Audit 351604

Finding 2024-005 – Special Tests – Enrollment Reporting — Material Weakness Department of Education Student Financial Assistance Cluster Assistance Listing No. 84.268 (Federal Direct Student Loans), 84.063 (Federal Pell Grant Program) Federal award year 2023-2024 Criteria: Under the Direct Loan programs, institutions are required to report student enrollment data via the National Student Loan Data System (NSLDS) using the Enrollment Reporting Roster file or Enrollment Maintenance page at least every 60 days. The reporting includes verification of enrollment data and communication of changes in student enrollment status within 60 days. Institutions are responsible for timely and accurate reporting, whether they report directly to the National Student Loan Data System (NSLDS) or through a third-party servicer. Condition: Student status changes were not reported accurately to NSLDS. Cause: The audit team noted that the University does not appear to have a control in place to identify in a timely manner inaccurate information that was provided to the NSLDS by their third party servicer. Effect or potential effect: The effect of the noncompliance is that NSLDS does not have timely and accurate enrollment. As noted in the Compliance Supplement, "The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions" which is not possible when the University does not provide accurate information. Questioned costs: None Context: We selected 40 students to evaluate reporting of status changes to NSLDS. Out of 40 students selected, 21 students who had graduated were reported to NSLDS as withdrawn, and two students, one who had graduated and one who had withdrawn, had no record reported to NSLDS. Identification as a repeat finding, if applicable: Not applicable. Recommendation: RSM recommends that the University implement a process to review information provided to NSLDS for accuracy in a timely manner such that the NSLDS receives accurate information within 60 days of status changes. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-005 – Special Tests – Enrollment Reporting — Material Weakness Department of Education Student Financial Assistance Cluster Assistance Listing No. 84.268 (Federal Direct Student Loans), 84.063 (Federal Pell Grant Program) Federal award year 2023-2024 Criteria: Under the Direct Loan programs, institutions are required to report student enrollment data via the National Student Loan Data System (NSLDS) using the Enrollment Reporting Roster file or Enrollment Maintenance page at least every 60 days. The reporting includes verification of enrollment data and communication of changes in student enrollment status within 60 days. Institutions are responsible for timely and accurate reporting, whether they report directly to the National Student Loan Data System (NSLDS) or through a third-party servicer. Condition: Student status changes were not reported accurately to NSLDS. Cause: The audit team noted that the University does not appear to have a control in place to identify in a timely manner inaccurate information that was provided to the NSLDS by their third party servicer. Effect or potential effect: The effect of the noncompliance is that NSLDS does not have timely and accurate enrollment. As noted in the Compliance Supplement, "The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions" which is not possible when the University does not provide accurate information. Questioned costs: None Context: We selected 40 students to evaluate reporting of status changes to NSLDS. Out of 40 students selected, 21 students who had graduated were reported to NSLDS as withdrawn, and two students, one who had graduated and one who had withdrawn, had no record reported to NSLDS. Identification as a repeat finding, if applicable: Not applicable. Recommendation: RSM recommends that the University implement a process to review information provided to NSLDS for accuracy in a timely manner such that the NSLDS receives accurate information within 60 days of status changes. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-005 – Special Tests – Enrollment Reporting — Material Weakness Department of Education Student Financial Assistance Cluster Assistance Listing No. 84.268 (Federal Direct Student Loans), 84.063 (Federal Pell Grant Program) Federal award year 2023-2024 Criteria: Under the Direct Loan programs, institutions are required to report student enrollment data via the National Student Loan Data System (NSLDS) using the Enrollment Reporting Roster file or Enrollment Maintenance page at least every 60 days. The reporting includes verification of enrollment data and communication of changes in student enrollment status within 60 days. Institutions are responsible for timely and accurate reporting, whether they report directly to the National Student Loan Data System (NSLDS) or through a third-party servicer. Condition: Student status changes were not reported accurately to NSLDS. Cause: The audit team noted that the University does not appear to have a control in place to identify in a timely manner inaccurate information that was provided to the NSLDS by their third party servicer. Effect or potential effect: The effect of the noncompliance is that NSLDS does not have timely and accurate enrollment. As noted in the Compliance Supplement, "The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions" which is not possible when the University does not provide accurate information. Questioned costs: None Context: We selected 40 students to evaluate reporting of status changes to NSLDS. Out of 40 students selected, 21 students who had graduated were reported to NSLDS as withdrawn, and two students, one who had graduated and one who had withdrawn, had no record reported to NSLDS. Identification as a repeat finding, if applicable: Not applicable. Recommendation: RSM recommends that the University implement a process to review information provided to NSLDS for accuracy in a timely manner such that the NSLDS receives accurate information within 60 days of status changes. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-005 – Special Tests – Enrollment Reporting — Material Weakness Department of Education Student Financial Assistance Cluster Assistance Listing No. 84.268 (Federal Direct Student Loans), 84.063 (Federal Pell Grant Program) Federal award year 2023-2024 Criteria: Under the Direct Loan programs, institutions are required to report student enrollment data via the National Student Loan Data System (NSLDS) using the Enrollment Reporting Roster file or Enrollment Maintenance page at least every 60 days. The reporting includes verification of enrollment data and communication of changes in student enrollment status within 60 days. Institutions are responsible for timely and accurate reporting, whether they report directly to the National Student Loan Data System (NSLDS) or through a third-party servicer. Condition: Student status changes were not reported accurately to NSLDS. Cause: The audit team noted that the University does not appear to have a control in place to identify in a timely manner inaccurate information that was provided to the NSLDS by their third party servicer. Effect or potential effect: The effect of the noncompliance is that NSLDS does not have timely and accurate enrollment. As noted in the Compliance Supplement, "The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions" which is not possible when the University does not provide accurate information. Questioned costs: None Context: We selected 40 students to evaluate reporting of status changes to NSLDS. Out of 40 students selected, 21 students who had graduated were reported to NSLDS as withdrawn, and two students, one who had graduated and one who had withdrawn, had no record reported to NSLDS. Identification as a repeat finding, if applicable: Not applicable. Recommendation: RSM recommends that the University implement a process to review information provided to NSLDS for accuracy in a timely manner such that the NSLDS receives accurate information within 60 days of status changes. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-005 – Special Tests – Enrollment Reporting — Material Weakness Department of Education Student Financial Assistance Cluster Assistance Listing No. 84.268 (Federal Direct Student Loans), 84.063 (Federal Pell Grant Program) Federal award year 2023-2024 Criteria: Under the Direct Loan programs, institutions are required to report student enrollment data via the National Student Loan Data System (NSLDS) using the Enrollment Reporting Roster file or Enrollment Maintenance page at least every 60 days. The reporting includes verification of enrollment data and communication of changes in student enrollment status within 60 days. Institutions are responsible for timely and accurate reporting, whether they report directly to the National Student Loan Data System (NSLDS) or through a third-party servicer. Condition: Student status changes were not reported accurately to NSLDS. Cause: The audit team noted that the University does not appear to have a control in place to identify in a timely manner inaccurate information that was provided to the NSLDS by their third party servicer. Effect or potential effect: The effect of the noncompliance is that NSLDS does not have timely and accurate enrollment. As noted in the Compliance Supplement, "The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions" which is not possible when the University does not provide accurate information. Questioned costs: None Context: We selected 40 students to evaluate reporting of status changes to NSLDS. Out of 40 students selected, 21 students who had graduated were reported to NSLDS as withdrawn, and two students, one who had graduated and one who had withdrawn, had no record reported to NSLDS. Identification as a repeat finding, if applicable: Not applicable. Recommendation: RSM recommends that the University implement a process to review information provided to NSLDS for accuracy in a timely manner such that the NSLDS receives accurate information within 60 days of status changes. