage access to its student information system. First, UW-Parkside did not have a formal documented process to provision or deprovision user access to its student information system. Second, UW-Parkside did not maintain a list of provisioned users with access and was unable to generate a report of users provisioned or deprovisioned during FY 2023-24. Third, UW-Parkside did not complete a periodic review of access, which assists in ensuring its provisioning and deprovisioning processes are working as intended. Although failure in any one IT control may be detected by complementary IT controls, UW‑Parkside did not have effective IT controls in any of the three areas. As a result, UW-Parkside was at a higher risk of granting unauthorized access to its student information system.
Context:
We reviewed GLBA requirements, UW System Board of Regents policies, and NIST 800-53 guidance to identify policies and procedures for UW-Parkside’s monitoring of access granted to its student information system. We requested documentation from UW-Parkside to assess compliance with these policies.
Questioned Costs:
None.
Effect:
Ineffective general IT controls may permit controls over systems to operate improperly and may allow noncompliance to occur and not be detected. Weaknesses in IT security policies, procedures, and controls increase the risk that unauthorized or erroneous transactions could be processed or changes made to student data. In addition, failure to provide an appropriate level of protection for its student information system and data increased the risk that personally identifiable information could be accidentally or maliciously exposed.
Cause:
UW-Parkside did not have a formal policy or procedures in place to provision, deprovision, and review access to its student information system. UW-Parkside staff indicated the process for provisioning and deprovisioning access had been informally operated, such as through electronic mail and direct communication and it did not consistently retain documentation of these communications. For example,
UW-Parkside indicated access requests were accepted from a variety of UW-Parkside employees. As a result, UW-Parkside had not assessed whether a user’s access was necessary or otherwise limited the access only to specific information needed or to a specified time period. Finally, UW-Parkside also indicated that prior efforts to improve its provisioning and deprovisioning of user access were not fully completed or implemented, in part, due to staff turnover.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-develop and implement written procedures for provisioning and deprovisioning user access to its student information system, including specifying those who are authorized to request user access and assigning responsibility to staff to assess access requests to restrict the access only to data needed for a specified period of time;
-retain consistent documentation of its provisioning and deprovisioning activities;
-develop and implement written procedures for a review at least annually of access granted to its student information system; and
-complete an assessment of users who currently have access to its student information system and remove those users who no longer require the access.
Finding 2024-711: Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-Madison must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. For students that begin attending classes, but who later withdraw from enrollment, 34 CFR s. 668.22 requires that UW-Madison must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In order not to consider a student to have withdrawn from enrollment under certain circumstances, which permits a student to retain federal financial assistance that otherwise would need to be returned to the federal government, 34 CFR s. 668.22 (a) (2) (ii) provides certain exemptions to students.
Condition:
For four students, we found that UW-Madison did not accurately determine the amount of federal financial assistance it disbursed that should have been returned to the U.S. Department of Education. First, we found that UW-Madison did not return all federal financial assistance it disbursed to two students that did not begin attendance and to one student who only attended one day during FY 2023-24. For these three students, UW-Madison determined it failed to return $16,403 in federal financial assistance it disbursed during FY 2023-24. Second, we found that UW-Madison did not accurately determine the federal financial assistance that should be returned after a student withdrew from enrollment during the summer 2023 term. For this student, UW-Madison incorrectly applied an exemption, which led to UW-Madison failing to return $584 in federal financial assistance to the U.S. Department of Education.
Context:
UW-Madison uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Madison staff its process for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Madison to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. When reviewing the data UW-Madison provided, we noted potential errors in the amount of aid returned for students identified as never attending.
Separately, as part of a UW systemwide sample of 60 students, we selected 6 students who had received federal financial assistance and who withdrew from enrollment from UW-Madison to determine the amount of federal financial assistance those students earned and the related amounts UW-Madison returned to the U.S. Department of Education.
Questioned Costs:
$16,987, Plus an Undetermined Amount
Effect:
UW-Madison did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Madison identified that the errors in determining the amount of the federal financial assistance that should have been returned to the federal government for the four students we identified were manual errors in the withdrawal procedures and calculations completed during and at the end of each term. These errors were not detected by any other review procedures. Although UW-Madison correctly identified the status of the two students who never attended and the need to return all disbursed federal financial assistance, it did not follow through on the actual repayment.
For the student who had an exemption applied, the exemption was incorrectly selected when UW-Madison completed a determination, and the error was not detected in UW-Madison’s review process. UW-Madison indicated that its automated review processes conducted at the end of each term did not specifically address the matters we identified for the four students.
After we identified these errors in the determination of the amount of federal financial assistance to return to the federal government, UW-Madison returned in fall 2024 the unearned federal financial assistance for the three students who never attended or withdrew from enrollment after attending one day. In addition, UW Madison returned the additional $584 in February 2025 for the student who withdrew from enrollment and did not meet the criteria for a withdrawal exemption.
Recommendation:
We recommend the University of Wisconsin-Madison review, update, and implement its procedures to improve the accuracy and follow-through for making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including thoroughly reviewing applied exemptions, and returning federal financial assistance in a timely manner to the federal government.
Finding 2024-703: Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,987, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Background:
UW-River Falls receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-River Falls reported a total of $23.6 million in federal financial assistance under the SFA Cluster. UW-River Falls is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-River Falls must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. Under Volume 5, Chapter 1 of the Federal Student Aid Handbook, when a student begins attendance in at least one course but does not begin attendance in all courses the student was scheduled to attend, the school must determine if it is necessary to recalculate the student’s eligibility for the Pell Grant based on a revised enrollment status and the cost of education pursuant to 34 CFR s. 690.80. If the student withdraws, this recalculation must be performed before determining whether to return federal financial assistance pursuant to 34 CFR s. 668.22.
Condition:
We found that UW-River Falls did not return $16,010 in federal financial assistance for four students that did not begin attendance in all enrolled courses during FY 2023-24. This included two students who never began attendance in any enrolled courses for whom all disbursed federal financial assistance was required to be returned. This also included two students who began at least one course but not all courses for which the students had enrolled. UW-River Falls did not perform the required recalculation of Pell Grant eligibility or an assessment of federal financial assistance it had disbursed that these students had not earned.
Context:
UW-River Falls uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-River Falls the process used for identifying students who did not begin attending all enrolled courses or withdrew from enrollment, and we requested a list of such students during FY 2023-24. UW-River Falls did not have a complete list readily available of students who did not begin attending all enrolled courses.
Questioned Costs:
$16,010, Plus an Undetermined Amount
Effect:
UW-River Falls did not comply with all requirements to return federal financial assistance for students who never attended or did not begin attending all enrolled courses during FY 2023-24.
Cause:
UW-River Falls did not have procedures to identify from its student information system, or other sources, those students for whom it disbursed federal financial assistance, yet the students did not attend at least one course during the term or begin all courses enrolled. Depending on whether a student dropped any of their courses, UW-River Falls indicated that the procedures to evaluate attendance may not have identified all students who would ultimately be determined as never attending for the academic term.
After we requested a list of students who did not begin attending all enrolled courses, UW-River Falls identified two students who did not begin at least one course but for whom it had disbursed federal financial assistance. For the other two students who began at least one course, UW-River Falls completed the required Pell Grant recalculation for the students. UW-River Falls also determined the amount of federal financial assistance to return for all four students, as applicable, to the U.S. Department of Education in September 2024.
Recommendation:
We recommend the University of Wisconsin-River Falls review, update, and implement procedures to:
-identify students after the start of each academic term for whom it disbursed federal financial assistance and the students did not begin all enrolled courses;
-complete required recalculations for Pell Grant eligibility and a determination of federal financial assistance that was not earned by the students, as applicable; and
-return amounts to the federal government in a timely manner.
Finding 2024-704: Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,010, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-River Falls: The University of Wisconsin-River Falls agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Background:
UW-Parkside receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Parkside reported a total of $21.3 million in federal financial assistance under the SFA Cluster. UW-Parkside is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22, requires that UW-Parkside must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW Parkside should be returned to the U.S. Department of Education unless certain conditions are met. In determining whether federal financial assistance was earned by a student, the Federal Student Aid Handbook provides guidance on how to calculate applicable institution charges and academic days under different circumstances.
Condition:
For two of three students we reviewed who withdrew from enrollment during FY 2023-24, UW-Parkside inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Parkside incorrectly accounted for a disbursement that occurred after the student’s withdrawal from enrollment as an amount that was earned by the student for the fall 2023 term. As a result, UW Parkside returned $548 less than what should have been returned to the U.S. Department of Education. For the second student, UW-Parkside incorrectly identified the end date of the spring 2024 term and did not include the correct institutional charges in its determination. As a result, UW-Parkside returned $1,190 less than should have been returned to the U.S. Department of Education.
Context:
UW-Parkside uses a student information system to track activity for students that withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Parkside staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from
UW-Parkside to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 3 students who had received federal financial assistance and withdrew from UW-Parkside to determine the amount of federal financial assistance those students earned and the related amounts UW-Parkside returned to the U.S. Department of Education.
Questioned Costs:
$1,738, Plus an Undetermined Amount
Effect:
UW-Parkside did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Parkside did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal assistance to return. Although UW-Parkside disbursed federal financial assistance later than is typical to one student, the disbursement was not correctly categorized within the calculations completed by UW-Parkside to determine that the entire amount of the federal financial assistance was required to be returned to the federal government.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the students we identified.
Finding 2024-705: Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $1,738, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Background:
UW-Platteville receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Platteville reported a total of $29.1 million in federal financial assistance under the SFA Cluster. UW-Platteville is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Under 34 CFR s. 668.21, UW-Platteville must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. In addition, when a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Platteville must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In determining whether federal financial assistance was earned by a student, Volume 5, Chapter 2 of the Federal Student Aid Handbook specifies how to calculate academic days.
Condition:
For two of the five students we reviewed who never began attendance or who withdrew from enrollment during FY 2023-24, UW-Platteville inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Platteville incorrectly determined the student began attendance because the student attended one day of the fall 2023 term. As a result, UW-Platteville failed to return $24 in federal financial assistance to the U.S. Department of Education. For the second student, UW-Platteville did not exclude a five-day break from its determination of the federal financial assistance amount the student had earned during the fall 2023 term. Although this student had earned all of the federal financial assistance prior to the student’s withdrawal from enrollment, UW-Platteville incorrectly returned $1,226. Because UW-Platteville used the same calculation for all determinations for the fall 2023 term, there may be further errors in the federal financial assistance amounts UW-Platteville determined.
Context:
UW-Platteville uses a student information system to track activity for students who withdraw from enrollment in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Platteville staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Platteville to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 5 students who had received federal financial assistance and who withdrew from UW-Platteville to determine the amount of federal financial assistance those students earned and the related amounts UW-Platteville returned to the U.S. Department of Education.
Questioned Costs:
$24, Plus an Undetermined Amount
Effect:
UW-Platteville did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Platteville did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal financial assistance to return to the federal government. After we identified the error for the student who attended only one day, UW-Platteville returned the additional $24 to the federal government in November 2024. For the fall 2023 term, UW-Platteville changed its fall break from four to five days, which required a change in the number of academic days used in the calculation of federal financial assistance earned when a student withdraws from enrollment. UW-Platteville did not have a process to review the academic calendar for purposes of its return procedures.
Recommendation:
We recommend the University of Wisconsin-Platteville review, update, and implement its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including annually reviewing the academic days used in its determinations.
Finding 2024-706: Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $24, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Platteville: The University of Wisconsin-Platteville agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Background:
UW-Whitewater receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Whitewater reported a total of $58.4 million in federal financial assistance under the SFA Cluster. UW-Whitewater is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Whitewater must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook, the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW-Whitewater is required to be returned to the U.S. Department of Education unless certain conditions are met.
Condition:
UW-Whitewater inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education for one of seven students we reviewed who withdrew from enrollment during FY 2023 24. UW-Whitewater incorrectly accounted for a disbursement to the student that occurred after the date for which UW-Whitewater later identified the student had withdrawn from enrollment as an amount that was earned by the student. As a result, UW-Whitewater failed to return $400 in federal financial assistance to the U.S. Department of Education for the spring 2024 term.
Context:
In order to determine the federal financial assistance a student earned and the amount that must be returned to the U.S. Department of Education for amounts a student did not earn, UW-Whitewater uses a student information system to track activity for students who withdraw. We discussed with UW-Whitewater staff the process used for identifying students who withdrew from enrollment. We also requested information from UW-Whitewater to identify students who withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 7 students who had received federal financial assistance and who withdrew from UW-Whitewater to determine the amount of federal financial assistance those students earned and the related amounts UW-Whitewater returned to the U.S. Department of Education.
