Audit 350900

Finding #2023-001 Grantor: U.S. Department of Education Federal Program Name: Federal Pell Grant Program Assistance Listing Number: 84.063 Criteria and Condition Returns of Title IV funds are required to be deposited or transferred into the Student Financial Assistance (SFA) account or electronic fund transfers initiated to Secretary of Education (ED) as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. This is the criteria for students who have begun attendance who have been awarded Title IV funds. Context During our testing of the controls over the timeliness of the institution’s return of unobligated Title IV Funds, it was noted that for 1 of the 2 students selected for testing during the year ended June 30, 2023, the returned Pell funds were returned to the ED 57 days after their withdrawal date. The correct amount of funds were returned and this student’s other Title IV funds were returned timely. Cause Programs are reconciled on a monthly basis. During the month of March 2023, there was not enough Pell funds available to draw down, so a batch of 31 students for a net total of $33,932 which included the refund selected for $401, was held for draw downs and returns until the next month when more Pell funds were available, which surpassed the 45 day threshold. There was also turnover in financial aid positions at the institution during the 2022-2023 academic year. Potential Effect Failure to properly administer and return funds exposes the institution to the risk of regulatory sanctions, which could include the reduction of program funding, program suspension or debarment. Questioned Costs None Recommendation It is recommended that the institution implement a process whereby management reviews federal awards on a monthly basis to identify and return unobligated funds in a timely manner. This review should be formally documented and formally approved by the appropriate level of management. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and the reader’s attention is directed to the corrective action plan.

Finding #2023-002 Grantor: U.S. Department of Homeland Security Federal Program Name: Pass-through from the State of Connecticut Department For Emergency Services & Public Protection; FEMA - COVID Testing reimbursement Assistance Listing Number: 97.036 Criteria and Condition Under the Stafford Act, the Federal Emergency Management Agency (FEMA) cannot duplicate funding for any cost for which there is another funding source. Other funding sources may include Medicare/Medicaid, patient health insurance, or direct payment for services. Context In response to an inquiry on behalf of FEMA Region 1 Sustained Operations Unit, the University was asked to confirm whether it collected patient care revenue for medical care expenses submitted to FEMA for reimbursement. During the post obligation reconciliation review of emergency protective measures costs, the University determined that one of the invoices for COVID testing supplies submitted with the FEMA project worksheet was also charged to patients as a direct payment for services. The University formally amended the FEMA project and reduced the cost of materials for this invoice. Cause During the closure of the region’s COVID-19 Public Assistance grant program, FEMA requested additional financial data to complete the Patient Care Revenue Duplication of Benefits (DOB) review. After a comprehensive review of program expenses, the University identified an invoice that was charged to patients as direct payment for services and submitted for FEMA reimbursement. Potential Effect Failure to properly evaluate allowable costs exposes the institution to the risk of regulatory sanctions, which could include the reduction of program funding, program suspension as well as the return of the unallowable costs. Questioned Costs The total cost of the invoice submitted to FEMA in error was $1,093,848. The amount of the invoice was subsequently returned to the state of Connecticut after the project worksheet was formally amended. Recommendation It is recommended that the University implement a process whereby management reviews federal award project worksheets prior to final submission to FEMA in order to identify any disallowed costs in a timely manner. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and the reader’s attention is directed to the corrective action plan.

Finding #2023-001 Grantor: U.S. Department of Education Federal Program Name: Federal Pell Grant Program Assistance Listing Number: 84.063 Criteria and Condition Returns of Title IV funds are required to be deposited or transferred into the Student Financial Assistance (SFA) account or electronic fund transfers initiated to Secretary of Education (ED) as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. This is the criteria for students who have begun attendance who have been awarded Title IV funds. Context During our testing of the controls over the timeliness of the institution’s return of unobligated Title IV Funds, it was noted that for 1 of the 2 students selected for testing during the year ended June 30, 2023, the returned Pell funds were returned to the ED 57 days after their withdrawal date. The correct amount of funds were returned and this student’s other Title IV funds were returned timely. Cause Programs are reconciled on a monthly basis. During the month of March 2023, there was not enough Pell funds available to draw down, so a batch of 31 students for a net total of $33,932 which included the refund selected for $401, was held for draw downs and returns until the next month when more Pell funds were available, which surpassed the 45 day threshold. There was also turnover in financial aid positions at the institution during the 2022-2023 academic year. Potential Effect Failure to properly administer and return funds exposes the institution to the risk of regulatory sanctions, which could include the reduction of program funding, program suspension or debarment. Questioned Costs None Recommendation It is recommended that the institution implement a process whereby management reviews federal awards on a monthly basis to identify and return unobligated funds in a timely manner. This review should be formally documented and formally approved by the appropriate level of management. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and the reader’s attention is directed to the corrective action plan.

Finding #2023-002 Grantor: U.S. Department of Homeland Security Federal Program Name: Pass-through from the State of Connecticut Department For Emergency Services & Public Protection; FEMA - COVID Testing reimbursement Assistance Listing Number: 97.036 Criteria and Condition Under the Stafford Act, the Federal Emergency Management Agency (FEMA) cannot duplicate funding for any cost for which there is another funding source. Other funding sources may include Medicare/Medicaid, patient health insurance, or direct payment for services. Context In response to an inquiry on behalf of FEMA Region 1 Sustained Operations Unit, the University was asked to confirm whether it collected patient care revenue for medical care expenses submitted to FEMA for reimbursement. During the post obligation reconciliation review of emergency protective measures costs, the University determined that one of the invoices for COVID testing supplies submitted with the FEMA project worksheet was also charged to patients as a direct payment for services. The University formally amended the FEMA project and reduced the cost of materials for this invoice. Cause During the closure of the region’s COVID-19 Public Assistance grant program, FEMA requested additional financial data to complete the Patient Care Revenue Duplication of Benefits (DOB) review. After a comprehensive review of program expenses, the University identified an invoice that was charged to patients as direct payment for services and submitted for FEMA reimbursement. Potential Effect Failure to properly evaluate allowable costs exposes the institution to the risk of regulatory sanctions, which could include the reduction of program funding, program suspension as well as the return of the unallowable costs. Questioned Costs The total cost of the invoice submitted to FEMA in error was $1,093,848. The amount of the invoice was subsequently returned to the state of Connecticut after the project worksheet was formally amended. Recommendation It is recommended that the University implement a process whereby management reviews federal award project worksheets prior to final submission to FEMA in order to identify any disallowed costs in a timely manner. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and the reader’s attention is directed to the corrective action plan.