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-001 – Equipment and Real Property Management — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Also, in accordance with 2 CFR 200.313(d)(1), property records must be maintained that included a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. In accordance with 2 CFR 200.313(d)(2), a physical inventory of equipment and property must be taken, and the results reconciled with property records at least once every two years. Condition: The University’s controls were not operating effectively to reasonably ensure the University maintained property records with the above required information and performed the required physical inventory of equipment within the two previous years. As a result, the University did not comply with the compliance requirements for equipment and real property management. Cause: The University does not have processes and procedures in place related to equipment management, tracking and required physical inventories. Effect or potential effect: The University is not in compliance with federal grant requirements over the tracking and physical inventory of equipment. Improper equipment management procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: The University has five pieces of qualified equipment with an aggregate cost of approximately $119,000. For all sample selections tested in the major program, there was no process of tagging and tracking equipment purchased with federal funding, nor was there any evidence that physical inventories had been performed. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to tag and track the equipment purchased with federal funding, and maintain support that physical inventories were performed as required. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-002 – Procurement and Suspension and Debarment — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement methods outline by the University are properly followed. In accordance with 2 CFR 200.320, price quotations should be obtained from an adequate number of qualified sources for procurements that meet the small purchase procurement threshold. Condition: The University’s controls were not operating effectively to reasonably ensure the University obtained the proper number of price quotations as required using the small purchase procurement method. The University’s procurement policy requires price quotations be obtained from at least two sources when using the small purchase procurement method. The University only obtained one price quotation and no written documentation as the rational for selection was maintained. As a result, the University did not comply with the compliance requirements for procurement. Cause: The University does not have processes and procedures in place to ensure all procurements of goods and services are in accordance with Uniform Guidance and in accordance with it’s own procurement policy. Effect or potential effect: The University is not in compliance with federal grant requirements over small purchase procurements. Improper procurement procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: For all sample selections tested in the major program, one price quotation was obtained and no documentation was maintained as to the rationale for selection of the underlying vendor. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to obtain the required number of price quotations required under the small purchase procurement method, and maintain support for the required number of price quotations received under the small purchase procurement method. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-003 – Procurement and Suspension and Debarment — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure vendors are not suspended or debarred. In accordance with 2 CFR 200.212 and 200.318(h)), when a nonfederal entity enters into a contract or purchase with an entity (vendor or subrecipient), the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants when expending $25,000 or more in a year (or any amount in the case of a subrecipient). Condition: The University’s controls were not operating effectively to reasonably ensure the University verified the vendor was not suspended or debarred from participation in federal programs/grants prior to entering into a contract with the vendor. The University’s procurement policy requires vendor transactions equal to or greater than $25,000 undergo verification to ensure the vendor is not suspended or debarred, prior to entering into a contract with the vendor. Cause: A lack of controls to reasonably ensure this verification was performed. Effect or potential effect: The University did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Questioned costs: $0 Context: For all sample selections tested in the major program, documentation was not maintained that could provide evidence that the University had performed the required verification. None of the samples tested were identified as suspended or debarred entities. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop proper controls and procedures to determine whether vendors have been suspended or debarred prior to entering into contracts or purchase orders for all transactions, and maintain documentation supporting this verification. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-004 – Subrecipient Monitoring — Material Weakness Department of Health and Human Services Research and Development Cluster National Science Foundation, Assistance Listing No. 47.076 (STEM Education) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that risk assessment and monitoring are formally documented over subrecipient monitoring. In accordance with 2 CFR 200.332(b) and 2 CFR 200.332(e), a pass-through entity is required to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of each sub-award for purposes of determining appropriate subrecipient monitoring requirements. Depending on the risk assessment, the pass-through entity should identify monitoring procedures to be performed in order to ensure proper accountability and compliance with program requirements and achievements of performance goals. Condition: The University’s controls were not operating effectively to reasonably ensure the University performed risk assessment and monitoring procedures for its subrecipients. As a result, the University did not comply with the compliance requirements for subrecipient monitoring. Cause: The University does not have processes and procedures in place related to risk assessment and subrecipient monitoring. Effect or potential effect: The University is not in compliance with federal grant requirements over subrecipient monitoring. Lack of properly documented evidence of subrecipient monitoring policies and procedures performed, including required risk assessments, could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: The University has two active awards under the program with subrecipients with an aggregate award value of approximately $71,000. The University has two subrecipients and for both subrecipients tested in the major program, there was no evidence that a risk assessment or monitoring of those subrecipients was performed. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to perform the required risk assessments and related monitoring, and maintain support that the risk assessments and related monitoring were performed as required. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-001 – Equipment and Real Property Management — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Also, in accordance with 2 CFR 200.313(d)(1), property records must be maintained that included a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. In accordance with 2 CFR 200.313(d)(2), a physical inventory of equipment and property must be taken, and the results reconciled with property records at least once every two years. Condition: The University’s controls were not operating effectively to reasonably ensure the University maintained property records with the above required information and performed the required physical inventory of equipment within the two previous years. As a result, the University did not comply with the compliance requirements for equipment and real property management. Cause: The University does not have processes and procedures in place related to equipment management, tracking and required physical inventories. Effect or potential effect: The University is not in compliance with federal grant requirements over the tracking and physical inventory of equipment. Improper equipment management procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: The University has five pieces of qualified equipment with an aggregate cost of approximately $119,000. For all sample selections tested in the major program, there was no process of tagging and tracking equipment purchased with federal funding, nor was there any evidence that physical inventories had been performed. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to tag and track the equipment purchased with federal funding, and maintain support that physical inventories were performed as required. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-002 – Procurement and Suspension and Debarment — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement methods outline by the University are properly followed. In accordance with 2 CFR 200.320, price quotations should be obtained from an adequate number of qualified sources for procurements that meet the small purchase procurement threshold. Condition: The University’s controls were not operating effectively to reasonably ensure the University obtained the proper number of price quotations as required using the small purchase procurement method. The University’s procurement policy requires price quotations be obtained from at least two sources when using the small purchase procurement method. The University only obtained one price quotation and no written documentation as the rational for selection was maintained. As a result, the University did not comply with the compliance requirements for procurement. Cause: The University does not have processes and procedures in place to ensure all procurements of goods and services are in accordance with Uniform Guidance and in accordance with it’s own procurement policy. Effect or potential effect: The University is not in compliance with federal grant requirements over small purchase procurements. Improper procurement procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: For all sample selections tested in the major program, one price quotation was obtained and no documentation was maintained as to the rationale for selection of the underlying vendor. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to obtain the required number of price quotations required under the small purchase procurement method, and maintain support for the required number of price quotations received under the small purchase procurement method. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-003 – Procurement and Suspension and Debarment — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure vendors are not suspended or debarred. In accordance with 2 CFR 200.212 and 200.318(h)), when a nonfederal entity enters into a contract or purchase with an entity (vendor or subrecipient), the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants when expending $25,000 or more in a year (or any amount in the case of a subrecipient). Condition: The University’s controls were not operating effectively to reasonably ensure the University verified the vendor was not suspended or debarred from participation in federal programs/grants prior to entering into a contract with the vendor. The University’s procurement policy requires vendor transactions equal to or greater than $25,000 undergo verification to ensure the vendor is not suspended or debarred, prior to entering into a contract with the vendor. Cause: A lack of controls to reasonably ensure this verification was performed. Effect or potential effect: The University did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Questioned costs: $0 Context: For all sample selections tested in the major program, documentation was not maintained that could provide evidence that the University had performed the required verification. None of the samples tested were identified as suspended or debarred entities. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop proper controls and procedures to determine whether vendors have been suspended or debarred prior to entering into contracts or purchase orders for all transactions, and maintain documentation supporting this verification. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-004 – Subrecipient Monitoring — Material Weakness Department of Health and Human Services Research and Development Cluster National Science Foundation, Assistance Listing No. 47.076 (STEM Education) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that risk assessment and monitoring are formally documented over subrecipient monitoring. In accordance with 2 CFR 200.332(b) and 2 CFR 200.332(e), a pass-through entity is required to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of each sub-award for purposes of determining appropriate subrecipient monitoring requirements. Depending on the risk assessment, the pass-through entity should identify monitoring procedures to be performed in order to ensure proper accountability and compliance with program requirements and achievements of performance goals. Condition: The University’s controls were not operating effectively to reasonably ensure the University performed risk assessment and monitoring procedures for its subrecipients. As a result, the University did not comply with the compliance requirements for subrecipient monitoring. Cause: The University does not have processes and procedures in place related to risk assessment and subrecipient monitoring. Effect or potential effect: The University is not in compliance with federal grant requirements over subrecipient monitoring. Lack of properly documented evidence of subrecipient monitoring policies and procedures performed, including required risk assessments, could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: The University has two active awards under the program with subrecipients with an aggregate award value of approximately $71,000. The University has two subrecipients and for both subrecipients tested in the major program, there was no evidence that a risk assessment or monitoring of those subrecipients was performed. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to perform the required risk assessments and related monitoring, and maintain support that the risk assessments and related monitoring were performed as required. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-001 – Equipment and Real Property Management — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Also, in accordance with 2 CFR 200.313(d)(1), property records must be maintained that included a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. In accordance with 2 CFR 200.313(d)(2), a physical inventory of equipment and property must be taken, and the results reconciled with property records at least once every two years. Condition: The University’s controls were not operating effectively to reasonably ensure the University maintained property records with the above required information and performed the required physical inventory of equipment within the two previous years. As a result, the University did not comply with the compliance requirements for equipment and real property management. Cause: The University does not have processes and procedures in place related to equipment management, tracking and required physical inventories. Effect or potential effect: The University is not in compliance with federal grant requirements over the tracking and physical inventory of equipment. Improper equipment management procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: The University has five pieces of qualified equipment with an aggregate cost of approximately $119,000. For all sample selections tested in the major program, there was no process of tagging and tracking equipment purchased with federal funding, nor was there any evidence that physical inventories had been performed. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to tag and track the equipment purchased with federal funding, and maintain support that physical inventories were performed as required. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-002 – Procurement and Suspension and Debarment — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement methods outline by the University are properly followed. In accordance with 2 CFR 200.320, price quotations should be obtained from an adequate number of qualified sources for procurements that meet the small purchase procurement threshold. Condition: The University’s controls were not operating effectively to reasonably ensure the University obtained the proper number of price quotations as required using the small purchase procurement method. The University’s procurement policy requires price quotations be obtained from at least two sources when using the small purchase procurement method. The University only obtained one price quotation and no written documentation as the rational for selection was maintained. As a result, the University did not comply with the compliance requirements for procurement. Cause: The University does not have processes and procedures in place to ensure all procurements of goods and services are in accordance with Uniform Guidance and in accordance with it’s own procurement policy. Effect or potential effect: The University is not in compliance with federal grant requirements over small purchase procurements. Improper procurement procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: For all sample selections tested in the major program, one price quotation was obtained and no documentation was maintained as to the rationale for selection of the underlying vendor. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to obtain the required number of price quotations required under the small purchase procurement method, and maintain support for the required number of price quotations received under the small purchase procurement method. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-003 – Procurement and Suspension and Debarment — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure vendors are not suspended or debarred. In accordance with 2 CFR 200.212 and 200.318(h)), when a nonfederal entity enters into a contract or purchase with an entity (vendor or subrecipient), the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants when expending $25,000 or more in a year (or any amount in the case of a subrecipient). Condition: The University’s controls were not operating effectively to reasonably ensure the University verified the vendor was not suspended or debarred from participation in federal programs/grants prior to entering into a contract with the vendor. The University’s procurement policy requires vendor transactions equal to or greater than $25,000 undergo verification to ensure the vendor is not suspended or debarred, prior to entering into a contract with the vendor. Cause: A lack of controls to reasonably ensure this verification was performed. Effect or potential effect: The University did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Questioned costs: $0 Context: For all sample selections tested in the major program, documentation was not maintained that could provide evidence that the University had performed the required verification. None of the samples tested were identified as suspended or debarred entities. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop proper controls and procedures to determine whether vendors have been suspended or debarred prior to entering into contracts or purchase orders for all transactions, and maintain documentation supporting this verification. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-004 – Subrecipient Monitoring — Material Weakness Department of Health and Human Services Research and Development Cluster National Science Foundation, Assistance Listing No. 47.076 (STEM Education) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that risk assessment and monitoring are formally documented over subrecipient monitoring. In accordance with 2 CFR 200.332(b) and 2 CFR 200.332(e), a pass-through entity is required to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of each sub-award for purposes of determining appropriate subrecipient monitoring requirements. Depending on the risk assessment, the pass-through entity should identify monitoring procedures to be performed in order to ensure proper accountability and compliance with program requirements and achievements of performance goals. Condition: The University’s controls were not operating effectively to reasonably ensure the University performed risk assessment and monitoring procedures for its subrecipients. As a result, the University did not comply with the compliance requirements for subrecipient monitoring. Cause: The University does not have processes and procedures in place related to risk assessment and subrecipient monitoring. Effect or potential effect: The University is not in compliance with federal grant requirements over subrecipient monitoring. Lack of properly documented evidence of subrecipient monitoring policies and procedures performed, including required risk assessments, could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: The University has two active awards under the program with subrecipients with an aggregate award value of approximately $71,000. The University has two subrecipients and for both subrecipients tested in the major program, there was no evidence that a risk assessment or monitoring of those subrecipients was performed. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to perform the required risk assessments and related monitoring, and maintain support that the risk assessments and related monitoring were performed as required. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-001 – Equipment and Real Property Management — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Also, in accordance with 2 CFR 200.313(d)(1), property records must be maintained that included a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. In accordance with 2 CFR 200.313(d)(2), a physical inventory of equipment and property must be taken, and the results reconciled with property records at least once every two years. Condition: The University’s controls were not operating effectively to reasonably ensure the University maintained property records with the above required information and performed the required physical inventory of equipment within the two previous years. As a result, the University did not comply with the compliance requirements for equipment and real property management. Cause: The University does not have processes and procedures in place related to equipment management, tracking and required physical inventories. Effect or potential effect: The University is not in compliance with federal grant requirements over the tracking and physical inventory of equipment. Improper equipment management procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: The University has five pieces of qualified equipment with an aggregate cost of approximately $119,000. For all sample selections tested in the major program, there was no process of tagging and tracking equipment purchased with federal funding, nor was there any evidence that physical inventories had been performed. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to tag and track the equipment purchased with federal funding, and maintain support that physical inventories were performed as required. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-002 – Procurement and Suspension and Debarment — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement methods outline by the University are properly followed. In accordance with 2 CFR 200.320, price quotations should be obtained from an adequate number of qualified sources for procurements that meet the small purchase procurement threshold. Condition: The University’s controls were not operating effectively to reasonably ensure the University obtained the proper number of price quotations as required using the small purchase procurement method. The University’s procurement policy requires price quotations be obtained from at least two sources when using the small purchase procurement method. The University only obtained one price quotation and no written documentation as the rational for selection was maintained. As a result, the University did not comply with the compliance requirements for procurement. Cause: The University does not have processes and procedures in place to ensure all procurements of goods and services are in accordance with Uniform Guidance and in accordance with it’s own procurement policy. Effect or potential effect: The University is not in compliance with federal grant requirements over small purchase procurements. Improper procurement procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: For all sample selections tested in the major program, one price quotation was obtained and no documentation was maintained as to the rationale for selection of the underlying vendor. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to obtain the required number of price quotations required under the small purchase procurement method, and maintain support for the required number of price quotations received under the small purchase procurement method. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-003 – Procurement and Suspension and Debarment — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure vendors are not suspended or debarred. In accordance with 2 CFR 200.212 and 200.318(h)), when a nonfederal entity enters into a contract or purchase with an entity (vendor or subrecipient), the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants when expending $25,000 or more in a year (or any amount in the case of a subrecipient). Condition: The University’s controls were not operating effectively to reasonably ensure the University verified the vendor was not suspended or debarred from participation in federal programs/grants prior to entering into a contract with the vendor. The University’s procurement policy requires vendor transactions equal to or greater than $25,000 undergo verification to ensure the vendor is not suspended or debarred, prior to entering into a contract with the vendor. Cause: A lack of controls to reasonably ensure this verification was performed. Effect or potential effect: The University did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Questioned costs: $0 Context: For all sample selections tested in the major program, documentation was not maintained that could provide evidence that the University had performed the required verification. None of the samples tested were identified as suspended or debarred entities. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop proper controls and procedures to determine whether vendors have been suspended or debarred prior to entering into contracts or purchase orders for all transactions, and maintain documentation supporting this verification. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-004 – Subrecipient Monitoring — Material Weakness Department of Health and Human Services Research and Development Cluster National Science Foundation, Assistance Listing No. 47.076 (STEM Education) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that risk assessment and monitoring are formally documented over subrecipient monitoring. In accordance with 2 CFR 200.332(b) and 2 CFR 200.332(e), a pass-through entity is required to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of each sub-award for purposes of determining appropriate subrecipient monitoring requirements. Depending on the risk assessment, the pass-through entity should identify monitoring procedures to be performed in order to ensure proper accountability and compliance with program requirements and achievements of performance goals. Condition: The University’s controls were not operating effectively to reasonably ensure the University performed risk assessment and monitoring procedures for its subrecipients. As a result, the University did not comply with the compliance requirements for subrecipient monitoring. Cause: The University does not have processes and procedures in place related to risk assessment and subrecipient monitoring. Effect or potential effect: The University is not in compliance with federal grant requirements over subrecipient monitoring. Lack of properly documented evidence of subrecipient monitoring policies and procedures performed, including required risk assessments, could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: The University has two active awards under the program with subrecipients with an aggregate award value of approximately $71,000. The University has two subrecipients and for both subrecipients tested in the major program, there was no evidence that a risk assessment or monitoring of those subrecipients was performed. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to perform the required risk assessments and related monitoring, and maintain support that the risk assessments and related monitoring were performed as required. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-005 – Special Tests – Enrollment Reporting — Material Weakness Department of Education Student Financial Assistance Cluster Assistance Listing No. 84.268 (Federal Direct Student Loans), 84.063 (Federal Pell Grant Program) Federal award year 2023-2024 Criteria: Under the Direct Loan programs, institutions are required to report student enrollment data via the National Student Loan Data System (NSLDS) using the Enrollment Reporting Roster file or Enrollment Maintenance page at least every 60 days. The reporting includes verification of enrollment data and communication of changes in student enrollment status within 60 days. Institutions are responsible for timely and accurate reporting, whether they report directly to the National Student Loan Data System (NSLDS) or through a third-party servicer. Condition: Student status changes were not reported accurately to NSLDS. Cause: The audit team noted that the University does not appear to have a control in place to identify in a timely manner inaccurate information that was provided to the NSLDS by their third party servicer. Effect or potential effect: The effect of the noncompliance is that NSLDS does not have timely and accurate enrollment. As noted in the Compliance Supplement, "The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions" which is not possible when the University does not provide accurate information. Questioned costs: None Context: We selected 40 students to evaluate reporting of status changes to NSLDS. Out of 40 students selected, 21 students who had graduated were reported to NSLDS as withdrawn, and two students, one who had graduated and one who had withdrawn, had no record reported to NSLDS. Identification as a repeat finding, if applicable: Not applicable. Recommendation: RSM recommends that the University implement a process to review information provided to NSLDS for accuracy in a timely manner such that the NSLDS receives accurate information within 60 days of status changes. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-005 – Special Tests – Enrollment Reporting — Material Weakness Department of Education Student Financial Assistance Cluster Assistance Listing No. 84.268 (Federal Direct Student Loans), 84.063 (Federal Pell Grant Program) Federal award year 2023-2024 Criteria: Under the Direct Loan programs, institutions are required to report student enrollment data via the National Student Loan Data System (NSLDS) using the Enrollment Reporting Roster file or Enrollment Maintenance page at least every 60 days. The reporting includes verification of enrollment data and communication of changes in student enrollment status within 60 days. Institutions are responsible for timely and accurate reporting, whether they report directly to the National Student Loan Data System (NSLDS) or through a third-party servicer. Condition: Student status changes were not reported accurately to NSLDS. Cause: The audit team noted that the University does not appear to have a control in place to identify in a timely manner inaccurate information that was provided to the NSLDS by their third party servicer. Effect or potential effect: The effect of the noncompliance is that NSLDS does not have timely and accurate enrollment. As noted in the Compliance Supplement, "The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions" which is not possible when the University does not provide accurate information. Questioned costs: None Context: We selected 40 students to evaluate reporting of status changes to NSLDS. Out of 40 students selected, 21 students who had graduated were reported to NSLDS as withdrawn, and two students, one who had graduated and one who had withdrawn, had no record reported to NSLDS. Identification as a repeat finding, if applicable: Not applicable. Recommendation: RSM recommends that the University implement a process to review information provided to NSLDS for accuracy in a timely manner such that the NSLDS receives accurate information within 60 days of status changes. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-005 – Special Tests – Enrollment Reporting — Material Weakness Department of Education Student Financial Assistance Cluster Assistance Listing No. 84.268 (Federal Direct Student Loans), 84.063 (Federal Pell Grant Program) Federal award year 2023-2024 Criteria: Under the Direct Loan programs, institutions are required to report student enrollment data via the National Student Loan Data System (NSLDS) using the Enrollment Reporting Roster file or Enrollment Maintenance page at least every 60 days. The reporting includes verification of enrollment data and communication of changes in student enrollment status within 60 days. Institutions are responsible for timely and accurate reporting, whether they report directly to the National Student Loan Data System (NSLDS) or through a third-party servicer. Condition: Student status changes were not reported accurately to NSLDS. Cause: The audit team noted that the University does not appear to have a control in place to identify in a timely manner inaccurate information that was provided to the NSLDS by their third party servicer. Effect or potential effect: The effect of the noncompliance is that NSLDS does not have timely and accurate enrollment. As noted in the Compliance Supplement, "The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions" which is not possible when the University does not provide accurate information. Questioned costs: None Context: We selected 40 students to evaluate reporting of status changes to NSLDS. Out of 40 students selected, 21 students who had graduated were reported to NSLDS as withdrawn, and two students, one who had graduated and one who had withdrawn, had no record reported to NSLDS. Identification as a repeat finding, if applicable: Not applicable. Recommendation: RSM recommends that the University implement a process to review information provided to NSLDS for accuracy in a timely manner such that the NSLDS receives accurate information within 60 days of status changes. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-005 – Special Tests – Enrollment Reporting — Material Weakness Department of Education Student Financial Assistance Cluster Assistance Listing No. 84.268 (Federal Direct Student Loans), 84.063 (Federal Pell Grant Program) Federal award year 2023-2024 Criteria: Under the Direct Loan programs, institutions are required to report student enrollment data via the National Student Loan Data System (NSLDS) using the Enrollment Reporting Roster file or Enrollment Maintenance page at least every 60 days. The reporting includes verification of enrollment data and communication of changes in student enrollment status within 60 days. Institutions are responsible for timely and accurate reporting, whether they report directly to the National Student Loan Data System (NSLDS) or through a third-party servicer. Condition: Student status changes were not reported accurately to NSLDS. Cause: The audit team noted that the University does not appear to have a control in place to identify in a timely manner inaccurate information that was provided to the NSLDS by their third party servicer. Effect or potential effect: The effect of the noncompliance is that NSLDS does not have timely and accurate enrollment. As noted in the Compliance Supplement, "The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions" which is not possible when the University does not provide accurate information. Questioned costs: None Context: We selected 40 students to evaluate reporting of status changes to NSLDS. Out of 40 students selected, 21 students who had graduated were reported to NSLDS as withdrawn, and two students, one who had graduated and one who had withdrawn, had no record reported to NSLDS. Identification as a repeat finding, if applicable: Not applicable. Recommendation: RSM recommends that the University implement a process to review information provided to NSLDS for accuracy in a timely manner such that the NSLDS receives accurate information within 60 days of status changes. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-005 – Special Tests – Enrollment Reporting — Material Weakness Department of Education Student Financial Assistance Cluster Assistance Listing No. 84.268 (Federal Direct Student Loans), 84.063 (Federal Pell Grant Program) Federal award year 2023-2024 Criteria: Under the Direct Loan programs, institutions are required to report student enrollment data via the National Student Loan Data System (NSLDS) using the Enrollment Reporting Roster file or Enrollment Maintenance page at least every 60 days. The reporting includes verification of enrollment data and communication of changes in student enrollment status within 60 days. Institutions are responsible for timely and accurate reporting, whether they report directly to the National Student Loan Data System (NSLDS) or through a third-party servicer. Condition: Student status changes were not reported accurately to NSLDS. Cause: The audit team noted that the University does not appear to have a control in place to identify in a timely manner inaccurate information that was provided to the NSLDS by their third party servicer. Effect or potential effect: The effect of the noncompliance is that NSLDS does not have timely and accurate enrollment. As noted in the Compliance Supplement, "The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions" which is not possible when the University does not provide accurate information. Questioned costs: None Context: We selected 40 students to evaluate reporting of status changes to NSLDS. Out of 40 students selected, 21 students who had graduated were reported to NSLDS as withdrawn, and two students, one who had graduated and one who had withdrawn, had no record reported to NSLDS. Identification as a repeat finding, if applicable: Not applicable. Recommendation: RSM recommends that the University implement a process to review information provided to NSLDS for accuracy in a timely manner such that the NSLDS receives accurate information within 60 days of status changes. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-001 – Equipment and Real Property Management — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Also, in accordance with 2 CFR 200.313(d)(1), property records must be maintained that included a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. In accordance with 2 CFR 200.313(d)(2), a physical inventory of equipment and property must be taken, and the results reconciled with property records at least once every two years. Condition: The University’s controls were not operating effectively to reasonably ensure the University maintained property records with the above required information and performed the required physical inventory of equipment within the two previous years. As a result, the University did not comply with the compliance requirements for equipment and real property management. Cause: The University does not have processes and procedures in place related to equipment management, tracking and required physical inventories. Effect or potential effect: The University is not in compliance with federal grant requirements over the tracking and physical inventory of equipment. Improper equipment management procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: The University has five pieces of qualified equipment with an aggregate cost of approximately $119,000. For all sample selections tested in the major program, there was no process of tagging and tracking equipment purchased with federal funding, nor was there any evidence that physical inventories had been performed. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to tag and track the equipment purchased with federal funding, and maintain support that physical inventories were performed as required. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-002 – Procurement and Suspension and Debarment — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement methods outline by the University are properly followed. In accordance with 2 CFR 200.320, price quotations should be obtained from an adequate number of qualified sources for procurements that meet the small purchase procurement threshold. Condition: The University’s controls were not operating effectively to reasonably ensure the University obtained the proper number of price quotations as required using the small purchase procurement method. The University’s procurement policy requires price quotations be obtained from at least two sources when using the small purchase procurement method. The University only obtained one price quotation and no written documentation as the rational for selection was maintained. As a result, the University did not comply with the compliance requirements for procurement. Cause: The University does not have processes and procedures in place to ensure all procurements of goods and services are in accordance with Uniform Guidance and in accordance with it’s own procurement policy. Effect or potential effect: The University is not in compliance with federal grant requirements over small purchase procurements. Improper procurement procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: For all sample selections tested in the major program, one price quotation was obtained and no documentation was maintained as to the rationale for selection of the underlying vendor. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to obtain the required number of price quotations required under the small purchase procurement method, and maintain support for the required number of price quotations received under the small purchase procurement method. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-003 – Procurement and Suspension and Debarment — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure vendors are not suspended or debarred. In accordance with 2 CFR 200.212 and 200.318(h)), when a nonfederal entity enters into a contract or purchase with an entity (vendor or subrecipient), the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants when expending $25,000 or more in a year (or any amount in the case of a subrecipient). Condition: The University’s controls were not operating effectively to reasonably ensure the University verified the vendor was not suspended or debarred from participation in federal programs/grants prior to entering into a contract with the vendor. The University’s procurement policy requires vendor transactions equal to or greater than $25,000 undergo verification to ensure the vendor is not suspended or debarred, prior to entering into a contract with the vendor. Cause: A lack of controls to reasonably ensure this verification was performed. Effect or potential effect: The University did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Questioned costs: $0 Context: For all sample selections tested in the major program, documentation was not maintained that could provide evidence that the University had performed the required verification. None of the samples tested were identified as suspended or debarred entities. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop proper controls and procedures to determine whether vendors have been suspended or debarred prior to entering into contracts or purchase orders for all transactions, and maintain documentation supporting this verification. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-004 – Subrecipient Monitoring — Material Weakness Department of Health and Human Services Research and Development Cluster National Science Foundation, Assistance Listing No. 47.076 (STEM Education) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that risk assessment and monitoring are formally documented over subrecipient monitoring. In accordance with 2 CFR 200.332(b) and 2 CFR 200.332(e), a pass-through entity is required to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of each sub-award for purposes of determining appropriate subrecipient monitoring requirements. Depending on the risk assessment, the pass-through entity should identify monitoring procedures to be performed in order to ensure proper accountability and compliance with program requirements and achievements of performance goals. Condition: The University’s controls were not operating effectively to reasonably ensure the University performed risk assessment and monitoring procedures for its subrecipients. As a result, the University did not comply with the compliance requirements for subrecipient monitoring. Cause: The University does not have processes and procedures in place related to risk assessment and subrecipient monitoring. Effect or potential effect: The University is not in compliance with federal grant requirements over subrecipient monitoring. Lack of properly documented evidence of subrecipient monitoring policies and procedures performed, including required risk assessments, could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: The University has two active awards under the program with subrecipients with an aggregate award value of approximately $71,000. The University has two subrecipients and for both subrecipients tested in the major program, there was no evidence that a risk assessment or monitoring of those subrecipients was performed. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to perform the required risk assessments and related monitoring, and maintain support that the risk assessments and related monitoring were performed as required. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-001 – Equipment and Real Property Management — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Also, in accordance with 2 CFR 200.313(d)(1), property records must be maintained that included a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. In accordance with 2 CFR 200.313(d)(2), a physical inventory of equipment and property must be taken, and the results reconciled with property records at least once every two years. Condition: The University’s controls were not operating effectively to reasonably ensure the University maintained property records with the above required information and performed the required physical inventory of equipment within the two previous years. As a result, the University did not comply with the compliance requirements for equipment and real property management. Cause: The University does not have processes and procedures in place related to equipment management, tracking and required physical inventories. Effect or potential effect: The University is not in compliance with federal grant requirements over the tracking and physical inventory of equipment. Improper equipment management procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: The University has five pieces of qualified equipment with an aggregate cost of approximately $119,000. For all sample selections tested in the major program, there was no process of tagging and tracking equipment purchased with federal funding, nor was there any evidence that physical inventories had been performed. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to tag and track the equipment purchased with federal funding, and maintain support that physical inventories were performed as required. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-002 – Procurement and Suspension and Debarment — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement methods outline by the University are properly followed. In accordance with 2 CFR 200.320, price quotations should be obtained from an adequate number of qualified sources for procurements that meet the small purchase procurement threshold. Condition: The University’s controls were not operating effectively to reasonably ensure the University obtained the proper number of price quotations as required using the small purchase procurement method. The University’s procurement policy requires price quotations be obtained from at least two sources when using the small purchase procurement method. The University only obtained one price quotation and no written documentation as the rational for selection was maintained. As a result, the University did not comply with the compliance requirements for procurement. Cause: The University does not have processes and procedures in place to ensure all procurements of goods and services are in accordance with Uniform Guidance and in accordance with it’s own procurement policy. Effect or potential effect: The University is not in compliance with federal grant requirements over small purchase procurements. Improper procurement procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: For all sample selections tested in the major program, one price quotation was obtained and no documentation was maintained as to the rationale for selection of the underlying vendor. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to obtain the required number of price quotations required under the small purchase procurement method, and maintain support for the required number of price quotations received under the small purchase procurement method. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-003 – Procurement and Suspension and Debarment — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure vendors are not suspended or debarred. In accordance with 2 CFR 200.212 and 200.318(h)), when a nonfederal entity enters into a contract or purchase with an entity (vendor or subrecipient), the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants when expending $25,000 or more in a year (or any amount in the case of a subrecipient). Condition: The University’s controls were not operating effectively to reasonably ensure the University verified the vendor was not suspended or debarred from participation in federal programs/grants prior to entering into a contract with the vendor. The University’s procurement policy requires vendor transactions equal to or greater than $25,000 undergo verification to ensure the vendor is not suspended or debarred, prior to entering into a contract with the vendor. Cause: A lack of controls to reasonably ensure this verification was performed. Effect or potential effect: The University did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Questioned costs: $0 Context: For all sample selections tested in the major program, documentation was not maintained that could provide evidence that the University had performed the required verification. None of the samples tested were identified as suspended or debarred entities. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop proper controls and procedures to determine whether vendors have been suspended or debarred prior to entering into contracts or purchase orders for all transactions, and maintain documentation supporting this verification. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-004 – Subrecipient Monitoring — Material Weakness Department of Health and Human Services Research and Development Cluster National Science Foundation, Assistance Listing No. 47.076 (STEM Education) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that risk assessment and monitoring are formally documented over subrecipient monitoring. In accordance with 2 CFR 200.332(b) and 2 CFR 200.332(e), a pass-through entity is required to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of each sub-award for purposes of determining appropriate subrecipient monitoring requirements. Depending on the risk assessment, the pass-through entity should identify monitoring procedures to be performed in order to ensure proper accountability and compliance with program requirements and achievements of performance goals. Condition: The University’s controls were not operating effectively to reasonably ensure the University performed risk assessment and monitoring procedures for its subrecipients. As a result, the University did not comply with the compliance requirements for subrecipient monitoring. Cause: The University does not have processes and procedures in place related to risk assessment and subrecipient monitoring. Effect or potential effect: The University is not in compliance with federal grant requirements over subrecipient monitoring. Lack of properly documented evidence of subrecipient monitoring policies and procedures performed, including required risk assessments, could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: The University has two active awards under the program with subrecipients with an aggregate award value of approximately $71,000. The University has two subrecipients and for both subrecipients tested in the major program, there was no evidence that a risk assessment or monitoring of those subrecipients was performed. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to perform the required risk assessments and related monitoring, and maintain support that the risk assessments and related monitoring were performed as required. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-001 – Equipment and Real Property Management — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Also, in accordance with 2 CFR 200.313(d)(1), property records must be maintained that included a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. In accordance with 2 CFR 200.313(d)(2), a physical inventory of equipment and property must be taken, and the results reconciled with property records at least once every two years. Condition: The University’s controls were not operating effectively to reasonably ensure the University maintained property records with the above required information and performed the required physical inventory of equipment within the two previous years. As a result, the University did not comply with the compliance requirements for equipment and real property management. Cause: The University does not have processes and procedures in place related to equipment management, tracking and required physical inventories. Effect or potential effect: The University is not in compliance with federal grant requirements over the tracking and physical inventory of equipment. Improper equipment management procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: The University has five pieces of qualified equipment with an aggregate cost of approximately $119,000. For all sample selections tested in the major program, there was no process of tagging and tracking equipment purchased with federal funding, nor was there any evidence that physical inventories had been performed. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to tag and track the equipment purchased with federal funding, and maintain support that physical inventories were performed as required. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-002 – Procurement and Suspension and Debarment — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement methods outline by the University are properly followed. In accordance with 2 CFR 200.320, price quotations should be obtained from an adequate number of qualified sources for procurements that meet the small purchase procurement threshold. Condition: The University’s controls were not operating effectively to reasonably ensure the University obtained the proper number of price quotations as required using the small purchase procurement method. The University’s procurement policy requires price quotations be obtained from at least two sources when using the small purchase procurement method. The University only obtained one price quotation and no written documentation as the rational for selection was maintained. As a result, the University did not comply with the compliance requirements for procurement. Cause: The University does not have processes and procedures in place to ensure all procurements of goods and services are in accordance with Uniform Guidance and in accordance with it’s own procurement policy. Effect or potential effect: The University is not in compliance with federal grant requirements over small purchase procurements. Improper procurement procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: For all sample selections tested in the major program, one price quotation was obtained and no documentation was maintained as to the rationale for selection of the underlying vendor. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to obtain the required number of price quotations required under the small purchase procurement method, and maintain support for the required number of price quotations received under the small purchase procurement method. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-003 – Procurement and Suspension and Debarment — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure vendors are not suspended or debarred. In accordance with 2 CFR 200.212 and 200.318(h)), when a nonfederal entity enters into a contract or purchase with an entity (vendor or subrecipient), the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants when expending $25,000 or more in a year (or any amount in the case of a subrecipient). Condition: The University’s controls were not operating effectively to reasonably ensure the University verified the vendor was not suspended or debarred from participation in federal programs/grants prior to entering into a contract with the vendor. The University’s procurement policy requires vendor transactions equal to or greater than $25,000 undergo verification to ensure the vendor is not suspended or debarred, prior to entering into a contract with the vendor. Cause: A lack of controls to reasonably ensure this verification was performed. Effect or potential effect: The University did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Questioned costs: $0 Context: For all sample selections tested in the major program, documentation was not maintained that could provide evidence that the University had performed the required verification. None of the samples tested were identified as suspended or debarred entities. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop proper controls and procedures to determine whether vendors have been suspended or debarred prior to entering into contracts or purchase orders for all transactions, and maintain documentation supporting this verification. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-004 – Subrecipient Monitoring — Material Weakness Department of Health and Human Services Research and Development Cluster National Science Foundation, Assistance Listing No. 47.076 (STEM Education) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that risk assessment and monitoring are formally documented over subrecipient monitoring. In accordance with 2 CFR 200.332(b) and 2 CFR 200.332(e), a pass-through entity is required to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of each sub-award for purposes of determining appropriate subrecipient monitoring requirements. Depending on the risk assessment, the pass-through entity should identify monitoring procedures to be performed in order to ensure proper accountability and compliance with program requirements and achievements of performance goals. Condition: The University’s controls were not operating effectively to reasonably ensure the University performed risk assessment and monitoring procedures for its subrecipients. As a result, the University did not comply with the compliance requirements for subrecipient monitoring. Cause: The University does not have processes and procedures in place related to risk assessment and subrecipient monitoring. Effect or potential effect: The University is not in compliance with federal grant requirements over subrecipient monitoring. Lack of properly documented evidence of subrecipient monitoring policies and procedures performed, including required risk assessments, could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: The University has two active awards under the program with subrecipients with an aggregate award value of approximately $71,000. The University has two subrecipients and for both subrecipients tested in the major program, there was no evidence that a risk assessment or monitoring of those subrecipients was performed. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to perform the required risk assessments and related monitoring, and maintain support that the risk assessments and related monitoring were performed as required. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-001 – Equipment and Real Property Management — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Also, in accordance with 2 CFR 200.313(d)(1), property records must be maintained that included a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. In accordance with 2 CFR 200.313(d)(2), a physical inventory of equipment and property must be taken, and the results reconciled with property records at least once every two years. Condition: The University’s controls were not operating effectively to reasonably ensure the University maintained property records with the above required information and performed the required physical inventory of equipment within the two previous years. As a result, the University did not comply with the compliance requirements for equipment and real property management. Cause: The University does not have processes and procedures in place related to equipment management, tracking and required physical inventories. Effect or potential effect: The University is not in compliance with federal grant requirements over the tracking and physical inventory of equipment. Improper equipment management procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: The University has five pieces of qualified equipment with an aggregate cost of approximately $119,000. For all sample selections tested in the major program, there was no process of tagging and tracking equipment purchased with federal funding, nor was there any evidence that physical inventories had been performed. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to tag and track the equipment purchased with federal funding, and maintain support that physical inventories were performed as required. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-002 – Procurement and Suspension and Debarment — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement methods outline by the University are properly followed. In accordance with 2 CFR 200.320, price quotations should be obtained from an adequate number of qualified sources for procurements that meet the small purchase procurement threshold. Condition: The University’s controls were not operating effectively to reasonably ensure the University obtained the proper number of price quotations as required using the small purchase procurement method. The University’s procurement policy requires price quotations be obtained from at least two sources when using the small purchase procurement method. The University only obtained one price quotation and no written documentation as the rational for selection was maintained. As a result, the University did not comply with the compliance requirements for procurement. Cause: The University does not have processes and procedures in place to ensure all procurements of goods and services are in accordance with Uniform Guidance and in accordance with it’s own procurement policy. Effect or potential effect: The University is not in compliance with federal grant requirements over small purchase procurements. Improper procurement procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: For all sample selections tested in the major program, one price quotation was obtained and no documentation was maintained as to the rationale for selection of the underlying vendor. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to obtain the required number of price quotations required under the small purchase procurement method, and maintain support for the required number of price quotations received under the small purchase procurement method. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-003 – Procurement and Suspension and Debarment — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure vendors are not suspended or debarred. In accordance with 2 CFR 200.212 and 200.318(h)), when a nonfederal entity enters into a contract or purchase with an entity (vendor or subrecipient), the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants when expending $25,000 or more in a year (or any amount in the case of a subrecipient). Condition: The University’s controls were not operating effectively to reasonably ensure the University verified the vendor was not suspended or debarred from participation in federal programs/grants prior to entering into a contract with the vendor. The University’s procurement policy requires vendor transactions equal to or greater than $25,000 undergo verification to ensure the vendor is not suspended or debarred, prior to entering into a contract with the vendor. Cause: A lack of controls to reasonably ensure this verification was performed. Effect or potential effect: The University did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Questioned costs: $0 Context: For all sample selections tested in the major program, documentation was not maintained that could provide evidence that the University had performed the required verification. None of the samples tested were identified as suspended or debarred entities. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop proper controls and procedures to determine whether vendors have been suspended or debarred prior to entering into contracts or purchase orders for all transactions, and maintain documentation supporting this verification. View of responsible officials: Management agrees with this finding. See corrective action plan.

Finding 2024-004 – Subrecipient Monitoring — Material Weakness Department of Health and Human Services Research and Development Cluster National Science Foundation, Assistance Listing No. 47.076 (STEM Education) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that risk assessment and monitoring are formally documented over subrecipient monitoring. In accordance with 2 CFR 200.332(b) and 2 CFR 200.332(e), a pass-through entity is required to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of each sub-award for purposes of determining appropriate subrecipient monitoring requirements. Depending on the risk assessment, the pass-through entity should identify monitoring procedures to be performed in order to ensure proper accountability and compliance with program requirements and achievements of performance goals. Condition: The University’s controls were not operating effectively to reasonably ensure the University performed risk assessment and monitoring procedures for its subrecipients. As a result, the University did not comply with the compliance requirements for subrecipient monitoring. Cause: The University does not have processes and procedures in place related to risk assessment and subrecipient monitoring. Effect or potential effect: The University is not in compliance with federal grant requirements over subrecipient monitoring. Lack of properly documented evidence of subrecipient monitoring policies and procedures performed, including required risk assessments, could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: The University has two active awards under the program with subrecipients with an aggregate award value of approximately $71,000. The University has two subrecipients and for both subrecipients tested in the major program, there was no evidence that a risk assessment or monitoring of those subrecipients was performed. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to perform the required risk assessments and related monitoring, and maintain support that the risk assessments and related monitoring were performed as required. View of responsible officials: Management agrees with this finding. See corrective action plan.