Questioned Costs:
$400, Plus an Undetermined Amount
Effect:
UW-Whitewater did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Whitewater did not have adequate procedures to review and ensure its determination of the amount of federal assistance to return was accurate. Although UW-Whitewater disbursed federal financial assistance later than is typical to the student, the disbursement was not correctly categorized within the calculations completed by UW-Whitewater nor was the categorization error detected by other
UW-Whitewater procedures.
Recommendation:
We recommend the University of Wisconsin-Whitewater:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the student we identified.
Finding 2024-707: Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $400, Plus an Undetermined Amount
Type of Finding: Noncompliance
Response from the University of Wisconsin-Whitewater: The University of Wisconsin-Whitewater agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Madison is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to the National Student Loan Data System (NSLDS). Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Madison is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time;
-report the same effective date for a student who withdraws from enrollment as the date used in its determination of whether any federal financial assistance must be returned in accordance with
34 CFR s. 668.22;
-report a student who has completed a program with a status of “graduated” rather than “withdrawn”;
-maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed; and
-maintain the program begin date, which is the date the student first began attending the program being reported, if a student’s program of study has not changed.
Condition:
UW-Madison uses the National Student Clearinghouse (NSC) to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Madison that identify potential errors in UW-Madison’s reporting of student activities. It is the responsibility of UW-Madison to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Madison did not report to NSLDS accurate information for 12 of the 17 students we reviewed. First, UW-Madison did not accurately report a student who withdrew from enrollment without notification in a timely manner. Second, UW-Madison incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment. Third, UW-Madison incorrectly reported the program-level enrollment status effective date for two students. Fourth, UW-Madison incorrectly reported the program begin date for six students. In addition, UW Madison incorrectly reported both the program-level enrollment status effective date and program begin date for two students.
Context:
We discussed with UW-Madison staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Madison relies on data from its student information system to compile information to transmit to NSC. UW-Madison also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student that withdrew from UW-Madison and six students who graduated from UW-Madison. In addition, we selected ten additional UW-Madison students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Madison did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Madison did not report to NSLDS who had withdrawn from enrollment without notification, we found UW-Madison’s enrollment reporting procedures did not assign responsibility for communicating certain information to those staff in the registrar’s office who are responsible for NSLDS reporting. As a result, those students the financial aid office determined had withdrawn from enrollment without notification, and for which it had completed a determination of federal financial assistance the students did not earn, were not known to staff in the registrar’s office for purposes of NSLDS reporting. In addition, UW-Madison indicated that withdrawals from enrollment without notification are identified after the term ends and its student information system did not have a dedicated effective date field in order to automatically identify such student records for the required NSLDS reporting.
Second, for the student UW-Madison did not accurately report as graduated within NSLDS, we found UW‑Madison relied on a NSC process that is intended to simultaneously update a student’s enrollment status in NSLDS when UW-Madison separately updates a student’s degree as completed. UW-Madison did not complete a separate report to ensure the enrollment status for graduated students was accurately reflected in NSLDS. However, in 2022 NSC had published information that indicated reliance solely on NSC’s process may result in the incorrect status being reported under certain circumstances. Although NSC error reports identified that such errors were present, UW-Madison indicated that it did not review these errors until fall 2024 when it began implementing new U.S. Department of Education reporting requirements.
At that time, UW-Madison stated that it identified that it did not consistently and accurately report in NSLDS those students who had graduated. UW-Madison stated that it then began to work with NSC to identify the extent of the reporting inaccuracies.
Third, in 2021 NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW-Madison’s data from its student information system and had communicated error or warning codes to UW-Madison in these areas. However, UW-Madison did not sufficiently review whether the records identified by NSC as potential errors resulted in inaccurate reporting. For example, NSC used warning codes for potential errors in the program-level enrollment status effective dates. As warning codes do not prohibit submission of reporting, UW-Madison did not review the warnings.
Fourth, in 2021 NSC similarly published information on accurately reporting student program begin dates in NSLDS and NSC had also identified instances of potential inaccurate reporting in UW Madison’s data from its student information system. Although NSC had communicated error or warning codes to UW-Madison in these areas, UW-Madison had not sufficiently reviewed whether the records identified by NSC as potential errors resulted in inaccurate reporting until 2023. At that time, UW-Madison indicated that, after reviewing other NSC warnings, it identified that it did not accurately report program begin dates for students. UW-Madison indicated it then began to work to update its student information system data extraction process to identify the correct program begin date for its submissions to NSC. However, it did not implement these changes until after the audit period.
In addition, UW-Madison indicated that it had turnover in staff responsible for NSLDS reporting in 2021, which may have caused UW-Madison to have missed the NSC publications regarding reporting graduated students accurately, new warning codes, and the importance of reviewing certain warning codes to accurately complete NSLDS reporting.
Recommendation:
We recommend the University of Wisconsin-Madison:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as updating its student information system to allow for an automated identification process to communicate those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated and implement separate reporting to the National Student Clearinghouse to accurately report students who graduate;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program-level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program begin dates and update its student information system extraction process to accurately report program begin dates; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-708: Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Background:
UW-Milwaukee receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Milwaukee reported a total of $133.1 million in federal financial assistance under the SFA Cluster. UW-Milwaukee records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Milwaukee is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Milwaukee is required to maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed.
Condition:
UW-Milwaukee uses NSC to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Milwaukee that identify potential errors in UW-Milwaukee’s reporting of student activities through NSC. These errors are the responsibility of UW-Milwaukee to resolve to ensure its submissions to NSLDS are accurate and complete.
UW-Milwaukee did not report to NSLDS accurate information for the program level enrollment status effective date for five students we reviewed. In addition, based on how information from its student information system is extracted for student reporting to NSLDS, we found that the reporting inaccuracy extended to other UW-Milwaukee students.
Context:
We discussed with UW-Milwaukee staff its procedures for identifying student enrollment status changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Milwaukee relies on data from its student information system to compile information to transmit to NSC. UW-Milwaukee also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included two students who withdrew from UW-Milwaukee and four students who graduated from UW- Milwaukee. In addition, we selected ten additional UW-Milwaukee students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Milwaukee did not comply with requirements to accurately report certain student enrollment status changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
In 2021, NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW- Milwaukee’s data from its student information system and had communicated error or warning codes to UW-Milwaukee in these areas. UW-Milwaukee staff indicated that they were aware that NSC error reports included warnings to identify potential inaccurate reporting of program level enrollment status effective dates and that the errors were a known issue for Peoplesoft-based student information systems. However, UW-Milwaukee chose not to use an all-record update feature that was available to correct the program-level enrollment status effective dates for all student records simultaneously due to the risk that other reporting inaccuracies could result from the action. Further, UW-Milwaukee staff indicated that they were not aware that specific guidance on the program-level enrollment status effective date had been updated to reflect that corrections should be made to fully comply with NSLDS reporting requirements.
Recommendation:
We recommend the University of Wisconsin-Milwaukee:
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates; and
-report changes in student enrollment accurately, completely, and in a timely manner for all student changes that require reporting.
Finding 2024-709: Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Milwaukee: The University of Wisconsin-Milwaukee agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Background:
UW-Oshkosh receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Oshkosh reported a total of $45.3 million in federal financial assistance under the SFA Cluster. UW-Oshkosh records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Oshkosh is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Oshkosh is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time; and
-report a student who has completed a program with a status of “graduated” rather than “withdrawn.”
Condition:
UW-Oshkosh uses NSC to facilitate the enrollment reporting in NSLDS. NSC provides error reports to UW-Oshkosh that identify potential errors in UW Oshkosh’s reporting of student activities. It is the responsibility of UW-Oshkosh to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Oshkosh did not report to NSLDS accurate information for two of the three students we reviewed.
First, UW-Oshkosh did not report in a timely manner one student who withdrew from enrollment without notification. Second, UW-Oshkosh incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment.
Context:
We discussed with UW-Oshkosh staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and UW Oshkosh’s procedures for monitoring the reporting performed by NSC. UW-Oshkosh relies on data from its student information system to compile information to transmit to NSC. UW-Oshkosh also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve. To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023 24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student who withdrew from UW-Oshkosh and two students who graduated from UW‑Oshkosh.
Questioned Costs:
None.
Effect:
UW-Oshkosh did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Oshkosh did not report to NSLDS in a timely manner who had withdrawn from enrollment without notification, we found that UW-Oshkosh indicated that it believed it needed to report to NSLDS only when students withdrew from enrollment and had notified UW-Oshkosh of the withdrawal. As a result, students detected by UW Oshkosh through procedures completed by the financial aid office at the end of each term were not communicated to those staff in the registrar’s office who were responsible for NSLDS reporting.
Second, for the student UW-Oshkosh did not accurately report as graduated within NSLDS, we found that inaccuracies in the reporting of students who had graduated were noted on NSC error reports. However, UW-Oshkosh’s registrar’s office staff did sufficiently review the errors to correct the status in NSLDS.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as communicating those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-710: Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Background:
UW Parkside operates in a highly computerized environment and is responsible for maintaining confidential and sensitive information, such as student data. UW Parkside maintains its own student information system to administer federal student financial assistance programs under the SFA Cluster.
Criteria:
To ensure data processed and stored by UW-Parkside is protected from accidental or intentional misuse or destruction, and to provide proper internal control, information technology (IT) security policies and procedures are necessary. In addition, IT controls should be established to prevent inappropriate or inadvertent access to data. UW-Parkside is responsible for following specific requirements under the Gramm-Leach-Bliley Act (GLBA), which requires entities that administer student financial assistance programs to develop, implement, and maintain safeguards to protect the security, integrity, and confidentiality of student data.
Under GLBA, UW-Parkside is required to authenticate and permit access only to authorized users. Further, UW Board of Regents Policy 25-5 requires that UW-Parkside follow the National Institute of Standards and Technology (NIST) in establishing IT controls. NIST Special Publication (SP) 800-53, Security and Privacy Controls for Information Systems and Organizations, recommends best practices in IT controls related to user access. These best practices include developing a provisioning and deprovisioning process focused on limiting access in a manner that provides the least access based on business need; retaining documentation of provisioning and deprovisioning activities, including records of when such access was added or removed; and performing periodic reviews of access to ensure it remains appropriate.
Condition:
We found UW-Parkside did not have adequate IT controls in place during FY 2023-24 to provision, deprovision, and manage access to its student information system. First, UW-Parkside did not have a formal documented process to provision or deprovision user access to its student information system. Second, UW-Parkside did not maintain a list of provisioned users with access and was unable to generate a report of users provisioned or deprovisioned during FY 2023-24. Third, UW-Parkside did not complete a periodic review of access, which assists in ensuring its provisioning and deprovisioning processes are working as intended. Although failure in any one IT control may be detected by complementary IT controls, UW‑Parkside did not have effective IT controls in any of the three areas. As a result, UW-Parkside was at a higher risk of granting unauthorized access to its student information system.
Context:
We reviewed GLBA requirements, UW System Board of Regents policies, and NIST 800-53 guidance to identify policies and procedures for UW-Parkside’s monitoring of access granted to its student information system. We requested documentation from UW-Parkside to assess compliance with these policies.
Questioned Costs:
None.
Effect:
Ineffective general IT controls may permit controls over systems to operate improperly and may allow noncompliance to occur and not be detected. Weaknesses in IT security policies, procedures, and controls increase the risk that unauthorized or erroneous transactions could be processed or changes made to student data. In addition, failure to provide an appropriate level of protection for its student information system and data increased the risk that personally identifiable information could be accidentally or maliciously exposed.
Cause:
UW-Parkside did not have a formal policy or procedures in place to provision, deprovision, and review access to its student information system. UW-Parkside staff indicated the process for provisioning and deprovisioning access had been informally operated, such as through electronic mail and direct communication and it did not consistently retain documentation of these communications. For example,
UW-Parkside indicated access requests were accepted from a variety of UW-Parkside employees. As a result, UW-Parkside had not assessed whether a user’s access was necessary or otherwise limited the access only to specific information needed or to a specified time period. Finally, UW-Parkside also indicated that prior efforts to improve its provisioning and deprovisioning of user access were not fully completed or implemented, in part, due to staff turnover.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-develop and implement written procedures for provisioning and deprovisioning user access to its student information system, including specifying those who are authorized to request user access and assigning responsibility to staff to assess access requests to restrict the access only to data needed for a specified period of time;
-retain consistent documentation of its provisioning and deprovisioning activities;
-develop and implement written procedures for a review at least annually of access granted to its student information system; and
-complete an assessment of users who currently have access to its student information system and remove those users who no longer require the access.
Finding 2024-711: Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-Madison must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. For students that begin attending classes, but who later withdraw from enrollment, 34 CFR s. 668.22 requires that UW-Madison must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In order not to consider a student to have withdrawn from enrollment under certain circumstances, which permits a student to retain federal financial assistance that otherwise would need to be returned to the federal government, 34 CFR s. 668.22 (a) (2) (ii) provides certain exemptions to students.
Condition:
For four students, we found that UW-Madison did not accurately determine the amount of federal financial assistance it disbursed that should have been returned to the U.S. Department of Education. First, we found that UW-Madison did not return all federal financial assistance it disbursed to two students that did not begin attendance and to one student who only attended one day during FY 2023-24. For these three students, UW-Madison determined it failed to return $16,403 in federal financial assistance it disbursed during FY 2023-24. Second, we found that UW-Madison did not accurately determine the federal financial assistance that should be returned after a student withdrew from enrollment during the summer 2023 term. For this student, UW-Madison incorrectly applied an exemption, which led to UW-Madison failing to return $584 in federal financial assistance to the U.S. Department of Education.
Context:
UW-Madison uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Madison staff its process for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Madison to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. When reviewing the data UW-Madison provided, we noted potential errors in the amount of aid returned for students identified as never attending.
Separately, as part of a UW systemwide sample of 60 students, we selected 6 students who had received federal financial assistance and who withdrew from enrollment from UW-Madison to determine the amount of federal financial assistance those students earned and the related amounts UW-Madison returned to the U.S. Department of Education.
Questioned Costs:
$16,987, Plus an Undetermined Amount
Effect:
UW-Madison did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Madison identified that the errors in determining the amount of the federal financial assistance that should have been returned to the federal government for the four students we identified were manual errors in the withdrawal procedures and calculations completed during and at the end of each term. These errors were not detected by any other review procedures. Although UW-Madison correctly identified the status of the two students who never attended and the need to return all disbursed federal financial assistance, it did not follow through on the actual repayment.
For the student who had an exemption applied, the exemption was incorrectly selected when UW-Madison completed a determination, and the error was not detected in UW-Madison’s review process. UW-Madison indicated that its automated review processes conducted at the end of each term did not specifically address the matters we identified for the four students.
After we identified these errors in the determination of the amount of federal financial assistance to return to the federal government, UW-Madison returned in fall 2024 the unearned federal financial assistance for the three students who never attended or withdrew from enrollment after attending one day. In addition, UW Madison returned the additional $584 in February 2025 for the student who withdrew from enrollment and did not meet the criteria for a withdrawal exemption.
Recommendation:
We recommend the University of Wisconsin-Madison review, update, and implement its procedures to improve the accuracy and follow-through for making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including thoroughly reviewing applied exemptions, and returning federal financial assistance in a timely manner to the federal government.
Finding 2024-703: Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,987, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Background:
UW-River Falls receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-River Falls reported a total of $23.6 million in federal financial assistance under the SFA Cluster. UW-River Falls is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-River Falls must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. Under Volume 5, Chapter 1 of the Federal Student Aid Handbook, when a student begins attendance in at least one course but does not begin attendance in all courses the student was scheduled to attend, the school must determine if it is necessary to recalculate the student’s eligibility for the Pell Grant based on a revised enrollment status and the cost of education pursuant to 34 CFR s. 690.80. If the student withdraws, this recalculation must be performed before determining whether to return federal financial assistance pursuant to 34 CFR s. 668.22.
Condition:
We found that UW-River Falls did not return $16,010 in federal financial assistance for four students that did not begin attendance in all enrolled courses during FY 2023-24. This included two students who never began attendance in any enrolled courses for whom all disbursed federal financial assistance was required to be returned. This also included two students who began at least one course but not all courses for which the students had enrolled. UW-River Falls did not perform the required recalculation of Pell Grant eligibility or an assessment of federal financial assistance it had disbursed that these students had not earned.
Context:
UW-River Falls uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-River Falls the process used for identifying students who did not begin attending all enrolled courses or withdrew from enrollment, and we requested a list of such students during FY 2023-24. UW-River Falls did not have a complete list readily available of students who did not begin attending all enrolled courses.
Questioned Costs:
$16,010, Plus an Undetermined Amount
Effect:
UW-River Falls did not comply with all requirements to return federal financial assistance for students who never attended or did not begin attending all enrolled courses during FY 2023-24.
Cause:
UW-River Falls did not have procedures to identify from its student information system, or other sources, those students for whom it disbursed federal financial assistance, yet the students did not attend at least one course during the term or begin all courses enrolled. Depending on whether a student dropped any of their courses, UW-River Falls indicated that the procedures to evaluate attendance may not have identified all students who would ultimately be determined as never attending for the academic term.
After we requested a list of students who did not begin attending all enrolled courses, UW-River Falls identified two students who did not begin at least one course but for whom it had disbursed federal financial assistance. For the other two students who began at least one course, UW-River Falls completed the required Pell Grant recalculation for the students. UW-River Falls also determined the amount of federal financial assistance to return for all four students, as applicable, to the U.S. Department of Education in September 2024.
Recommendation:
We recommend the University of Wisconsin-River Falls review, update, and implement procedures to:
-identify students after the start of each academic term for whom it disbursed federal financial assistance and the students did not begin all enrolled courses;
-complete required recalculations for Pell Grant eligibility and a determination of federal financial assistance that was not earned by the students, as applicable; and
-return amounts to the federal government in a timely manner.
Finding 2024-704: Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,010, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-River Falls: The University of Wisconsin-River Falls agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Background:
UW-Parkside receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Parkside reported a total of $21.3 million in federal financial assistance under the SFA Cluster. UW-Parkside is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22, requires that UW-Parkside must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW Parkside should be returned to the U.S. Department of Education unless certain conditions are met. In determining whether federal financial assistance was earned by a student, the Federal Student Aid Handbook provides guidance on how to calculate applicable institution charges and academic days under different circumstances.
Condition:
For two of three students we reviewed who withdrew from enrollment during FY 2023-24, UW-Parkside inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Parkside incorrectly accounted for a disbursement that occurred after the student’s withdrawal from enrollment as an amount that was earned by the student for the fall 2023 term. As a result, UW Parkside returned $548 less than what should have been returned to the U.S. Department of Education. For the second student, UW-Parkside incorrectly identified the end date of the spring 2024 term and did not include the correct institutional charges in its determination. As a result, UW-Parkside returned $1,190 less than should have been returned to the U.S. Department of Education.
Context:
UW-Parkside uses a student information system to track activity for students that withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Parkside staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from
UW-Parkside to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 3 students who had received federal financial assistance and withdrew from UW-Parkside to determine the amount of federal financial assistance those students earned and the related amounts UW-Parkside returned to the U.S. Department of Education.
Questioned Costs:
$1,738, Plus an Undetermined Amount
Effect:
UW-Parkside did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Parkside did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal assistance to return. Although UW-Parkside disbursed federal financial assistance later than is typical to one student, the disbursement was not correctly categorized within the calculations completed by UW-Parkside to determine that the entire amount of the federal financial assistance was required to be returned to the federal government.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the students we identified.
Finding 2024-705: Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $1,738, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Background:
UW-Platteville receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Platteville reported a total of $29.1 million in federal financial assistance under the SFA Cluster. UW-Platteville is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Under 34 CFR s. 668.21, UW-Platteville must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. In addition, when a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Platteville must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In determining whether federal financial assistance was earned by a student, Volume 5, Chapter 2 of the Federal Student Aid Handbook specifies how to calculate academic days.
Condition:
For two of the five students we reviewed who never began attendance or who withdrew from enrollment during FY 2023-24, UW-Platteville inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Platteville incorrectly determined the student began attendance because the student attended one day of the fall 2023 term. As a result, UW-Platteville failed to return $24 in federal financial assistance to the U.S. Department of Education. For the second student, UW-Platteville did not exclude a five-day break from its determination of the federal financial assistance amount the student had earned during the fall 2023 term. Although this student had earned all of the federal financial assistance prior to the student’s withdrawal from enrollment, UW-Platteville incorrectly returned $1,226. Because UW-Platteville used the same calculation for all determinations for the fall 2023 term, there may be further errors in the federal financial assistance amounts UW-Platteville determined.
Context:
UW-Platteville uses a student information system to track activity for students who withdraw from enrollment in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Platteville staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Platteville to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 5 students who had received federal financial assistance and who withdrew from UW-Platteville to determine the amount of federal financial assistance those students earned and the related amounts UW-Platteville returned to the U.S. Department of Education.
Questioned Costs:
$24, Plus an Undetermined Amount
Effect:
UW-Platteville did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Platteville did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal financial assistance to return to the federal government. After we identified the error for the student who attended only one day, UW-Platteville returned the additional $24 to the federal government in November 2024. For the fall 2023 term, UW-Platteville changed its fall break from four to five days, which required a change in the number of academic days used in the calculation of federal financial assistance earned when a student withdraws from enrollment. UW-Platteville did not have a process to review the academic calendar for purposes of its return procedures.
Recommendation:
We recommend the University of Wisconsin-Platteville review, update, and implement its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including annually reviewing the academic days used in its determinations.
Finding 2024-706: Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $24, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Platteville: The University of Wisconsin-Platteville agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Background:
UW-Whitewater receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Whitewater reported a total of $58.4 million in federal financial assistance under the SFA Cluster. UW-Whitewater is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Whitewater must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook, the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW-Whitewater is required to be returned to the U.S. Department of Education unless certain conditions are met.
Condition:
UW-Whitewater inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education for one of seven students we reviewed who withdrew from enrollment during FY 2023 24. UW-Whitewater incorrectly accounted for a disbursement to the student that occurred after the date for which UW-Whitewater later identified the student had withdrawn from enrollment as an amount that was earned by the student. As a result, UW-Whitewater failed to return $400 in federal financial assistance to the U.S. Department of Education for the spring 2024 term.
Context:
In order to determine the federal financial assistance a student earned and the amount that must be returned to the U.S. Department of Education for amounts a student did not earn, UW-Whitewater uses a student information system to track activity for students who withdraw. We discussed with UW-Whitewater staff the process used for identifying students who withdrew from enrollment. We also requested information from UW-Whitewater to identify students who withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 7 students who had received federal financial assistance and who withdrew from UW-Whitewater to determine the amount of federal financial assistance those students earned and the related amounts UW-Whitewater returned to the U.S. Department of Education.
Questioned Costs:
$400, Plus an Undetermined Amount
Effect:
UW-Whitewater did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Whitewater did not have adequate procedures to review and ensure its determination of the amount of federal assistance to return was accurate. Although UW-Whitewater disbursed federal financial assistance later than is typical to the student, the disbursement was not correctly categorized within the calculations completed by UW-Whitewater nor was the categorization error detected by other
UW-Whitewater procedures.
Recommendation:
We recommend the University of Wisconsin-Whitewater:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the student we identified.
Finding 2024-707: Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $400, Plus an Undetermined Amount
Type of Finding: Noncompliance
Response from the University of Wisconsin-Whitewater: The University of Wisconsin-Whitewater agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Madison is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to the National Student Loan Data System (NSLDS). Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Madison is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time;
-report the same effective date for a student who withdraws from enrollment as the date used in its determination of whether any federal financial assistance must be returned in accordance with
34 CFR s. 668.22;
-report a student who has completed a program with a status of “graduated” rather than “withdrawn”;
-maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed; and
-maintain the program begin date, which is the date the student first began attending the program being reported, if a student’s program of study has not changed.
Condition:
UW-Madison uses the National Student Clearinghouse (NSC) to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Madison that identify potential errors in UW-Madison’s reporting of student activities. It is the responsibility of UW-Madison to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Madison did not report to NSLDS accurate information for 12 of the 17 students we reviewed. First, UW-Madison did not accurately report a student who withdrew from enrollment without notification in a timely manner. Second, UW-Madison incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment. Third, UW-Madison incorrectly reported the program-level enrollment status effective date for two students. Fourth, UW-Madison incorrectly reported the program begin date for six students. In addition, UW Madison incorrectly reported both the program-level enrollment status effective date and program begin date for two students.
Context:
We discussed with UW-Madison staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Madison relies on data from its student information system to compile information to transmit to NSC. UW-Madison also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student that withdrew from UW-Madison and six students who graduated from UW-Madison. In addition, we selected ten additional UW-Madison students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Madison did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Madison did not report to NSLDS who had withdrawn from enrollment without notification, we found UW-Madison’s enrollment reporting procedures did not assign responsibility for communicating certain information to those staff in the registrar’s office who are responsible for NSLDS reporting. As a result, those students the financial aid office determined had withdrawn from enrollment without notification, and for which it had completed a determination of federal financial assistance the students did not earn, were not known to staff in the registrar’s office for purposes of NSLDS reporting. In addition, UW-Madison indicated that withdrawals from enrollment without notification are identified after the term ends and its student information system did not have a dedicated effective date field in order to automatically identify such student records for the required NSLDS reporting.
Second, for the student UW-Madison did not accurately report as graduated within NSLDS, we found UW‑Madison relied on a NSC process that is intended to simultaneously update a student’s enrollment status in NSLDS when UW-Madison separately updates a student’s degree as completed. UW-Madison did not complete a separate report to ensure the enrollment status for graduated students was accurately reflected in NSLDS. However, in 2022 NSC had published information that indicated reliance solely on NSC’s process may result in the incorrect status being reported under certain circumstances. Although NSC error reports identified that such errors were present, UW-Madison indicated that it did not review these errors until fall 2024 when it began implementing new U.S. Department of Education reporting requirements.
At that time, UW-Madison stated that it identified that it did not consistently and accurately report in NSLDS those students who had graduated. UW-Madison stated that it then began to work with NSC to identify the extent of the reporting inaccuracies.
Third, in 2021 NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW-Madison’s data from its student information system and had communicated error or warning codes to UW-Madison in these areas. However, UW-Madison did not sufficiently review whether the records identified by NSC as potential errors resulted in inaccurate reporting. For example, NSC used warning codes for potential errors in the program-level enrollment status effective dates. As warning codes do not prohibit submission of reporting, UW-Madison did not review the warnings.
Fourth, in 2021 NSC similarly published information on accurately reporting student program begin dates in NSLDS and NSC had also identified instances of potential inaccurate reporting in UW Madison’s data from its student information system. Although NSC had communicated error or warning codes to UW-Madison in these areas, UW-Madison had not sufficiently reviewed whether the records identified by NSC as potential errors resulted in inaccurate reporting until 2023. At that time, UW-Madison indicated that, after reviewing other NSC warnings, it identified that it did not accurately report program begin dates for students. UW-Madison indicated it then began to work to update its student information system data extraction process to identify the correct program begin date for its submissions to NSC. However, it did not implement these changes until after the audit period.
In addition, UW-Madison indicated that it had turnover in staff responsible for NSLDS reporting in 2021, which may have caused UW-Madison to have missed the NSC publications regarding reporting graduated students accurately, new warning codes, and the importance of reviewing certain warning codes to accurately complete NSLDS reporting.
Recommendation:
We recommend the University of Wisconsin-Madison:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as updating its student information system to allow for an automated identification process to communicate those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated and implement separate reporting to the National Student Clearinghouse to accurately report students who graduate;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program-level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program begin dates and update its student information system extraction process to accurately report program begin dates; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-708: Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Background:
UW-Milwaukee receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Milwaukee reported a total of $133.1 million in federal financial assistance under the SFA Cluster. UW-Milwaukee records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Milwaukee is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Milwaukee is required to maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed.
Condition:
UW-Milwaukee uses NSC to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Milwaukee that identify potential errors in UW-Milwaukee’s reporting of student activities through NSC. These errors are the responsibility of UW-Milwaukee to resolve to ensure its submissions to NSLDS are accurate and complete.
UW-Milwaukee did not report to NSLDS accurate information for the program level enrollment status effective date for five students we reviewed. In addition, based on how information from its student information system is extracted for student reporting to NSLDS, we found that the reporting inaccuracy extended to other UW-Milwaukee students.
Context:
We discussed with UW-Milwaukee staff its procedures for identifying student enrollment status changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Milwaukee relies on data from its student information system to compile information to transmit to NSC. UW-Milwaukee also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included two students who withdrew from UW-Milwaukee and four students who graduated from UW- Milwaukee. In addition, we selected ten additional UW-Milwaukee students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Milwaukee did not comply with requirements to accurately report certain student enrollment status changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
In 2021, NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW- Milwaukee’s data from its student information system and had communicated error or warning codes to UW-Milwaukee in these areas. UW-Milwaukee staff indicated that they were aware that NSC error reports included warnings to identify potential inaccurate reporting of program level enrollment status effective dates and that the errors were a known issue for Peoplesoft-based student information systems. However, UW-Milwaukee chose not to use an all-record update feature that was available to correct the program-level enrollment status effective dates for all student records simultaneously due to the risk that other reporting inaccuracies could result from the action. Further, UW-Milwaukee staff indicated that they were not aware that specific guidance on the program-level enrollment status effective date had been updated to reflect that corrections should be made to fully comply with NSLDS reporting requirements.
Recommendation:
We recommend the University of Wisconsin-Milwaukee:
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates; and
-report changes in student enrollment accurately, completely, and in a timely manner for all student changes that require reporting.
Finding 2024-709: Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Milwaukee: The University of Wisconsin-Milwaukee agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Background:
UW-Oshkosh receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Oshkosh reported a total of $45.3 million in federal financial assistance under the SFA Cluster. UW-Oshkosh records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Oshkosh is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Oshkosh is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time; and
-report a student who has completed a program with a status of “graduated” rather than “withdrawn.”
Condition:
UW-Oshkosh uses NSC to facilitate the enrollment reporting in NSLDS. NSC provides error reports to UW-Oshkosh that identify potential errors in UW Oshkosh’s reporting of student activities. It is the responsibility of UW-Oshkosh to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Oshkosh did not report to NSLDS accurate information for two of the three students we reviewed.
First, UW-Oshkosh did not report in a timely manner one student who withdrew from enrollment without notification. Second, UW-Oshkosh incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment.
Context:
We discussed with UW-Oshkosh staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and UW Oshkosh’s procedures for monitoring the reporting performed by NSC. UW-Oshkosh relies on data from its student information system to compile information to transmit to NSC. UW-Oshkosh also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve. To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023 24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student who withdrew from UW-Oshkosh and two students who graduated from UW‑Oshkosh.
Questioned Costs:
None.
Effect:
UW-Oshkosh did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Oshkosh did not report to NSLDS in a timely manner who had withdrawn from enrollment without notification, we found that UW-Oshkosh indicated that it believed it needed to report to NSLDS only when students withdrew from enrollment and had notified UW-Oshkosh of the withdrawal. As a result, students detected by UW Oshkosh through procedures completed by the financial aid office at the end of each term were not communicated to those staff in the registrar’s office who were responsible for NSLDS reporting.
Second, for the student UW-Oshkosh did not accurately report as graduated within NSLDS, we found that inaccuracies in the reporting of students who had graduated were noted on NSC error reports. However, UW-Oshkosh’s registrar’s office staff did sufficiently review the errors to correct the status in NSLDS.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as communicating those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-710: Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Background:
UW Parkside operates in a highly computerized environment and is responsible for maintaining confidential and sensitive information, such as student data. UW Parkside maintains its own student information system to administer federal student financial assistance programs under the SFA Cluster.
Criteria:
To ensure data processed and stored by UW-Parkside is protected from accidental or intentional misuse or destruction, and to provide proper internal control, information technology (IT) security policies and procedures are necessary. In addition, IT controls should be established to prevent inappropriate or inadvertent access to data. UW-Parkside is responsible for following specific requirements under the Gramm-Leach-Bliley Act (GLBA), which requires entities that administer student financial assistance programs to develop, implement, and maintain safeguards to protect the security, integrity, and confidentiality of student data.
Under GLBA, UW-Parkside is required to authenticate and permit access only to authorized users. Further, UW Board of Regents Policy 25-5 requires that UW-Parkside follow the National Institute of Standards and Technology (NIST) in establishing IT controls. NIST Special Publication (SP) 800-53, Security and Privacy Controls for Information Systems and Organizations, recommends best practices in IT controls related to user access. These best practices include developing a provisioning and deprovisioning process focused on limiting access in a manner that provides the least access based on business need; retaining documentation of provisioning and deprovisioning activities, including records of when such access was added or removed; and performing periodic reviews of access to ensure it remains appropriate.
Condition:
We found UW-Parkside did not have adequate IT controls in place during FY 2023-24 to provision, deprovision, and manage access to its student information system. First, UW-Parkside did not have a formal documented process to provision or deprovision user access to its student information system. Second, UW-Parkside did not maintain a list of provisioned users with access and was unable to generate a report of users provisioned or deprovisioned during FY 2023-24. Third, UW-Parkside did not complete a periodic review of access, which assists in ensuring its provisioning and deprovisioning processes are working as intended. Although failure in any one IT control may be detected by complementary IT controls, UW‑Parkside did not have effective IT controls in any of the three areas. As a result, UW-Parkside was at a higher risk of granting unauthorized access to its student information system.
Context:
We reviewed GLBA requirements, UW System Board of Regents policies, and NIST 800-53 guidance to identify policies and procedures for UW-Parkside’s monitoring of access granted to its student information system. We requested documentation from UW-Parkside to assess compliance with these policies.
Questioned Costs:
None.
Effect:
Ineffective general IT controls may permit controls over systems to operate improperly and may allow noncompliance to occur and not be detected. Weaknesses in IT security policies, procedures, and controls increase the risk that unauthorized or erroneous transactions could be processed or changes made to student data. In addition, failure to provide an appropriate level of protection for its student information system and data increased the risk that personally identifiable information could be accidentally or maliciously exposed.
Cause:
UW-Parkside did not have a formal policy or procedures in place to provision, deprovision, and review access to its student information system. UW-Parkside staff indicated the process for provisioning and deprovisioning access had been informally operated, such as through electronic mail and direct communication and it did not consistently retain documentation of these communications. For example,
UW-Parkside indicated access requests were accepted from a variety of UW-Parkside employees. As a result, UW-Parkside had not assessed whether a user’s access was necessary or otherwise limited the access only to specific information needed or to a specified time period. Finally, UW-Parkside also indicated that prior efforts to improve its provisioning and deprovisioning of user access were not fully completed or implemented, in part, due to staff turnover.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-develop and implement written procedures for provisioning and deprovisioning user access to its student information system, including specifying those who are authorized to request user access and assigning responsibility to staff to assess access requests to restrict the access only to data needed for a specified period of time;
-retain consistent documentation of its provisioning and deprovisioning activities;
-develop and implement written procedures for a review at least annually of access granted to its student information system; and
-complete an assessment of users who currently have access to its student information system and remove those users who no longer require the access.
Finding 2024-711: Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-Madison must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. For students that begin attending classes, but who later withdraw from enrollment, 34 CFR s. 668.22 requires that UW-Madison must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In order not to consider a student to have withdrawn from enrollment under certain circumstances, which permits a student to retain federal financial assistance that otherwise would need to be returned to the federal government, 34 CFR s. 668.22 (a) (2) (ii) provides certain exemptions to students.
Condition:
For four students, we found that UW-Madison did not accurately determine the amount of federal financial assistance it disbursed that should have been returned to the U.S. Department of Education. First, we found that UW-Madison did not return all federal financial assistance it disbursed to two students that did not begin attendance and to one student who only attended one day during FY 2023-24. For these three students, UW-Madison determined it failed to return $16,403 in federal financial assistance it disbursed during FY 2023-24. Second, we found that UW-Madison did not accurately determine the federal financial assistance that should be returned after a student withdrew from enrollment during the summer 2023 term. For this student, UW-Madison incorrectly applied an exemption, which led to UW-Madison failing to return $584 in federal financial assistance to the U.S. Department of Education.
Context:
UW-Madison uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Madison staff its process for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Madison to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. When reviewing the data UW-Madison provided, we noted potential errors in the amount of aid returned for students identified as never attending.
Separately, as part of a UW systemwide sample of 60 students, we selected 6 students who had received federal financial assistance and who withdrew from enrollment from UW-Madison to determine the amount of federal financial assistance those students earned and the related amounts UW-Madison returned to the U.S. Department of Education.
Questioned Costs:
$16,987, Plus an Undetermined Amount
Effect:
UW-Madison did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Madison identified that the errors in determining the amount of the federal financial assistance that should have been returned to the federal government for the four students we identified were manual errors in the withdrawal procedures and calculations completed during and at the end of each term. These errors were not detected by any other review procedures. Although UW-Madison correctly identified the status of the two students who never attended and the need to return all disbursed federal financial assistance, it did not follow through on the actual repayment.
For the student who had an exemption applied, the exemption was incorrectly selected when UW-Madison completed a determination, and the error was not detected in UW-Madison’s review process. UW-Madison indicated that its automated review processes conducted at the end of each term did not specifically address the matters we identified for the four students.
After we identified these errors in the determination of the amount of federal financial assistance to return to the federal government, UW-Madison returned in fall 2024 the unearned federal financial assistance for the three students who never attended or withdrew from enrollment after attending one day. In addition, UW Madison returned the additional $584 in February 2025 for the student who withdrew from enrollment and did not meet the criteria for a withdrawal exemption.
Recommendation:
We recommend the University of Wisconsin-Madison review, update, and implement its procedures to improve the accuracy and follow-through for making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including thoroughly reviewing applied exemptions, and returning federal financial assistance in a timely manner to the federal government.
Finding 2024-703: Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,987, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Background:
UW-River Falls receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-River Falls reported a total of $23.6 million in federal financial assistance under the SFA Cluster. UW-River Falls is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-River Falls must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. Under Volume 5, Chapter 1 of the Federal Student Aid Handbook, when a student begins attendance in at least one course but does not begin attendance in all courses the student was scheduled to attend, the school must determine if it is necessary to recalculate the student’s eligibility for the Pell Grant based on a revised enrollment status and the cost of education pursuant to 34 CFR s. 690.80. If the student withdraws, this recalculation must be performed before determining whether to return federal financial assistance pursuant to 34 CFR s. 668.22.
Condition:
We found that UW-River Falls did not return $16,010 in federal financial assistance for four students that did not begin attendance in all enrolled courses during FY 2023-24. This included two students who never began attendance in any enrolled courses for whom all disbursed federal financial assistance was required to be returned. This also included two students who began at least one course but not all courses for which the students had enrolled. UW-River Falls did not perform the required recalculation of Pell Grant eligibility or an assessment of federal financial assistance it had disbursed that these students had not earned.
Context:
UW-River Falls uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-River Falls the process used for identifying students who did not begin attending all enrolled courses or withdrew from enrollment, and we requested a list of such students during FY 2023-24. UW-River Falls did not have a complete list readily available of students who did not begin attending all enrolled courses.
Questioned Costs:
$16,010, Plus an Undetermined Amount
Effect:
UW-River Falls did not comply with all requirements to return federal financial assistance for students who never attended or did not begin attending all enrolled courses during FY 2023-24.
Cause:
UW-River Falls did not have procedures to identify from its student information system, or other sources, those students for whom it disbursed federal financial assistance, yet the students did not attend at least one course during the term or begin all courses enrolled. Depending on whether a student dropped any of their courses, UW-River Falls indicated that the procedures to evaluate attendance may not have identified all students who would ultimately be determined as never attending for the academic term.
After we requested a list of students who did not begin attending all enrolled courses, UW-River Falls identified two students who did not begin at least one course but for whom it had disbursed federal financial assistance. For the other two students who began at least one course, UW-River Falls completed the required Pell Grant recalculation for the students. UW-River Falls also determined the amount of federal financial assistance to return for all four students, as applicable, to the U.S. Department of Education in September 2024.
Recommendation:
We recommend the University of Wisconsin-River Falls review, update, and implement procedures to:
-identify students after the start of each academic term for whom it disbursed federal financial assistance and the students did not begin all enrolled courses;
-complete required recalculations for Pell Grant eligibility and a determination of federal financial assistance that was not earned by the students, as applicable; and
-return amounts to the federal government in a timely manner.
Finding 2024-704: Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,010, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-River Falls: The University of Wisconsin-River Falls agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Background:
UW-Parkside receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Parkside reported a total of $21.3 million in federal financial assistance under the SFA Cluster. UW-Parkside is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22, requires that UW-Parkside must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW Parkside should be returned to the U.S. Department of Education unless certain conditions are met. In determining whether federal financial assistance was earned by a student, the Federal Student Aid Handbook provides guidance on how to calculate applicable institution charges and academic days under different circumstances.
Condition:
For two of three students we reviewed who withdrew from enrollment during FY 2023-24, UW-Parkside inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Parkside incorrectly accounted for a disbursement that occurred after the student’s withdrawal from enrollment as an amount that was earned by the student for the fall 2023 term. As a result, UW Parkside returned $548 less than what should have been returned to the U.S. Department of Education. For the second student, UW-Parkside incorrectly identified the end date of the spring 2024 term and did not include the correct institutional charges in its determination. As a result, UW-Parkside returned $1,190 less than should have been returned to the U.S. Department of Education.
Context:
UW-Parkside uses a student information system to track activity for students that withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Parkside staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from
UW-Parkside to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 3 students who had received federal financial assistance and withdrew from UW-Parkside to determine the amount of federal financial assistance those students earned and the related amounts UW-Parkside returned to the U.S. Department of Education.
Questioned Costs:
$1,738, Plus an Undetermined Amount
Effect:
UW-Parkside did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Parkside did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal assistance to return. Although UW-Parkside disbursed federal financial assistance later than is typical to one student, the disbursement was not correctly categorized within the calculations completed by UW-Parkside to determine that the entire amount of the federal financial assistance was required to be returned to the federal government.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the students we identified.
Finding 2024-705: Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $1,738, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Background:
UW-Platteville receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Platteville reported a total of $29.1 million in federal financial assistance under the SFA Cluster. UW-Platteville is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Under 34 CFR s. 668.21, UW-Platteville must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. In addition, when a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Platteville must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In determining whether federal financial assistance was earned by a student, Volume 5, Chapter 2 of the Federal Student Aid Handbook specifies how to calculate academic days.
Condition:
For two of the five students we reviewed who never began attendance or who withdrew from enrollment during FY 2023-24, UW-Platteville inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Platteville incorrectly determined the student began attendance because the student attended one day of the fall 2023 term. As a result, UW-Platteville failed to return $24 in federal financial assistance to the U.S. Department of Education. For the second student, UW-Platteville did not exclude a five-day break from its determination of the federal financial assistance amount the student had earned during the fall 2023 term. Although this student had earned all of the federal financial assistance prior to the student’s withdrawal from enrollment, UW-Platteville incorrectly returned $1,226. Because UW-Platteville used the same calculation for all determinations for the fall 2023 term, there may be further errors in the federal financial assistance amounts UW-Platteville determined.
Context:
UW-Platteville uses a student information system to track activity for students who withdraw from enrollment in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Platteville staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Platteville to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 5 students who had received federal financial assistance and who withdrew from UW-Platteville to determine the amount of federal financial assistance those students earned and the related amounts UW-Platteville returned to the U.S. Department of Education.
Questioned Costs:
$24, Plus an Undetermined Amount
Effect:
UW-Platteville did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Platteville did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal financial assistance to return to the federal government. After we identified the error for the student who attended only one day, UW-Platteville returned the additional $24 to the federal government in November 2024. For the fall 2023 term, UW-Platteville changed its fall break from four to five days, which required a change in the number of academic days used in the calculation of federal financial assistance earned when a student withdraws from enrollment. UW-Platteville did not have a process to review the academic calendar for purposes of its return procedures.
Recommendation:
We recommend the University of Wisconsin-Platteville review, update, and implement its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including annually reviewing the academic days used in its determinations.
Finding 2024-706: Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $24, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Platteville: The University of Wisconsin-Platteville agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Background:
UW-Whitewater receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Whitewater reported a total of $58.4 million in federal financial assistance under the SFA Cluster. UW-Whitewater is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Whitewater must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook, the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW-Whitewater is required to be returned to the U.S. Department of Education unless certain conditions are met.
Condition:
UW-Whitewater inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education for one of seven students we reviewed who withdrew from enrollment during FY 2023 24. UW-Whitewater incorrectly accounted for a disbursement to the student that occurred after the date for which UW-Whitewater later identified the student had withdrawn from enrollment as an amount that was earned by the student. As a result, UW-Whitewater failed to return $400 in federal financial assistance to the U.S. Department of Education for the spring 2024 term.
Context:
In order to determine the federal financial assistance a student earned and the amount that must be returned to the U.S. Department of Education for amounts a student did not earn, UW-Whitewater uses a student information system to track activity for students who withdraw. We discussed with UW-Whitewater staff the process used for identifying students who withdrew from enrollment. We also requested information from UW-Whitewater to identify students who withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 7 students who had received federal financial assistance and who withdrew from UW-Whitewater to determine the amount of federal financial assistance those students earned and the related amounts UW-Whitewater returned to the U.S. Department of Education.
Questioned Costs:
$400, Plus an Undetermined Amount
Effect:
UW-Whitewater did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Whitewater did not have adequate procedures to review and ensure its determination of the amount of federal assistance to return was accurate. Although UW-Whitewater disbursed federal financial assistance later than is typical to the student, the disbursement was not correctly categorized within the calculations completed by UW-Whitewater nor was the categorization error detected by other
UW-Whitewater procedures.
Recommendation:
We recommend the University of Wisconsin-Whitewater:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the student we identified.
Finding 2024-707: Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $400, Plus an Undetermined Amount
Type of Finding: Noncompliance
Response from the University of Wisconsin-Whitewater: The University of Wisconsin-Whitewater agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Madison is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to the National Student Loan Data System (NSLDS). Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Madison is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time;
-report the same effective date for a student who withdraws from enrollment as the date used in its determination of whether any federal financial assistance must be returned in accordance with
34 CFR s. 668.22;
-report a student who has completed a program with a status of “graduated” rather than “withdrawn”;
-maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed; and
-maintain the program begin date, which is the date the student first began attending the program being reported, if a student’s program of study has not changed.
Condition:
UW-Madison uses the National Student Clearinghouse (NSC) to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Madison that identify potential errors in UW-Madison’s reporting of student activities. It is the responsibility of UW-Madison to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Madison did not report to NSLDS accurate information for 12 of the 17 students we reviewed. First, UW-Madison did not accurately report a student who withdrew from enrollment without notification in a timely manner. Second, UW-Madison incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment. Third, UW-Madison incorrectly reported the program-level enrollment status effective date for two students. Fourth, UW-Madison incorrectly reported the program begin date for six students. In addition, UW Madison incorrectly reported both the program-level enrollment status effective date and program begin date for two students.
Context:
We discussed with UW-Madison staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Madison relies on data from its student information system to compile information to transmit to NSC. UW-Madison also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student that withdrew from UW-Madison and six students who graduated from UW-Madison. In addition, we selected ten additional UW-Madison students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Madison did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Madison did not report to NSLDS who had withdrawn from enrollment without notification, we found UW-Madison’s enrollment reporting procedures did not assign responsibility for communicating certain information to those staff in the registrar’s office who are responsible for NSLDS reporting. As a result, those students the financial aid office determined had withdrawn from enrollment without notification, and for which it had completed a determination of federal financial assistance the students did not earn, were not known to staff in the registrar’s office for purposes of NSLDS reporting. In addition, UW-Madison indicated that withdrawals from enrollment without notification are identified after the term ends and its student information system did not have a dedicated effective date field in order to automatically identify such student records for the required NSLDS reporting.
Second, for the student UW-Madison did not accurately report as graduated within NSLDS, we found UW‑Madison relied on a NSC process that is intended to simultaneously update a student’s enrollment status in NSLDS when UW-Madison separately updates a student’s degree as completed. UW-Madison did not complete a separate report to ensure the enrollment status for graduated students was accurately reflected in NSLDS. However, in 2022 NSC had published information that indicated reliance solely on NSC’s process may result in the incorrect status being reported under certain circumstances. Although NSC error reports identified that such errors were present, UW-Madison indicated that it did not review these errors until fall 2024 when it began implementing new U.S. Department of Education reporting requirements.
At that time, UW-Madison stated that it identified that it did not consistently and accurately report in NSLDS those students who had graduated. UW-Madison stated that it then began to work with NSC to identify the extent of the reporting inaccuracies.
Third, in 2021 NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW-Madison’s data from its student information system and had communicated error or warning codes to UW-Madison in these areas. However, UW-Madison did not sufficiently review whether the records identified by NSC as potential errors resulted in inaccurate reporting. For example, NSC used warning codes for potential errors in the program-level enrollment status effective dates. As warning codes do not prohibit submission of reporting, UW-Madison did not review the warnings.
Fourth, in 2021 NSC similarly published information on accurately reporting student program begin dates in NSLDS and NSC had also identified instances of potential inaccurate reporting in UW Madison’s data from its student information system. Although NSC had communicated error or warning codes to UW-Madison in these areas, UW-Madison had not sufficiently reviewed whether the records identified by NSC as potential errors resulted in inaccurate reporting until 2023. At that time, UW-Madison indicated that, after reviewing other NSC warnings, it identified that it did not accurately report program begin dates for students. UW-Madison indicated it then began to work to update its student information system data extraction process to identify the correct program begin date for its submissions to NSC. However, it did not implement these changes until after the audit period.
In addition, UW-Madison indicated that it had turnover in staff responsible for NSLDS reporting in 2021, which may have caused UW-Madison to have missed the NSC publications regarding reporting graduated students accurately, new warning codes, and the importance of reviewing certain warning codes to accurately complete NSLDS reporting.
Recommendation:
We recommend the University of Wisconsin-Madison:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as updating its student information system to allow for an automated identification process to communicate those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated and implement separate reporting to the National Student Clearinghouse to accurately report students who graduate;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program-level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program begin dates and update its student information system extraction process to accurately report program begin dates; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-708: Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Background:
UW-Milwaukee receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Milwaukee reported a total of $133.1 million in federal financial assistance under the SFA Cluster. UW-Milwaukee records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Milwaukee is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Milwaukee is required to maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed.
Condition:
UW-Milwaukee uses NSC to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Milwaukee that identify potential errors in UW-Milwaukee’s reporting of student activities through NSC. These errors are the responsibility of UW-Milwaukee to resolve to ensure its submissions to NSLDS are accurate and complete.
UW-Milwaukee did not report to NSLDS accurate information for the program level enrollment status effective date for five students we reviewed. In addition, based on how information from its student information system is extracted for student reporting to NSLDS, we found that the reporting inaccuracy extended to other UW-Milwaukee students.
Context:
We discussed with UW-Milwaukee staff its procedures for identifying student enrollment status changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Milwaukee relies on data from its student information system to compile information to transmit to NSC. UW-Milwaukee also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included two students who withdrew from UW-Milwaukee and four students who graduated from UW- Milwaukee. In addition, we selected ten additional UW-Milwaukee students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Milwaukee did not comply with requirements to accurately report certain student enrollment status changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
In 2021, NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW- Milwaukee’s data from its student information system and had communicated error or warning codes to UW-Milwaukee in these areas. UW-Milwaukee staff indicated that they were aware that NSC error reports included warnings to identify potential inaccurate reporting of program level enrollment status effective dates and that the errors were a known issue for Peoplesoft-based student information systems. However, UW-Milwaukee chose not to use an all-record update feature that was available to correct the program-level enrollment status effective dates for all student records simultaneously due to the risk that other reporting inaccuracies could result from the action. Further, UW-Milwaukee staff indicated that they were not aware that specific guidance on the program-level enrollment status effective date had been updated to reflect that corrections should be made to fully comply with NSLDS reporting requirements.
Recommendation:
We recommend the University of Wisconsin-Milwaukee:
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates; and
-report changes in student enrollment accurately, completely, and in a timely manner for all student changes that require reporting.
Finding 2024-709: Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Milwaukee: The University of Wisconsin-Milwaukee agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Background:
UW-Oshkosh receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Oshkosh reported a total of $45.3 million in federal financial assistance under the SFA Cluster. UW-Oshkosh records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Oshkosh is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Oshkosh is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time; and
-report a student who has completed a program with a status of “graduated” rather than “withdrawn.”
Condition:
UW-Oshkosh uses NSC to facilitate the enrollment reporting in NSLDS. NSC provides error reports to UW-Oshkosh that identify potential errors in UW Oshkosh’s reporting of student activities. It is the responsibility of UW-Oshkosh to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Oshkosh did not report to NSLDS accurate information for two of the three students we reviewed.
First, UW-Oshkosh did not report in a timely manner one student who withdrew from enrollment without notification. Second, UW-Oshkosh incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment.
Context:
We discussed with UW-Oshkosh staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and UW Oshkosh’s procedures for monitoring the reporting performed by NSC. UW-Oshkosh relies on data from its student information system to compile information to transmit to NSC. UW-Oshkosh also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve. To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023 24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student who withdrew from UW-Oshkosh and two students who graduated from UW‑Oshkosh.
Questioned Costs:
None.
Effect:
UW-Oshkosh did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Oshkosh did not report to NSLDS in a timely manner who had withdrawn from enrollment without notification, we found that UW-Oshkosh indicated that it believed it needed to report to NSLDS only when students withdrew from enrollment and had notified UW-Oshkosh of the withdrawal. As a result, students detected by UW Oshkosh through procedures completed by the financial aid office at the end of each term were not communicated to those staff in the registrar’s office who were responsible for NSLDS reporting.
Second, for the student UW-Oshkosh did not accurately report as graduated within NSLDS, we found that inaccuracies in the reporting of students who had graduated were noted on NSC error reports. However, UW-Oshkosh’s registrar’s office staff did sufficiently review the errors to correct the status in NSLDS.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as communicating those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-710: Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Background:
UW Parkside operates in a highly computerized environment and is responsible for maintaining confidential and sensitive information, such as student data. UW Parkside maintains its own student information system to administer federal student financial assistance programs under the SFA Cluster.
Criteria:
To ensure data processed and stored by UW-Parkside is protected from accidental or intentional misuse or destruction, and to provide proper internal control, information technology (IT) security policies and procedures are necessary. In addition, IT controls should be established to prevent inappropriate or inadvertent access to data. UW-Parkside is responsible for following specific requirements under the Gramm-Leach-Bliley Act (GLBA), which requires entities that administer student financial assistance programs to develop, implement, and maintain safeguards to protect the security, integrity, and confidentiality of student data.
Under GLBA, UW-Parkside is required to authenticate and permit access only to authorized users. Further, UW Board of Regents Policy 25-5 requires that UW-Parkside follow the National Institute of Standards and Technology (NIST) in establishing IT controls. NIST Special Publication (SP) 800-53, Security and Privacy Controls for Information Systems and Organizations, recommends best practices in IT controls related to user access. These best practices include developing a provisioning and deprovisioning process focused on limiting access in a manner that provides the least access based on business need; retaining documentation of provisioning and deprovisioning activities, including records of when such access was added or removed; and performing periodic reviews of access to ensure it remains appropriate.
Condition:
We found UW-Parkside did not have adequate IT controls in place during FY 2023-24 to provision, deprovision, and manage access to its student information system. First, UW-Parkside did not have a formal documented process to provision or deprovision user access to its student information system. Second, UW-Parkside did not maintain a list of provisioned users with access and was unable to generate a report of users provisioned or deprovisioned during FY 2023-24. Third, UW-Parkside did not complete a periodic review of access, which assists in ensuring its provisioning and deprovisioning processes are working as intended. Although failure in any one IT control may be detected by complementary IT controls, UW‑Parkside did not have effective IT controls in any of the three areas. As a result, UW-Parkside was at a higher risk of granting unauthorized access to its student information system.
Context:
We reviewed GLBA requirements, UW System Board of Regents policies, and NIST 800-53 guidance to identify policies and procedures for UW-Parkside’s monitoring of access granted to its student information system. We requested documentation from UW-Parkside to assess compliance with these policies.
Questioned Costs:
None.
Effect:
Ineffective general IT controls may permit controls over systems to operate improperly and may allow noncompliance to occur and not be detected. Weaknesses in IT security policies, procedures, and controls increase the risk that unauthorized or erroneous transactions could be processed or changes made to student data. In addition, failure to provide an appropriate level of protection for its student information system and data increased the risk that personally identifiable information could be accidentally or maliciously exposed.
Cause:
UW-Parkside did not have a formal policy or procedures in place to provision, deprovision, and review access to its student information system. UW-Parkside staff indicated the process for provisioning and deprovisioning access had been informally operated, such as through electronic mail and direct communication and it did not consistently retain documentation of these communications. For example,
UW-Parkside indicated access requests were accepted from a variety of UW-Parkside employees. As a result, UW-Parkside had not assessed whether a user’s access was necessary or otherwise limited the access only to specific information needed or to a specified time period. Finally, UW-Parkside also indicated that prior efforts to improve its provisioning and deprovisioning of user access were not fully completed or implemented, in part, due to staff turnover.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-develop and implement written procedures for provisioning and deprovisioning user access to its student information system, including specifying those who are authorized to request user access and assigning responsibility to staff to assess access requests to restrict the access only to data needed for a specified period of time;
-retain consistent documentation of its provisioning and deprovisioning activities;
-develop and implement written procedures for a review at least annually of access granted to its student information system; and
-complete an assessment of users who currently have access to its student information system and remove those users who no longer require the access.
Finding 2024-711: Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-Madison must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. For students that begin attending classes, but who later withdraw from enrollment, 34 CFR s. 668.22 requires that UW-Madison must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In order not to consider a student to have withdrawn from enrollment under certain circumstances, which permits a student to retain federal financial assistance that otherwise would need to be returned to the federal government, 34 CFR s. 668.22 (a) (2) (ii) provides certain exemptions to students.
Condition:
For four students, we found that UW-Madison did not accurately determine the amount of federal financial assistance it disbursed that should have been returned to the U.S. Department of Education. First, we found that UW-Madison did not return all federal financial assistance it disbursed to two students that did not begin attendance and to one student who only attended one day during FY 2023-24. For these three students, UW-Madison determined it failed to return $16,403 in federal financial assistance it disbursed during FY 2023-24. Second, we found that UW-Madison did not accurately determine the federal financial assistance that should be returned after a student withdrew from enrollment during the summer 2023 term. For this student, UW-Madison incorrectly applied an exemption, which led to UW-Madison failing to return $584 in federal financial assistance to the U.S. Department of Education.
Context:
UW-Madison uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Madison staff its process for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Madison to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. When reviewing the data UW-Madison provided, we noted potential errors in the amount of aid returned for students identified as never attending.
Separately, as part of a UW systemwide sample of 60 students, we selected 6 students who had received federal financial assistance and who withdrew from enrollment from UW-Madison to determine the amount of federal financial assistance those students earned and the related amounts UW-Madison returned to the U.S. Department of Education.
Questioned Costs:
$16,987, Plus an Undetermined Amount
Effect:
UW-Madison did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Madison identified that the errors in determining the amount of the federal financial assistance that should have been returned to the federal government for the four students we identified were manual errors in the withdrawal procedures and calculations completed during and at the end of each term. These errors were not detected by any other review procedures. Although UW-Madison correctly identified the status of the two students who never attended and the need to return all disbursed federal financial assistance, it did not follow through on the actual repayment.
For the student who had an exemption applied, the exemption was incorrectly selected when UW-Madison completed a determination, and the error was not detected in UW-Madison’s review process. UW-Madison indicated that its automated review processes conducted at the end of each term did not specifically address the matters we identified for the four students.
After we identified these errors in the determination of the amount of federal financial assistance to return to the federal government, UW-Madison returned in fall 2024 the unearned federal financial assistance for the three students who never attended or withdrew from enrollment after attending one day. In addition, UW Madison returned the additional $584 in February 2025 for the student who withdrew from enrollment and did not meet the criteria for a withdrawal exemption.
Recommendation:
We recommend the University of Wisconsin-Madison review, update, and implement its procedures to improve the accuracy and follow-through for making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including thoroughly reviewing applied exemptions, and returning federal financial assistance in a timely manner to the federal government.
Finding 2024-703: Student Financial Assistance Cluster—UW-Madison Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,987, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Background:
UW-River Falls receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-River Falls reported a total of $23.6 million in federal financial assistance under the SFA Cluster. UW-River Falls is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Pursuant to 34 CFR s. 668.21, UW-River Falls must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. Under Volume 5, Chapter 1 of the Federal Student Aid Handbook, when a student begins attendance in at least one course but does not begin attendance in all courses the student was scheduled to attend, the school must determine if it is necessary to recalculate the student’s eligibility for the Pell Grant based on a revised enrollment status and the cost of education pursuant to 34 CFR s. 690.80. If the student withdraws, this recalculation must be performed before determining whether to return federal financial assistance pursuant to 34 CFR s. 668.22.
Condition:
We found that UW-River Falls did not return $16,010 in federal financial assistance for four students that did not begin attendance in all enrolled courses during FY 2023-24. This included two students who never began attendance in any enrolled courses for whom all disbursed federal financial assistance was required to be returned. This also included two students who began at least one course but not all courses for which the students had enrolled. UW-River Falls did not perform the required recalculation of Pell Grant eligibility or an assessment of federal financial assistance it had disbursed that these students had not earned.
Context:
UW-River Falls uses a student information system to track activity for students who withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-River Falls the process used for identifying students who did not begin attending all enrolled courses or withdrew from enrollment, and we requested a list of such students during FY 2023-24. UW-River Falls did not have a complete list readily available of students who did not begin attending all enrolled courses.
Questioned Costs:
$16,010, Plus an Undetermined Amount
Effect:
UW-River Falls did not comply with all requirements to return federal financial assistance for students who never attended or did not begin attending all enrolled courses during FY 2023-24.
Cause:
UW-River Falls did not have procedures to identify from its student information system, or other sources, those students for whom it disbursed federal financial assistance, yet the students did not attend at least one course during the term or begin all courses enrolled. Depending on whether a student dropped any of their courses, UW-River Falls indicated that the procedures to evaluate attendance may not have identified all students who would ultimately be determined as never attending for the academic term.
After we requested a list of students who did not begin attending all enrolled courses, UW-River Falls identified two students who did not begin at least one course but for whom it had disbursed federal financial assistance. For the other two students who began at least one course, UW-River Falls completed the required Pell Grant recalculation for the students. UW-River Falls also determined the amount of federal financial assistance to return for all four students, as applicable, to the U.S. Department of Education in September 2024.
Recommendation:
We recommend the University of Wisconsin-River Falls review, update, and implement procedures to:
-identify students after the start of each academic term for whom it disbursed federal financial assistance and the students did not begin all enrolled courses;
-complete required recalculations for Pell Grant eligibility and a determination of federal financial assistance that was not earned by the students, as applicable; and
-return amounts to the federal government in a timely manner.
Finding 2024-704: Student Financial Assistance Cluster—UW-River Falls Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $16,010, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-River Falls: The University of Wisconsin-River Falls agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Background:
UW-Parkside receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Parkside reported a total of $21.3 million in federal financial assistance under the SFA Cluster. UW-Parkside is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22, requires that UW-Parkside must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW Parkside should be returned to the U.S. Department of Education unless certain conditions are met. In determining whether federal financial assistance was earned by a student, the Federal Student Aid Handbook provides guidance on how to calculate applicable institution charges and academic days under different circumstances.
Condition:
For two of three students we reviewed who withdrew from enrollment during FY 2023-24, UW-Parkside inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Parkside incorrectly accounted for a disbursement that occurred after the student’s withdrawal from enrollment as an amount that was earned by the student for the fall 2023 term. As a result, UW Parkside returned $548 less than what should have been returned to the U.S. Department of Education. For the second student, UW-Parkside incorrectly identified the end date of the spring 2024 term and did not include the correct institutional charges in its determination. As a result, UW-Parkside returned $1,190 less than should have been returned to the U.S. Department of Education.
Context:
UW-Parkside uses a student information system to track activity for students that withdraw in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Parkside staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from
UW-Parkside to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 3 students who had received federal financial assistance and withdrew from UW-Parkside to determine the amount of federal financial assistance those students earned and the related amounts UW-Parkside returned to the U.S. Department of Education.
Questioned Costs:
$1,738, Plus an Undetermined Amount
Effect:
UW-Parkside did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Parkside did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal assistance to return. Although UW-Parkside disbursed federal financial assistance later than is typical to one student, the disbursement was not correctly categorized within the calculations completed by UW-Parkside to determine that the entire amount of the federal financial assistance was required to be returned to the federal government.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the students we identified.
Finding 2024-705: Student Financial Assistance Cluster—UW-Parkside Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $1,738, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Background:
UW-Platteville receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Platteville reported a total of $29.1 million in federal financial assistance under the SFA Cluster. UW-Platteville is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
Under 34 CFR s. 668.21, UW-Platteville must return all federal financial assistance credited or disbursed to a student if the student does not begin attendance. In addition, when a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Platteville must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. In determining whether federal financial assistance was earned by a student, Volume 5, Chapter 2 of the Federal Student Aid Handbook specifies how to calculate academic days.
Condition:
For two of the five students we reviewed who never began attendance or who withdrew from enrollment during FY 2023-24, UW-Platteville inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education. For one student, UW-Platteville incorrectly determined the student began attendance because the student attended one day of the fall 2023 term. As a result, UW-Platteville failed to return $24 in federal financial assistance to the U.S. Department of Education. For the second student, UW-Platteville did not exclude a five-day break from its determination of the federal financial assistance amount the student had earned during the fall 2023 term. Although this student had earned all of the federal financial assistance prior to the student’s withdrawal from enrollment, UW-Platteville incorrectly returned $1,226. Because UW-Platteville used the same calculation for all determinations for the fall 2023 term, there may be further errors in the federal financial assistance amounts UW-Platteville determined.
Context:
UW-Platteville uses a student information system to track activity for students who withdraw from enrollment in order to determine the federal financial assistance each student earned and the amount that must be returned to the U.S. Department of Education. We discussed with UW-Platteville staff the process used for identifying students who never attended or withdrew from enrollment. We also requested information from UW-Platteville to identify students who did not begin attendance or withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 5 students who had received federal financial assistance and who withdrew from UW-Platteville to determine the amount of federal financial assistance those students earned and the related amounts UW-Platteville returned to the U.S. Department of Education.
Questioned Costs:
$24, Plus an Undetermined Amount
Effect:
UW-Platteville did not comply with all requirements to return federal financial assistance for students who never attended or withdrew from enrollment during FY 2023-24.
Cause:
UW-Platteville did not have adequate procedures to review and apply accurate calculations for the two students for whom we identified errors in the determination of the amount of federal financial assistance to return to the federal government. After we identified the error for the student who attended only one day, UW-Platteville returned the additional $24 to the federal government in November 2024. For the fall 2023 term, UW-Platteville changed its fall break from four to five days, which required a change in the number of academic days used in the calculation of federal financial assistance earned when a student withdraws from enrollment. UW-Platteville did not have a process to review the academic calendar for purposes of its return procedures.
Recommendation:
We recommend the University of Wisconsin-Platteville review, update, and implement its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government for students who never attended or withdrew from enrollment, including annually reviewing the academic days used in its determinations.
Finding 2024-706: Student Financial Assistance Cluster—UW-Platteville Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $24, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Platteville: The University of Wisconsin-Platteville agrees with the audit finding and recommendation.
Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Background:
UW-Whitewater receives funding from the U.S. Department of Education for several grant and loan programs administered under the SFA Cluster. During FY 2023-24, UW-Whitewater reported a total of $58.4 million in federal financial assistance under the SFA Cluster. UW-Whitewater is required to comply with U.S. Department of Education requirements for disbursing funds to students and monitoring that students attend courses after receiving the federal financial assistance.
Criteria:
When a student withdraws from enrollment, 34 CFR s. 668.22 requires that UW-Whitewater must determine the amount of federal financial assistance that the student earned and return to the federal government the amount that the student did not earn. Under Volume 5, Chapter 2 of the Federal Student Aid Handbook, the entire amount of disbursements of federal financial assistance after a student’s date of withdrawal from enrollment without notification to UW-Whitewater is required to be returned to the U.S. Department of Education unless certain conditions are met.
Condition:
UW-Whitewater inaccurately determined the amount of federal financial assistance to return to the U.S. Department of Education for one of seven students we reviewed who withdrew from enrollment during FY 2023 24. UW-Whitewater incorrectly accounted for a disbursement to the student that occurred after the date for which UW-Whitewater later identified the student had withdrawn from enrollment as an amount that was earned by the student. As a result, UW-Whitewater failed to return $400 in federal financial assistance to the U.S. Department of Education for the spring 2024 term.
Context:
In order to determine the federal financial assistance a student earned and the amount that must be returned to the U.S. Department of Education for amounts a student did not earn, UW-Whitewater uses a student information system to track activity for students who withdraw. We discussed with UW-Whitewater staff the process used for identifying students who withdrew from enrollment. We also requested information from UW-Whitewater to identify students who withdrew from enrollment during FY 2023-24. As part of a UW systemwide sample of 60 students, we selected 7 students who had received federal financial assistance and who withdrew from UW-Whitewater to determine the amount of federal financial assistance those students earned and the related amounts UW-Whitewater returned to the U.S. Department of Education.
Questioned Costs:
$400, Plus an Undetermined Amount
Effect:
UW-Whitewater did not comply with all requirements to return federal financial assistance for students who withdrew from enrollment during FY 2023-24.
Cause:
UW-Whitewater did not have adequate procedures to review and ensure its determination of the amount of federal assistance to return was accurate. Although UW-Whitewater disbursed federal financial assistance later than is typical to the student, the disbursement was not correctly categorized within the calculations completed by UW-Whitewater nor was the categorization error detected by other
UW-Whitewater procedures.
Recommendation:
We recommend the University of Wisconsin-Whitewater:
-update its procedures to improve the accuracy in making determinations of federal financial assistance that needs to be returned to the federal government and returning federal financial assistance in a timely manner to the federal government; and
-promptly return the additional amount of federal financial assistance for the student we identified.
Finding 2024-707: Student Financial Assistance Cluster—UW-Whitewater Return of Funds Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: $400, Plus an Undetermined Amount
Type of Finding: Noncompliance
Response from the University of Wisconsin-Whitewater: The University of Wisconsin-Whitewater agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Background:
UW-Madison receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Madison reported a total of $228.8 million in federal financial assistance under the SFA Cluster. UW-Madison records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Madison is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to the National Student Loan Data System (NSLDS). Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Madison is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time;
-report the same effective date for a student who withdraws from enrollment as the date used in its determination of whether any federal financial assistance must be returned in accordance with
34 CFR s. 668.22;
-report a student who has completed a program with a status of “graduated” rather than “withdrawn”;
-maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed; and
-maintain the program begin date, which is the date the student first began attending the program being reported, if a student’s program of study has not changed.
Condition:
UW-Madison uses the National Student Clearinghouse (NSC) to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Madison that identify potential errors in UW-Madison’s reporting of student activities. It is the responsibility of UW-Madison to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Madison did not report to NSLDS accurate information for 12 of the 17 students we reviewed. First, UW-Madison did not accurately report a student who withdrew from enrollment without notification in a timely manner. Second, UW-Madison incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment. Third, UW-Madison incorrectly reported the program-level enrollment status effective date for two students. Fourth, UW-Madison incorrectly reported the program begin date for six students. In addition, UW Madison incorrectly reported both the program-level enrollment status effective date and program begin date for two students.
Context:
We discussed with UW-Madison staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Madison relies on data from its student information system to compile information to transmit to NSC. UW-Madison also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student that withdrew from UW-Madison and six students who graduated from UW-Madison. In addition, we selected ten additional UW-Madison students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Madison did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Madison did not report to NSLDS who had withdrawn from enrollment without notification, we found UW-Madison’s enrollment reporting procedures did not assign responsibility for communicating certain information to those staff in the registrar’s office who are responsible for NSLDS reporting. As a result, those students the financial aid office determined had withdrawn from enrollment without notification, and for which it had completed a determination of federal financial assistance the students did not earn, were not known to staff in the registrar’s office for purposes of NSLDS reporting. In addition, UW-Madison indicated that withdrawals from enrollment without notification are identified after the term ends and its student information system did not have a dedicated effective date field in order to automatically identify such student records for the required NSLDS reporting.
Second, for the student UW-Madison did not accurately report as graduated within NSLDS, we found UW‑Madison relied on a NSC process that is intended to simultaneously update a student’s enrollment status in NSLDS when UW-Madison separately updates a student’s degree as completed. UW-Madison did not complete a separate report to ensure the enrollment status for graduated students was accurately reflected in NSLDS. However, in 2022 NSC had published information that indicated reliance solely on NSC’s process may result in the incorrect status being reported under certain circumstances. Although NSC error reports identified that such errors were present, UW-Madison indicated that it did not review these errors until fall 2024 when it began implementing new U.S. Department of Education reporting requirements.
At that time, UW-Madison stated that it identified that it did not consistently and accurately report in NSLDS those students who had graduated. UW-Madison stated that it then began to work with NSC to identify the extent of the reporting inaccuracies.
Third, in 2021 NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW-Madison’s data from its student information system and had communicated error or warning codes to UW-Madison in these areas. However, UW-Madison did not sufficiently review whether the records identified by NSC as potential errors resulted in inaccurate reporting. For example, NSC used warning codes for potential errors in the program-level enrollment status effective dates. As warning codes do not prohibit submission of reporting, UW-Madison did not review the warnings.
Fourth, in 2021 NSC similarly published information on accurately reporting student program begin dates in NSLDS and NSC had also identified instances of potential inaccurate reporting in UW Madison’s data from its student information system. Although NSC had communicated error or warning codes to UW-Madison in these areas, UW-Madison had not sufficiently reviewed whether the records identified by NSC as potential errors resulted in inaccurate reporting until 2023. At that time, UW-Madison indicated that, after reviewing other NSC warnings, it identified that it did not accurately report program begin dates for students. UW-Madison indicated it then began to work to update its student information system data extraction process to identify the correct program begin date for its submissions to NSC. However, it did not implement these changes until after the audit period.
In addition, UW-Madison indicated that it had turnover in staff responsible for NSLDS reporting in 2021, which may have caused UW-Madison to have missed the NSC publications regarding reporting graduated students accurately, new warning codes, and the importance of reviewing certain warning codes to accurately complete NSLDS reporting.
Recommendation:
We recommend the University of Wisconsin-Madison:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as updating its student information system to allow for an automated identification process to communicate those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated and implement separate reporting to the National Student Clearinghouse to accurately report students who graduate;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program-level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program begin dates and update its student information system extraction process to accurately report program begin dates; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-708: Student Financial Assistance Cluster—UW-Madison Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Madison: The University of Wisconsin-Madison agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Background:
UW-Milwaukee receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Milwaukee reported a total of $133.1 million in federal financial assistance under the SFA Cluster. UW-Milwaukee records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Milwaukee is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Milwaukee is required to maintain the program-level enrollment status effective date, which is the date that the current enrollment status reported was first effective, if a student’s status has not changed.
Condition:
UW-Milwaukee uses NSC to facilitate the enrollment reporting to NSLDS. NSC provides error reports to UW-Milwaukee that identify potential errors in UW-Milwaukee’s reporting of student activities through NSC. These errors are the responsibility of UW-Milwaukee to resolve to ensure its submissions to NSLDS are accurate and complete.
UW-Milwaukee did not report to NSLDS accurate information for the program level enrollment status effective date for five students we reviewed. In addition, based on how information from its student information system is extracted for student reporting to NSLDS, we found that the reporting inaccuracy extended to other UW-Milwaukee students.
Context:
We discussed with UW-Milwaukee staff its procedures for identifying student enrollment status changes that should be reported to the U.S. Department of Education through NSLDS and its procedures for monitoring the reporting performed by NSC. UW-Milwaukee relies on data from its student information system to compile information to transmit to NSC. UW-Milwaukee also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve.
To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023-24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included two students who withdrew from UW-Milwaukee and four students who graduated from UW- Milwaukee. In addition, we selected ten additional UW-Milwaukee students who had other changes that were required to be reported to NSLDS.
Questioned Costs:
None.
Effect:
UW-Milwaukee did not comply with requirements to accurately report certain student enrollment status changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
In 2021, NSC published information on accurately reporting student program-level enrollment status effective dates in NSLDS. NSC also had identified instances of potentially inaccurate reporting in UW- Milwaukee’s data from its student information system and had communicated error or warning codes to UW-Milwaukee in these areas. UW-Milwaukee staff indicated that they were aware that NSC error reports included warnings to identify potential inaccurate reporting of program level enrollment status effective dates and that the errors were a known issue for Peoplesoft-based student information systems. However, UW-Milwaukee chose not to use an all-record update feature that was available to correct the program-level enrollment status effective dates for all student records simultaneously due to the risk that other reporting inaccuracies could result from the action. Further, UW-Milwaukee staff indicated that they were not aware that specific guidance on the program-level enrollment status effective date had been updated to reflect that corrections should be made to fully comply with NSLDS reporting requirements.
Recommendation:
We recommend the University of Wisconsin-Milwaukee:
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate program level enrollment status effective dates and update its student information system extraction process to accurately report program-level enrollment status effective dates; and
-report changes in student enrollment accurately, completely, and in a timely manner for all student changes that require reporting.
Finding 2024-709: Student Financial Assistance Cluster—UW-Milwaukee Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Milwaukee: The University of Wisconsin-Milwaukee agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Background:
UW-Oshkosh receives funding from the U.S. Department of Education for several grant and loan programs that are administered under the SFA Cluster. For FY 2023-24, UW-Oshkosh reported a total of $45.3 million in federal financial assistance under the SFA Cluster. UW-Oshkosh records student enrollment information in a student information system and uses this data to comply with U.S. Department of Education requirements for reporting changes in student enrollment, such as withdrawals from enrollment, graduation, or address changes.
Criteria:
UW-Oshkosh is required to report changes in student enrollment and certain other changes to the U.S. Department of Education within specified timelines under 34 CFR s. 685.309 (b) for the Direct Student Loans program and under 34 CFR s. 690.83 (b) (2) for the Pell Grants program. The U.S. Department of Education requires that student enrollment status changes be reported to NSLDS. Specific guidance is also provided by the U.S. Department of Education in the NSLDS Enrollment Reporting Guide. Under this guidance, UW-Oshkosh is required to:
-certify enrollment at least every 60 days and report certain changes within 30 days, including a student’s withdrawal from enrollment, with or without notification, or a student’s enrollment that reduces to less than half-time; and
-report a student who has completed a program with a status of “graduated” rather than “withdrawn.”
Condition:
UW-Oshkosh uses NSC to facilitate the enrollment reporting in NSLDS. NSC provides error reports to UW-Oshkosh that identify potential errors in UW Oshkosh’s reporting of student activities. It is the responsibility of UW-Oshkosh to resolve potential errors to ensure its submissions to NSLDS are accurate and complete. UW-Oshkosh did not report to NSLDS accurate information for two of the three students we reviewed.
First, UW-Oshkosh did not report in a timely manner one student who withdrew from enrollment without notification. Second, UW-Oshkosh incorrectly reported the status of a student who graduated as though the student had withdrawn from enrollment.
Context:
We discussed with UW-Oshkosh staff its procedures for identifying student enrollment changes that should be reported to the U.S. Department of Education through NSLDS and UW Oshkosh’s procedures for monitoring the reporting performed by NSC. UW-Oshkosh relies on data from its student information system to compile information to transmit to NSC. UW-Oshkosh also receives submission reporting from NSC to identify errors or warnings of potential errors, which it indicated it reviews and takes steps to resolve. To review compliance with U.S. Department of Education enrollment reporting to NSLDS, we selected a UW systemwide sample of 40 students who had changes in enrollment status during FY 2023 24. This sample included 15 students who withdrew from enrollment and 25 students who graduated. The sample included one student who withdrew from UW-Oshkosh and two students who graduated from UW‑Oshkosh.
Questioned Costs:
None.
Effect:
UW-Oshkosh did not comply with requirements to accurately report certain student enrollment changes to the U.S. Department of Education in a timely manner. As a result, inaccurate or incomplete information was reported to the U.S. Department of Education, which then relied on this information, in part, to establish loan repayment provisions and to accomplish other purposes.
Cause:
First, for the student UW-Oshkosh did not report to NSLDS in a timely manner who had withdrawn from enrollment without notification, we found that UW-Oshkosh indicated that it believed it needed to report to NSLDS only when students withdrew from enrollment and had notified UW-Oshkosh of the withdrawal. As a result, students detected by UW Oshkosh through procedures completed by the financial aid office at the end of each term were not communicated to those staff in the registrar’s office who were responsible for NSLDS reporting.
Second, for the student UW-Oshkosh did not accurately report as graduated within NSLDS, we found that inaccuracies in the reporting of students who had graduated were noted on NSC error reports. However, UW-Oshkosh’s registrar’s office staff did sufficiently review the errors to correct the status in NSLDS.
Recommendation:
We recommend the University of Wisconsin-Oshkosh:
-update its procedures to ensure that when a student withdraws from enrollment without notification that the student’s status is identified for reporting in the National Student Loan Data System, such as communicating those student withdrawals to the registrar’s office;
-update its procedures to review and resolve all error and warning reports received from the National Student Clearinghouse for potentially inaccurate reporting of students who graduated; and
-report all changes in student enrollment accurately, completely, and in a timely manner for all those that require reporting.
Finding 2024-710: Student Financial Assistance Cluster—UW-Oshkosh Enrollment Reporting Special Tests
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the University of Wisconsin-Oshkosh: The University of Wisconsin-Oshkosh agrees with the audit finding and recommendations.
Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Background:
UW Parkside operates in a highly computerized environment and is responsible for maintaining confidential and sensitive information, such as student data. UW Parkside maintains its own student information system to administer federal student financial assistance programs under the SFA Cluster.
Criteria:
To ensure data processed and stored by UW-Parkside is protected from accidental or intentional misuse or destruction, and to provide proper internal control, information technology (IT) security policies and procedures are necessary. In addition, IT controls should be established to prevent inappropriate or inadvertent access to data. UW-Parkside is responsible for following specific requirements under the Gramm-Leach-Bliley Act (GLBA), which requires entities that administer student financial assistance programs to develop, implement, and maintain safeguards to protect the security, integrity, and confidentiality of student data.
Under GLBA, UW-Parkside is required to authenticate and permit access only to authorized users. Further, UW Board of Regents Policy 25-5 requires that UW-Parkside follow the National Institute of Standards and Technology (NIST) in establishing IT controls. NIST Special Publication (SP) 800-53, Security and Privacy Controls for Information Systems and Organizations, recommends best practices in IT controls related to user access. These best practices include developing a provisioning and deprovisioning process focused on limiting access in a manner that provides the least access based on business need; retaining documentation of provisioning and deprovisioning activities, including records of when such access was added or removed; and performing periodic reviews of access to ensure it remains appropriate.
Condition:
We found UW-Parkside did not have adequate IT controls in place during FY 2023-24 to provision, deprovision, and manage access to its student information system. First, UW-Parkside did not have a formal documented process to provision or deprovision user access to its student information system. Second, UW-Parkside did not maintain a list of provisioned users with access and was unable to generate a report of users provisioned or deprovisioned during FY 2023-24. Third, UW-Parkside did not complete a periodic review of access, which assists in ensuring its provisioning and deprovisioning processes are working as intended. Although failure in any one IT control may be detected by complementary IT controls, UW‑Parkside did not have effective IT controls in any of the three areas. As a result, UW-Parkside was at a higher risk of granting unauthorized access to its student information system.
Context:
We reviewed GLBA requirements, UW System Board of Regents policies, and NIST 800-53 guidance to identify policies and procedures for UW-Parkside’s monitoring of access granted to its student information system. We requested documentation from UW-Parkside to assess compliance with these policies.
Questioned Costs:
None.
Effect:
Ineffective general IT controls may permit controls over systems to operate improperly and may allow noncompliance to occur and not be detected. Weaknesses in IT security policies, procedures, and controls increase the risk that unauthorized or erroneous transactions could be processed or changes made to student data. In addition, failure to provide an appropriate level of protection for its student information system and data increased the risk that personally identifiable information could be accidentally or maliciously exposed.
Cause:
UW-Parkside did not have a formal policy or procedures in place to provision, deprovision, and review access to its student information system. UW-Parkside staff indicated the process for provisioning and deprovisioning access had been informally operated, such as through electronic mail and direct communication and it did not consistently retain documentation of these communications. For example,
UW-Parkside indicated access requests were accepted from a variety of UW-Parkside employees. As a result, UW-Parkside had not assessed whether a user’s access was necessary or otherwise limited the access only to specific information needed or to a specified time period. Finally, UW-Parkside also indicated that prior efforts to improve its provisioning and deprovisioning of user access were not fully completed or implemented, in part, due to staff turnover.
Recommendation:
We recommend the University of Wisconsin-Parkside:
-develop and implement written procedures for provisioning and deprovisioning user access to its student information system, including specifying those who are authorized to request user access and assigning responsibility to staff to assess access requests to restrict the access only to data needed for a specified period of time;
-retain consistent documentation of its provisioning and deprovisioning activities;
-develop and implement written procedures for a review at least annually of access granted to its student information system; and
-complete an assessment of users who currently have access to its student information system and remove those users who no longer require the access.
Finding 2024-711: Student Financial Assistance Cluster—UW-Parkside Information Technology Controls
Student Financial Assistance Cluster (various Assistance Listing numbers)
Award Numbers Award Years
Various Various
Questioned Costs: None
Type of Finding: Significant Deficiency
Response from the University of Wisconsin-Parkside: The University of Wisconsin-Parkside agrees with the audit finding and recommendations.